This document covers the schema design, priority logic, confidence framework, keyword dictionary, and example coding scenarios for the NEPA trigger classification pipeline.
Primary vs. secondary trigger logic
Many projects have multiple forms of federal involvement. For example: - A transmission line may cross federal land and require a permit - A transit project may receive federal funding and require a USACE permit - A renewable project may be on BLM land and involve a federal right-of-way grant
Rule: assign the primary trigger as the federal nexus most directly responsible for the agency’s NEPA decision.
Priority order for primary trigger assignment (as implemented)
Use this only when the text is ambiguous. This is the order implemented in TRIGGER_HIERARCHY in 01_extract_nepa_trigger.py:
federal_programfederal_direct_actionpma (Power Marketing Administration (PMA) + Tennessee Valley Authority (TVA))federal_property_transactionfederal_landfederal_permitfederal_fundingunknown
Why this order: A programmatic umbrella outranks everything because it changes the level of the NEPA review itself (see the example below). Below that, priority goes to the federal role when the agency is the principal actor or decision-maker, rather than simply one source of support or one regulatory checkpoint. PMA/TVA projects are elevated above land and permit because the agency identity is the clearest nexus signal for those entities.
Note (updated 2026-07): the ordering is no longer empirically inert for federal_program — 17 projects in the current published output carry federal_program together with another class in nepa_trigger_multi (7 + federal_funding, 4 + federal_land, 3 + federal_direct_action, 3 + federal_permit), and in all 17 cases the hierarchy determines the primary (federal_program wins).
Examples: - If BLM is approving a right-of-way across federal land, federal_land is often more informative than federal_permit - If DOE is building or directly implementing the action, federal_direct_action should outrank federal_funding - If the document is a programmatic plan, federal_program should outrank narrower project features - If BPA, WAPA, SEPA, SWPA, or TVA is the lead agency, assign pma as primary even when the project also crosses federal land or requires a permit
Keyword dictionary
Keywords are a first-pass filter only — see the “Important caution” note below.
federal_funding
Indicative terms: federal funding, federally funded, federal financial assistance, grant, cooperative agreement, loan guarantee, cost share, reimbursable agreement, funded through
Agencies often associated: DOE, DOT, HUD, EPA, USDA, FEMA
federal_land
Indicative terms: federal land, public lands, right-of-way, ROW grant, special use permit, easement, crossing federal land, National Forest System lands, BLM land, Bureau of Land Management land, Forest Service land, military reservation
Agencies often associated: BLM, USFS, NPS, Bureau of Reclamation, DoD, USACE (when property control is central)
federal_permit
Indicative terms: permit, license, authorization, approval, certification, permit application, jurisdictional waters, Section 404, incidental take permit, license amendment
Agencies often associated: USACE, FERC, FAA, FCC, NOAA/NMFS, USFWS
federal_direct_action
Indicative terms: agency proposes to, the Bureau proposes, the Department proposes, federal action consists of, construct, install, upgrade, operate, implement, federal facility, base operations
Agencies often associated: DoD, VA, USFS, BLM, Bureau of Reclamation, DOE, USACE
federal_program
Indicative terms: programmatic EIS, PEIS, site-wide EIS (SWEIS), Tier 1 review, policy, rulemaking, integrated resource plan, program-wide, nationwide, regional plan
Note: land-management programmatic reviews (e.g., vegetation management PEAs, leasing program PEIS on federal lands, BLM wind/solar PEIS, Western Solar Plan, Section 368 corridor PEIS) are classified as federal_land, not federal_program.
pma — Power Marketing Administration (PMA) + Tennessee Valley Authority (TVA)
Indicative terms: Bonneville Power Administration, BPA, Western Area Power Administration, WAPA, Southeastern Power Administration, SEPA, Southwestern Power Administration, SWPA, Power Marketing Administration, Tennessee Valley Authority, TVA
Agencies: BPA, WAPA, SEPA, SWPA, TVA, and any generic PMA. Assign pma as the primary trigger whenever one of these entities is the lead or sponsoring agency, even when the project also involves federal land (e.g., transmission line ROW grants) or permits. Add federal_land or federal_permit as secondary triggers when applicable.
federal_property_transaction
Indicative terms: land exchange, conveyance, disposal, transfer, sale of federal land, acquisition, parcel transfer
Important caution
Do not classify solely on keyword presence. For example: - “permit” may appear in a background section even if the true trigger is federal land - “funding” may be mentioned historically without being the current federal nexus - “right-of-way” can be central or merely descriptive
Recommended rules engine: 1. detect candidate categories 2. extract surrounding evidence text 3. rank likely categories 4. assign confidence 5. send low-confidence cases to review