Event:16 September | Carbon Removal Policy Summit
Permitting Process StreamliningSystem and Capacity Enablers

PERMITTING PROCESS STREAMLINING

Lever last updated: 14 September 2026

Reorganising how permitting authorities receive and decide project applications.

Cost

Very low to Medium

Authorities pay for guidance, specialist assessors, shared application systems and coordination. Improving one existing process needs limited additional resources; a national programme with recruitment and backlog reduction requires substantially more. Applicant savings are separate.

Complexity

Low to High

Shared guidance can use existing powers. Reassigning decisions or recognising foreign approvals may require legislation, agreed standards and multi-agency procedures. Cross-border reform must identify who assesses each issue and retains legal responsibility.

Timeline

Very short to Medium

As planning estimates, coordinated evidence requests can reduce rework on live applications within a year. New laws, specialist teams or cross-border recognition arrangements may need two to five years before applicants experience more predictable decisions.

Integrity, Transparency & MRV

1–2

Innovation & Cost Reduction

1–2

Social & Environmental Safeguards

1–3

Energy, Transport & Storage Infrastructure

1–3

Inputs & Capacity

1–2

Demand Formation

N/A

Bankability and Cost of Capital

2–3

Policy Architecture & Coordination

2–4

Overview

Permitting authorities can reorganise how they receive and decide project applications, reducing repeated work and avoidable waiting. They may appoint one contact to coordinate agencies, combine information requests, run suitable reviews in parallel and recruit specialist assessors. For a cross-border project, authorities in neighbouring countries can coordinate their schedules and assessments so one part of the route is not held up by an avoidable procedural mismatch elsewhere. Where the law allows, they can also agree to accept equivalent technical evidence or assessments already checked by another authority. Applied to CDR facilities and their infrastructure, these changes make development costs and investment schedules easier to predict. Each authority remains responsible for the approvals within its jurisdiction, including environmental assessment and public consultation.

Key Considerations

Authorities should identify every required approval and who is legally responsible for it. For cross-border projects, they should agree which information can be submitted once, which studies can be assessed jointly and which local impacts require separate examination. Mutual recognition should specify exactly what one authority may rely on from another, such as a test result or an equivalent technical assessment. Recognising evidence does not automatically make a foreign construction or storage permit valid domestically; recognition of an approval itself requires the necessary legal authority. Deadlines need rules for incomplete applications, further studies and justified extensions. Novel methods may require guidance and trained reviewers before standard timetables are realistic. Public participation should begin early enough to influence the project, with information accessible in the affected jurisdictions.

Opportunities

Reducing repeated studies and uncoordinated waiting periods can lower project-development costs and make staff and financing needs easier to plan. Clear guidance is particularly valuable for smaller developers that cannot maintain large permitting teams. Reviews of initial projects can establish reusable application templates and reveal technical questions that regulators should answer consistently. Predictable decisions also help removal developers coordinate their plant with energy and storage providers. The improvement comes from better administration and earlier resolution of evidence gaps, which can support both timely approval of suitable projects and timely refusal of unsuitable ones.

Risks

Deadlines imposed without enough trained staff can shorten scrutiny or shift delays to the period before an application is accepted. Agencies may still duplicate work if they cannot agree whose assessment they can rely on. Across borders, incompatible permit conditions or an unresolved approval in one country can delay the whole project even when the other countries decide promptly. Recognition arrangements can also leave gaps if no authority checks a material local impact. Communities need enough time and information to participate, and standard templates must accommodate differences between methods and sites. Evaluation should examine the whole process and the quality of decisions, rather than reward authorities solely for issuing permits quickly.

Monitoring and Evaluation

Authorities should measure time from initial submission, acceptance of a complete application and each review stage to decision, including further evidence requests and appeals. For cross-border projects, they should compare the full route's approval schedule and record studies reused, inconsistent conditions and delays passed between authorities. Comparisons should use similar project types. Backlogs, staff availability, public participation and post-approval compliance can reveal whether delays were removed or shifted. The findings should guide improvements to guidance, staffing and coordination while retaining sound decisions.

Stakeholder Engagement

The authority leading the reform should map approvals with the bodies legally responsible for them, including those in neighbouring countries where a project crosses a border. Together they should decide which evidence and assessments can be shared or recognised and who retains each decision. Developers can identify repeated studies and inconsistent requests, while independent experts help specify necessary evidence. Communities should test whether information and consultation are accessible and timely on each side of the border. Permitting staff should help design workable guidance and workloads.

Governance Levels

SupranationalNationalRegional / StateCity / Municipal

Authorities holding planning, environmental, construction or storage powers can simplify and coordinate their processes. National and supranational law can set common procedures and deadlines, while state and municipal bodies implement relevant reviews. Private applicants and advisers supply information but cannot streamline statutory duties by agreement among themselves.

Implementation Strategies

  • Authorities should map the full approval process, including initial advice, completeness checks, specialist reviews and appeals. They should identify duplication and agree a common schedule with relevant domestic and neighbouring authorities, assigning a coordinator alongside each statutory decision-maker.

  • Authorities should publish evidence requirements and realistic schedules, including consultation and reasons for extensions. They can align requests, assess suitable evidence jointly and recognise equivalent assessments where legally permitted, while identifying any site-specific work each authority still requires.

  • Regulators should recruit or train specialists and share technical resources. They can test revised procedures on different project types, including smaller or novel activities, and revise templates where a standard application misses material risks.

  • Authorities should compare processing stages, applicant rework, public participation and post-approval compliance with the previous process. Those findings should guide staffing and procedural changes and be shared with other permitting bodies.

Case Studies

TEN-E permitting arrangements

The EU's Trans-European Networks for Energy Regulation, or TEN-E, gives designated priority infrastructure a coordinated permitting route, including eligible CO₂ networks. A national lead authority may issue an integrated decision, coordinate several decisions or monitor decisions retained by specialist bodies. For projects requiring decisions in several Member States, Article 8 requires their authorities to cooperate and encourages joint procedures, particularly environmental assessment. Article 9 also coordinates the timing of early public consultation across borders. The general process allows up to two years before a complete application and eighteen months for the statutory decision, with exceptional extensions. These provisions offer a concrete model for sharing work and aligning decisions across a CO₂ route. They do not create a single permit valid everywhere or remove each project's environmental requirements.

US Class VI primacy

The US Environmental Protection Agency's Class VI programme regulates wells used for permanent geological CO₂ storage. In November 2025, EPA announced approval of Texas's primary enforcement responsibility, commonly called primacy. This gives the state responsibility for issuing and overseeing those permits through the Railroad Commission of Texas, its oil and gas regulator, alongside its existing underground-injection responsibilities. EPA first assessed whether the state's legal and technical programme met the federal requirements. The arrangement illustrates a concrete administrative option, placing review with a competent state body that can coordinate related decisions and develop local expertise. Storage for direct air capture and bioenergy projects can use that route. The transfer itself does not establish that decisions became faster; that requires application and compliance evidence after implementation.

France's Project of Major National Interest designation

France's 2023 Green Industry Act created the Project of Major National Interest designation, or PINM, for strategically important projects approved by government decree. The state can coordinate changes needed to make planning documents compatible with a designated project, and state authorities decide its urban-planning permits. Required local-authority agreement, environmental assessment and public participation remain part of the planning process. Eastman's proposed plastics-recycling plant in Normandy received the designation in July 2024. In February 2026, France's highest administrative court upheld that designation while explaining that it did not itself grant an exemption from protected-species rules. A CDR developer could seek the same route if its project meets the statutory national-importance tests. The mechanism concentrates responsibility for strategic approvals and resolves planning conflicts earlier; designation alone does not prove shorter construction times or remove the need for project-specific environmental permissions.

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