NEPA Decarbonization Technology Analysis: Deliverable 1

Why NEPA Was Triggered — Classifying the Federal Nexus

Published

June 26, 2026

Executive Summary

Key Findings
  • Funding is the dominant NEPA trigger, accounting for 9,125 projects (44.0%). DOE’s grant and loan guarantee portfolio is the single largest source of decarbonization NEPA reviews.
  • Direct Action is the second-largest class at 3,092 projects (14.9%), driven by federal power authorities (BPA, WAPA, Power Marketing Administrations) building and operating transmission and generation infrastructure directly.
  • Land accounts for 3,666 projects (17.7%)—BLM and Forest Service right-of-way and special use permits for utility-scale renewables on public land.
  • Review process profiles differ sharply by trigger: Categorical Exclusions are dominated by Funding (DOE’s CE authority for grants); Environmental Impact Statements skew toward Land and Direct Action; Environmental Assessments show the most balanced trigger mix.
  • Trigger class predicts regulatory intensity: Funding projects are overwhelmingly CEs; Land and Permit generate proportionally more EAs and EISs—land disturbance and regulatory licensing carry heavier review burdens than financial assistance.
  • Technology patterns reflect nexus logic: Transmission has the highest Direct Action share (PMAs build federal lines); Solar and Wind split between Land (BLM right-of-way) and Funding (DOE grants); CCS and Energy Storage skew toward Funding via DOE emerging technology programs.

This report delivers:

Reasons why NEPA was triggered (e.g., federal land, federal funding) for different types of projects.

Methodology

Trigger Definitions

NEPA applies whenever a federal nexus exists—but the nature of that nexus varies. We classify each project into one of seven mutually exclusive primary trigger classes using a strict priority ordering (highest to lowest). When evidence points to multiple classes, the higher-priority class wins as the primary; lower-priority matches are retained as secondary triggers.

Trigger Federal Nexus
Direct Action The federal agency is the proposer — building, operating, or managing the project (e.g., federal power lines, agency construction, military facilities)
Program A programmatic EIS, land-use plan, or rulemaking umbrella covers the action — the NEPA review is at the policy or program level
Property Transaction A land exchange, disposal, or conveyance of federal property is the triggering event
Land A private or state actor seeks a right-of-way, special use permit, or lease on federal land (BLM, National Forest)
Permit A federal license or permit issued by a regulatory body (FERC license, FAA authorization, Section 404 dredge-and-fill) is the primary nexus
Funding Federal grant, loan guarantee, or financial assistance is the trigger (DOE loan program, IRA grant, Rural Energy for America Program)
Unknown NEPA is confirmed but the trigger cannot be reliably identified from available text or metadata

Secondary triggers are stored separately in the nepa_trigger_secondary field; 1,315 projects have more than one trigger class detected.

Classification Pipeline

Trigger classification runs in five tiers plus a manual-label seed. Each tier feeds into the next; a project is finalized the moment it clears a tier’s acceptance gate and is never re-processed by later tiers. This preserves precision at each level while reserving compute- intensive methods for the genuinely ambiguous cases.

Tier Method Projects Cumulative % Resolved
Tier 0 — Manual labels Hand-labeled seed set loaded first and locked — no downstream tier can override a manual label 890 890 4.3%
Tier 1a — Agency metadata Known agency-to-class lookup: FERC → Permit; BLM/USFS → Land; BPA/WAPA/PMAs → Direct Action; DOE/USACE routed to Tier 4 for document confirmation 5,568 6,458 31.2%
Tier 1b — Title + description Regex patterns on concatenated title and description; specificity-ranked; high-confidence matches auto-accepted 1,751 8,209 39.6%
Tier 2 — Document title scan Regex on document-level titles in the CE/EA/EIS page corpus; catches programmatic EIS, ROW grants, and FERC license amendments 62 8,271 39.9%
Tier 3 — Purpose-and-need Regex extraction from Purpose-and-Need section; auto-accepts BLM/NFS land, NPDES permit, and agency grant patterns 435 8,706 42.0%
Tier 3b — SetFit (DOE CE) Sentence-transformer + logistic regression head fine-tuned on labeled DOE CE examples; runs only on DOE Categorical Exclusions 10,846 19,552 94.3%
Tier 4 — NLI adjudication Cross-encoder NLI: retrieved passage vs. natural-language class hypothesis; must pass doc score, margin, and affirmative-support gates 37 19,589 94.5%
— Unknown Failed all three Tier 4 gates; queued for Tier 5 LLM review or manual inspection 1,136 — 5.5%

Total resolved: 20,225 / 20,725 (97.6%).

The pipeline is implemented in phase2/code/deliverable01/01_extract_nepa_trigger.py. The full output schema is documented in phase2/architecture/deliverables/deliverable01.md.

Evidence Sources

The table below shows how many projects were classified from each evidence source and at what confidence level. Agency Metadata reflects Tier 1a deterministic mappings; Purpose and Need and Project Description reflect document-level text extraction (Tiers 1b–3); Document Title reflects Tier 2 document title scanning.

Table 1: Trigger classification counts by evidence source and confidence level.
Evidence Source Confidence Level Total
High Medium Low
Project Description 13,066 0 0 13,066
Agency Metadata 6,731 0 0 6,731
Document Text 257 29 489 775
Purpose and Need 115 0 0 115
Document Title 27 0 11 38

Next Steps and Known Gaps

Item Status Notes
Tier 5 — LLM fallback Not run 500 unknowns queued; run with --use-llm flag when budget is approved
Secondary trigger analysis Pending Secondary triggers are populated in output; multi-label cross-tabulations deferred to next iteration
Multi-process / tiered review integration Future — D2 dependency Combining trigger class with programmatic and tiered review status requires joining D1 + D2 outputs

Trigger Distribution Overview

Figure 1 shows the total number of decarbonization projects in each primary trigger class. Funding is by far the largest class—DOE’s vast grant and loan guarantee portfolio generates more NEPA reviews than any other federal nexus. Direct Action is second, driven by federal power authorities (BPA, WAPA) building and operating transmission and generation infrastructure directly. Land is third, reflecting utility-scale renewables sited on BLM and National Forest lands under right-of-way or special use permits.

Permit, Program, and Property Transaction together account for fewer than 811 projects (3.9%)— these are real but narrow categories of federal nexus.

Figure 1: Primary NEPA trigger counts across 20,725 decarbonization projects. Colors match the trigger legend used throughout this report.

Trigger Type by Review Process

How triggers distribute across CE, EA, and EIS

Figure 2 shows what share of each review process is driven by each trigger class. The three processes reveal strikingly different trigger profiles:

  • Categorical Exclusions are dominated by Funding—DOE’s clean energy grant and loan programs generate an enormous volume of low-complexity actions that qualify for CE-level review.
  • Environmental Assessments show a more balanced mix: Land (BLM/USFS right-of-way grants for solar and wind) and Direct Action (federal transmission projects) each contribute meaningfully alongside Funding.
  • Environmental Impact Statements skew heavily toward Land and Direct Action—larger, more complex projects requiring full EIS review tend to be sited on public lands or are federally constructed.

Figure 2: Primary NEPA trigger type by review process across 20,725 decarbonization projects. Percentage labels shown for segments > 5%.

What review process does each trigger class use?

Figure 3 inverts the view: for each trigger class, it shows the share of projects that went through CE, EA, or EIS review. This reveals the typical regulatory pathway associated with each nexus type.

  • Funding is overwhelmingly resolved at the CE level—consistent with DOE’s categorical exclusion authority for grants and financial assistance that don’t individually require significant analysis.
  • Direct Action and to a a somewhat lesser degree Property Transaction are still overwhelmingly CE level reviews, owing to the clear rote transactional natural of these actions that likely require less rigorous reviews.
  • Land, Program, and Permit produce substantially more EAs and EISs per project than Funding, Direct Action, and Property Transaction, reflecting the environmental scrutiny attached to land disturbance, programming, and regulatory licensing.

Figure 3: Share of CE, EA, and EIS reviews within each primary trigger class. Percentage labels shown for segments > 5%; right-side labels show total project counts.

Trigger Distribution by Federal Department

Figure 4 shows trigger class distribution across federal departments—the parent cabinet agencies that house the lead agency for each project. Using department rather than individual agency names collapses the ~18+ distinct agencies into a legible set of ~8 entities.

The heatmap reads row by row: each row sums to 100%, showing how a given department’s projects are distributed across trigger classes. For example:

  • Department of Energy projects are largely Funding—DOE’s primary mechanism for decarbonization investment is grant and loan programs rather than direct construction.
  • Department of the Interior (primarily BLM) projects skew toward Land, as expected given BLM’s public land jurisdiction.
  • Department of Agriculture (Forest Service) mirrors Interior but at smaller scale— National Forest special use permits for biomass, wind, and transmission lines.

Figure 4: NEPA trigger distribution by federal parent department. Each row sums to 100%. Cell text: share of that department’s decarbonization projects in each trigger class.

Trigger Distribution by Energy Technology

Figure 5 shows trigger mix across primary clean energy technology types, filtered to technologies with at least 50 projects. Technology assignment uses the first matching clean-energy NEPATEC tag per project (e.g., a project tagged Solar + Utilities is assigned to Solar).

  • Solar and Wind (Onshore) projects are driven mainly by Land and Funding—utility-scale renewables either sit on BLM land or receive DOE financial assistance.
  • Transmission shows the highest Direct Action share, consistent with the Power Marketing Administrations (BPA, WAPA) building federal transmission infrastructure.
  • Hydropower shows a distinctive mix of Direct Action (federal dams) and Permit (FERC licensing for non-federal hydro).
  • Carbon Capture & Storage and Energy Storage skew toward Funding, reflecting DOE’s active grant program for emerging technologies.

Figure 5: Primary NEPA trigger by energy technology type. Technologies with fewer than 50 projects excluded. Right-side labels show total project counts; technology label = first clean-energy NEPATEC tag per project.

Federal Funding Deep Dive

The 9,125 Funding-primary projects (44.0% of the portfolio) warrant closer examination of how federal money flows and how much each mechanism typically awards. The figures below use a funding details sidecar produced by the funding mechanism extractor.

Funding Mechanism Types

Figure 6 breaks down Funding-primary projects by the type of federal financial instrument: grant, loan guarantee, cooperative agreement, cost-share, etc. This reveals the dominant instruments DOE and other agencies use to trigger NEPA review.

Figure 6: Count and share of Funding-primary decarbonization projects by federal funding mechanism type. Percentages denominated by all Funding-primary projects.

Funding Program Labels

Figure 7 shows which named federal programs and legislative authorities appear most frequently across Funding-primary projects. Program labels are multi-label — a single project may be linked to multiple programs (e.g., an IRA grant administered under the DOE LPO). Percentages are denominated by all Funding-primary projects.

Figure 7: Federal funding program and legislative authority labels across Funding-primary projects. Multi-label: a project may appear under multiple programs.

Dollar Amount Coverage and Distribution

Figure 8 shows what share of Funding-primary projects have each dollar-amount field successfully extracted. Coverage varies by field type: the federal award amount is most frequently present; recipient cost share and funding percentage require more detailed document language.

Figure 8: Share of Funding-primary projects with each dollar-amount field extracted. Missing values indicate no reliable figure was found in the document text.

Figure 9 complements the coverage view with the actual dollar distribution per mechanism type. A note on coverage: dollar amounts are extracted only when the document text contains an explicit award figure — most NEPA documents do not. As a result, only a fraction of the 9,125 Funding-primary projects have an extracted amount; the caption reports the exact count. Despite the limited coverage, the distributions are informative about typical award sizes within each mechanism type. Figure 9 focuses on common grant-scale mechanisms, excludes classes with fewer than 10 extracted amounts, and top-codes large grant-scale awards at $5 million so the main distribution remains legible. The larger loan guarantee and cooperative agreement records are shown separately in Table 2.

Figure 9: Distribution of common grant-scale federal funding amounts by mechanism type. Classes with fewer than 10 extracted amounts are excluded; values above $5M are top-coded at $5M+. Violin = distribution shape; box = Q1–Q3 with median; right-side labels show extracted amount counts.
Table 2: Large finance mechanisms with extracted federal funding amounts. These 9 loan guarantee and cooperative agreement records are shown as a table rather than scaled with the grant-size distributions.
Mechanism1 Federal Amount Project Source Text
Cooperative Agreement $475,287,678 DIII-D National Fusion Program Research and Facility Operations and Advanced Fusion Technology Research and Development Proposed Action Title: DIII-D National Fusion Program Research and Facility Operations and Advanced Fusion Technology Research and Development Total DOE Funding/Total Funding: $475,287,677.89 Proposed I.
Cooperative Agreement $456,394,130 DIII-D National Fusion Program Research and Facility Operations and Advanced Fusion Technology Research and Development Total DOE Funding/Total Funding: $456,394,130 Proposed I.
Cooperative Agreement $456,394,130 DIII-D National Fusion Program Research and Facility Operations and Advanced Fusion Technology Research and Development Total DOE Funding/Total Funding: $456,394,130 Proposed I.
Cooperative Agreement $1,500,000 DOE’s Proposed Financial Assistance to Pennsylvania for Frey Farm Landfill Wind Energy Project Pennsylvania proposes to provide the project a $1.5 million grant, which would come from a formula grant Pennsylvania received from DOE pursuant to the Department’s State Energy Program.
Loan Guarantee $969,000,000 Monolith Olive Creek Expansion Facility and Need for Agency Action The proposed action evaluated by the U.S. Department of Energy (DOE) in this environmental assessment (EA) is to issue a loan guarantee in the amount of $969 million to Monolith Nebraska LLC (Monolith) to support expansion construction and start-up of its natural gas to carbon black manufacturing plant in Hallam, Nebraska. The Energy Policy Act of 2005 (EPAct 2005) established a Fed
Loan Guarantee $535,000,000 DEPARTMENT OF ENERGY LOAN GUARANTEE TO SOLYNDRA, INC. FOR CONSTRUCTION OF A PHOTOVOLTAIC MANUFACTURING FACILITY AND LEASING OF AN EXISTING COMMERCIAL FACILITY IN FREMONT, CALIFORNIA ssment ES-1 Proposed Guarantee of Loan to Solyndra, Inc. EXECUTIVE SUMMARY INTRODUCTION The U.S. Department of Energy (DOE) is proposing to issue a loan guarantee in the amount of $535 million to Solyndra, Inc. (Solyndra) for (1) the construction of a photovoltaic manufacturing facility and accompanying administrative offices in Fremont, California; and (2) the leasing of an existing commercial facility for a
Loan Guarantee $241,000,000 Construction of the Diamond Green Diesel Facility hington, DC 20585 April 2011 FINAL ENVIRONMENTAL ASSESSMENT Environmental Assessment DOE/EA-1795 i SUMMARY Introduction The U.S. Department of Energy (DOE) is proposing to issue a $241 million loan guarantee to Diamond Green Diesel, LLC (Diamond) to support construction of a biomass-based diesel facility adjacent to the existing Valero St. Charles Refinery (VSCR) in Norco, Louisiana. DOE has prepared this Env
Loan Guarantee $5,000,000 Stion Corporation CIGSS Manufacturing Plant ciency and Renewable Energy (EERE) Project Management Center (Golden Field Office) issued a National Environmental Policy Act categorical exclusion (GFO-10-599-001) for the use of $5 million in Recovery Act funds (state block grant) for Stion Corporation to design, build, assemble and install 28 Metalorganic Chemical Vapor Deposition Tools and ancillary components and to upgrade the service yard at 6331 San
Loan Guarantee $2,000,000 AltAir Fuels DOE has made a final NEPA determination for this award Insert the following language in the award: Note to Specialist: According to the project officer, funding for this effort is $2,000,000. Unless there is a significant c
1 DOE is the lead agency for all records shown.

Geographic Distribution

State-Level Dominant Trigger

Figure 10 shows the dominant trigger class in each state — the trigger type with the most projects in that state. The map captures broad regional patterns:

  • Funding dominates most states, consistent with DOE’s nationwide grant footprint.
  • Land dominates in the intermountain West (Nevada, Utah, Wyoming, Montana, Arizona, and New Mexico)—states with high proportions of BLM land and active solar and wind development.
  • Direct Action appears in states with significant federal power authority infrastructure (Pacific Northwest, Colorado, Nebraska, and South Carolina).

Note that dominant trigger is determined by project count, not by area or capacity. A state where a single large BLM wind project is the only decarbonization project will appear as Land even if a dozen smaller DOE-funded projects are present.

Figure 10: Dominant NEPA trigger by state — the trigger class with the most projects in each state. Grey = no decarbonization projects in NEPATEC 2.0. Alaska and Hawaii repositioned for display.

County-Level Dominant Trigger

Figure 11 disaggregates the state-level map to the county level, revealing more fine-grained geographic patterns in trigger type. Counties are colored by the dominant trigger class among all decarbonization projects located in that county.

  • The Funding / Land boundary maps closely onto federal land ownership: counties spanning BLM or National Forest land (interior West) show Land as dominant; counties without substantial federal land show Funding.
  • Direct Action clusters in counties with federal power authority infrastructure—Pacific Northwest corridors (BPA transmission), parts of the MidWest, and Southwest transmission hubs.
  • Many rural counties host only one or two projects and are therefore colored by a single project’s trigger type; interpret sparse interior counties with caution.

Figure 11: Dominant NEPA trigger by county — the trigger class with the most projects in each county. Counties with no NEPATEC 2.0 decarbonization projects shown in light grey. Alaska and Hawaii repositioned for display.

Representative Evidence Examples

Table 3 shows two high-confidence classification examples per trigger class, drawn from high-quality evidence sources (Purpose and Need sections, project descriptions, and document titles). These excerpts are selected to show visible trigger-specific language and are intended to be quotable in client reports.

Table 3: Representative evidence text by trigger class. Two high-confidence examples per class; source limited to Purpose and Need, Project Description, and Document Title. Excerpts are selected around trigger-specific cue language.
Process Lead Agency Project Evidence Text Source
Funding
EA Department of Energy Ocean Sequestration of CO2 Field Experiment “DOE would provide funds for development of experimental plans, public outreach, permitting, data analysis, modeling predictions, and other support functions; the DOE funding would equate to about 20% of the total estimated cost of the experiment. The primary purpose of the Field Experiment would be to develop the data needed to verify scientific principles and to test, validate, and refine computer models used for predicting the behavior of carbon dioxide released into the ocean at moderate depth.” purpose_and_need
EA Energy Programs Old Town Fuel and Fiber Proposed Demonstration-Scale Inte... “This EA analyzes the potential environmental and socioeconomic impacts that would result from implementing the Proposed Action (with DOE funding) and the No-Action Alternative (without DOE funding), and evaluates the potential individual and cumulative effects of the Proposed Action 1.3 Public Scoping In accordance with applicable regulations and policies, DOE sent scoping letters to potentially interested local, state, and federal agencies, including the U.S.” purpose_and_need
Land
EIS Department of the Interior Cross-Tie 500-kilovolt Transmission Project “Cross-Tie 500-kV Transmission Project Draft Environmental Impact Statement Executive Summary ES-1 Executive Summary 1.0 Introduction TransCanyon, LLC (TransCanyon or Applicant), has applied for a right-of-way (ROW) grant and a Special Use Permit (SUP) to construct, operate, maintain, and decommission the Cross-Tie 500-kilovolt (kV) Transmiss...” purpose_and_need
CE Department of Agriculture Special Use Authorization for Electrical Line Realignment... “The right-of-way will be 20 feet wide and 10,302 feet long, for a total affected area of 4.73 acres. The following mitigation measures will be outlined in construction stipulations that will be made part of the special use permit amendment: * Tree removal will not be conducted May 1 - September 1 to protect roosting bats and other wildlife. * Tree removal will not be conducted May 1 - September 1 to protect roosting bats and other wildlife. * If any unknown cultural resources are discovered during the project activities for the proposed project or there is a change in the location of the Area...” description
PMA/TVA
EIS Department of Energy San Luis Rio Colorado Project “The purpose and need for the decisions of the Federal agencies regarding the Proposed Project are discussed below. Western Area Power Administration Western’s decision is to grant or deny an interconnection request at its Gila Substation under the provisions of its Open Access Transmission Services Tariff, which complies with the intent of Federal Energy Regulatory Commission (FERC) Orders for providing nondiscriminatory transmission access.” purpose_and_need
EIS NA Southline Transmission Line Project “The proposed Project would include the construction of approximately 240 miles of new double-circuit 345-kilovolt (kV) transmission line, and the upgrade of approximately 120 miles of Western Area Power Administration’s (Western’s) existing Saguaro–Tucson and Tucson–Apache 115-kV transmission lines to a double-circuit 230-kV transmission line.” purpose_and_need
Direct Action
EIS Department of Energy Construction and Operation of the Spallation Neutron Source “20585 Telephone: (202) 586-4600, or leave a message at (800) 472-2756 Facsimile: (202) 586-7031 ABSTRACT: DOE proposes to construct and operate a state-of-the-art, short-pulsed spallation neutron source comprised of an ion source, a linear accelerator, a proton accumulator ring, and an experiment building containing a liquid mercury target and a suite of neutron scattering instrumentation.” purpose_and_need
EIS Department of Energy Strategic Petroleum Reserve Expansion of Reserve “Description of the Proposed Action : The Department of Energy Administration proposes to implement the S trategic Petroleum Reserve , Titl e I , Part B of the Energy Policy and Conservation Act o f 1975 ( P .” purpose_and_need
Program
EIS Nuclear Regulatory Commission Completion and Operation of Watts Bar Nuclear Plant Unit 2 “As set forth in the GEIS (generic environmental impact statement), Category 1 issues are those defined as meeting all of the following criteria: Internet Address (URL) http://www.epa.gov Recycled/Recyclable .Printed with Vegetable Oil Based Inks on Recyded Paper (Minimum 30% Poslconsumer) The environmental impacts associated with the issue are determined to apply either to all plants or, for some issues, to plants having a specific type of cooling system or other specified plant or site characteristics.” purpose_and_need
CE Department of Energy Hydrogen Generation and Fueling Station on the STM Campus “Final Site-Site Wide Environmental Assessment of the National Renewable Energy Laboratory's (NREL) South Table Mountain Complex (February 2003) Rational for determination: BACKGROUND This proposed project would be for the purchase, installation, and operation a hydrogen generation and fueling system (HGFS) at the Vehicle Testing and Integration Facility (VTIF) located at the National Renewable Energy Laboratory's (NREL's) South Table Mountain (STM) campus in the Golden, Colorado.” description
Permit
EIS Department of Energy New England/Hydro-Quebec ± 450 kilovolt Transmission Line... “The proposed act ion is the issuance of an amendment to Presidential Permit PP-76 to the Vermont Electric Transmiss ion Company to operate the internat ional interconnect ion therein authorized at power levels above those stipulated in PP-76 , and to construct new transmission fac ilities to d istr ibute this power .” purpose_and_need
EIS Department of Energy Eagle Mountain Pumped Storage Hydroelectric Project “We urge development of more definitive information on the amount of acid rock drainage, prior to the Commission’s approval of the hydropower license.” purpose_and_need
Property Transaction
EIS Denali Commission Mertarvik Infrastructure Development, Nelson Island, Alaska “This final Environmental Impact Statement (EIS) describes a number of alternatives in a historical context for the purpose of illustrating how the long-term evolution of the project led to the selection of a new village site to be constructed at Mertarvik on Nelson Island, a site granted to the village in a land exchange approved by the U.S.” description

Report generated 2026-06-26 | NEPA Decarbonization Technology Analysis — Phase 2, Deliverable 1