NEPA Decarbonization Technologies Analysis

Preliminary Phase 1 Findings

Clean Air Task Force

March 05, 2026

Agenda

Phase 1 Deliverables

  1. Project Background & Data
  2. D1 — Decarbonization Project Landscape
  3. D2 — Programmatic & Tiered Reviews
  4. D3 — NEPA Process Types, Timelines & Generation Capacity
  5. D4 — Multi-State & Multi-Agency Projects
  6. D5 — Document Length & Fiscal Responsibility Act Impact
  7. D6 — Technology Specific: Transmission, Geothermal, Pipelines
  8. Discussion & Next Steps

Format

~45 minutes of content; ~15 minutes for discussion

See the full report: on the project’s website


Appendix slides follow the main deck with additional detail, methodology, and the NEPA policy timeline.

Project Background & Data

The NEPATEC 2.0 Dataset

What and why: NEPATEC 2.0 is a comprehensive public database of National Environmental Policy Act (NEPA) reviews in machine-readable form created by Pacific Northwest National Laboratory (PNNL) that allows researchers to systematically analyze NEPA data at scale.


NEPATEC 2.0 Dataset Universe by Review Process:

Process Total Projects Total Files Total Pages
CE — Categorical Exclusion 54,668 73,544 366,876
EA — Environmental Assessment 3,083 14,242 469,106
EIS — Environmental Impact Statement 4,130 54,297 6,131,757
Total 61,881 142,083 6,967,739

CE: no significant impact anticipated · EA: significance uncertain, brief analysis · EIS: significant impacts expected, full review

All federal projects by review type

  • CEs account for 88% of projects but only 5% of total pages — the vast majority of NEPA activity is routine and low-documentation by design.
  • EIS reviews are ~7% of projects but generate 88% of all pages — each EIS produces an average of ~1,480 total pages, compared to ~152 for EAs and ~7 for CEs.

Munikoti, S., Nally, D., Koneru, S.D., et al. (2025). NEPATEC v2.0: Standardized Metadata and Text Corpus of National Environmental Policy Act Documents. PNNL/PermitAI. PDF

Defining Decarbonization Technologies

Decarbonization Technology Tags (≥1 required, no Fossil Fuel tags) Fossil Fuel Tags (any 1 excludes)
Carbon Capture and Sequestration Conventional Energy — Coal
Nuclear Energy Production Land-based Oil & Gas
Other Conventional Production Offshore Oil & Gas
Electricity Transmission Rural Energy
Nuclear Technology Pipelines
Solar
Wind (Offshore)
Wind (Onshore)
Geothermal
Hydropower
Hydrokinetic
Energy Storage
Biomass
Utilities


Decarbonization Technologies Universe: ~25,000 projects initially tagged but 20,725 retained after exclusion criteria applied — see Appendix for details on what was excluded

  • Universe used across all six Phase 1 deliverables.

Decarbonization-related projects by review type

Energy type breakdown across all federal projects

Process Types by Energy Classification

Project counts by NEPA process and energy type

Share of process types within each energy classification

  • Decarbonization-related projects use Categorical Exclusions at higher rates than fossil fuel or other project types, likely reflecting smaller average project footprints.
  • Fossil fuel projects show higher EA/EIS rates, consistent with larger environmental footprints requiring more detailed review.
  • CE is the dominant NEPA pathway for decarbonization-related projects across all technology types.

Deliverable 1: Decarbonization Project Landscape

Technology Distribution

Technology by NEPA process type

  • Utilities and Electricity Transmission dominate, possibly reflecting the infrastructure build required to connect renewable energy generation.
  • While most projects are granted “Categorical Exclusion (CE)” status, Hydropower, Nuclear, and Wind have notably higher rates of EA/EIS reviews, reflecting larger potential environmental footprints than many of the other types of projects.

Project Breakdown by Lead Department

Process type mix by lead department

Process type mix — DOE and BLM only (comprehensive coverage)

  • DOE accounts for 81% of all decarbonization-related projects — and processes 97% of those through Categorical Exclusions
  • BLM shows a more varied process mix, consistent with its land-management mandate for large-scale renewables on federal lands.
  • See Appendix for detailed coverage note: Only DOE and BLM have comprehensive CE, EA and EIS data so the second figure limits to those departments/agencies for a clearer picture.
  • Key department deep dive analysis →

Geographic Distribution

Top 20 states by decarbonization project count

  • Western states dominate renewable-driven activity: Washington, California, Idaho, and Colorado together account for a large share of transmission, solar, wind, and hydropower projects.
  • South Carolina leads with 2,000+ projects — largely driven by DOE’s Savannah River Site nuclear facility.

County-Level Maps by Process Type

Categorical Exclusions by county

Environmental Assessments by county

Environmental Impact Statements by county

  • Decarbonization-related projects across all three review types are predominately located in western counties of the United States, consistent with the concentration of public lands managed by BLM, Forest Service, and DOE in the West.
  • Electricity Transmission and solar projects dominate EAs and EIS in the southwest (see project deep dive)

Deliverable 2: Programmatic and Tiered Reviews

Programmatic & Tiered Reviews

There are three types of reviews in the NEPA process:

  • Standard: Stand-alone EA or EIS covering a single project — the default NEPA approach
  • Programmatic (Tier 1): Broad “umbrella” review (PEIS/PEA) covering a class of actions or a region, usually before site-specific work begins
  • Tiered (Tier 2): Site-specific review that builds on a prior programmatic review, scopes out specific issues already identified, streamline the review process

  • Standard review is the overwhelming norm — Almost 90% of projects use the standalone standard review process.
  • Tiered reviews are more rare

Non-standard Reviews: Who and Where?

Review type distribution across EA/EIS

Share of non-standard reviews by lead agency

  • The Nuclear Regulatory Commission and BLM drive Other Independent Agencies and Department of Interior non-standard review use – check out our analysis on the website
  • Non-standard reviews are not evenly distributed: they concentrate in western states and large-scale land-use actions where BLM and Forest Service manage extensive federal acreage.

Are Tiered Reviews Actually Faster?


Tiered EAs take longer than standard EAs on average — but they are substantially shorter than a full EIS, suggesting the real efficiency gain from tiering is when it allows an agency to avoid a full EIS altogether rather than just shortening an EA.

Tiered EISs take less time than standard and programmatic EISs, though distributions substantially overlap and sample sizes are small.

WORD OF CAUTION: Small sample for non-standard reviews is still quite small to draw strong conclusions here.

Deliverable 3: Timelines and Generation Capacity

How Long Does NEPA Review Take?

Timeline completeness (projects with both initiation + decision dates):

  • The CE→EA→EIS duration gradient is steep: median durations range from ~1 month (CE) to ~14 months (EA) to ~34 months (EIS) — a rather large difference.
  • The long tail drives NEPA’s reputation: 10% of EIS reviews exceed 7.5 years, but this is not typical — the median is 3 years.
  • Timeline completeness is partial: only 30% of CEs have extractable dates; EA (62%) and EIS (48%) are better but not complete, so medians likely undercount the slowest cases.

NEPA Activity Over Time

  • CE peaked in 2010, could be due to the American Recovery and Reinvestment Act (ARRA) stimulus
  • CE again peaked in 2022 and 2023, likely resulting from the Inflation Reduction Act (IRA)/ Bipartisan Infrastructure Law (BIL) investment surge

Generation Capacity by Review Process

Capacity distribution (stacked)

Violin + boxplot by process

  • CE projects are largely small and medium-scale projects; utility-scale projects mostly EIS, and EA having a balanced mixture
  • CE median: 1.2 MW | EA median: 60 MW | EIS median: 538 MW — Review intensity is broadly proportional to project scale, consistent with NEPA’s risk-proportional design.

Deliverable 4: Multi-State & Multi-Agency Projects

Multi-State & Multi-Agency Projects

Long-distance transmission lines, pipelines, and large renewables often cross multiple state boundaries or require multiple federal agencies — driving disproportionately high EIS rates in both categories.

Multi-state projects by NEPA process type

Multi-agency projects by NEPA process type

  • Multi-state projects are predominantly CE or EIS-level, whereas Multi-department projects are predominantly EIS-level.

Multi-State Projects

  • Western states dominate multi-state activity
  • Top corridors: connecting renewable-rich areas to load centers in California and the Pacific Northwest, main exceptions being CO-NM and NE-MO

Multi-Department Collaboration

Department collaboration hub scores

Cross-department project flows. Lead department on the left, partner on the right.

  • Department of Energy (DOE) dominates multi-department projects (9 partner agencies)
  • Department of Energy and Department of Interior partner together the most

Deliverable 5: Document Length & Fiscal Responsibility Act Impact

Pre/Post FRA: Lengths & Compliance

Pre vs. Post-FRA page count comparison

Compliance rates (post-FRA only)

  • EAs are largely compliant: ~70% of post-FRA EAs meet the 75-page limit — a strong signal that the rule is working for shorter reviews.
  • EIS compliance is more mixed: Only 29% of EIS documents meet the 150-page limit outright; but another 29% fall in the 150–300 “extraordinary complexity” range and are compliant — a total of 57% compliant under the full standard.

Deliverable 6: Technology Specific: Transmission, Geothermal, Pipeline

Electricity Transmission Lines: Length and Duration

Projects and median duration by length band

Line length vs. NEPA duration (scatter)

Mixed results: No strong statistical relationship between line length and review duration.

  • Median length is 8 miles and most (55%) under 10 miles
  • Very long lines (≥100 miles) take ~6× longer, but with small N.

Geothermal Energy

Distribution of NEPA actions across development phases

Duration by development phase

914 NEPA actions | 5 phases | A single geothermal project may require multiple sequential NEPA reviews — the total permitting burden is the sum of all phases, not just one review.

Carbon, Hydrogen & Natural Gas Pipelines

Pipeline length by type

Duration by pipeline type

6,133 total pipeline NEPA actions | Natural gas provides the most reliable baseline | Carbon and hydrogen samples are very small — treat as exploratory findings only.

Warning

Only a few carbon and hydrogen projects have both length and duration data. Findings are directional, not statistically definitive.

Phase 1 Summary: Key Findings

  1. D1: DOE Categorical Exclusions are king: DOE handles 81% of review cases, processing 96% via CE
  2. D1: Western states and federal lands dominate — BLM, Forest Service, and DOE public land concentration drives the geographic pattern
  3. D2: Tiering might help — tiered EAs take longer than standard EAs — but less time than a full EIS
  4. D3: Duration gradient is steep with a long tail — CE (~1 mo) → EA (~14 mo) → EIS (~3 yr median)
  5. D3: Policy stimulus — ARRA (2010) and IRA/BIL (2022–23), CE peaks are clear
  6. D3: Scale matches review intensity — EIS = median 538 MW; EA = 60 MW; CE = 1.2 MW
  7. D4: DOE is the multi-agency hub — improving DOE-DOI-USDA coordination would have outsized impact
  8. D5: FRA had effect but not definitive — document lengths declined; most projects are compliant (small N)
  9. D6: No relation between line length and duration, but long lines (100+ miles) take longer (small N)

Discussion & Next Steps

Phase 2 Directions

  1. Why is NEPA triggered? (federal land vs. federal funding)
  2. Significance determinations across resource areas
  3. Fossil fuel vs. decarbonization technology comparison
  4. Deeper timeline analysis and outlier case studies (90th percentile EIS)
  5. Regulatory categorical exclusion development patterns

Discussion Questions

  • Which findings most surprise you?
  • Which are most actionable for CATF’s policy work?
  • Any specific follow ups for Phase 2?

Full Analysis Website | NEPATEC 2.0

Download PDF Version

Appendix

Defining Decarbonization Technologies — Tag and Exclusion System

Decarbonization Technologies Tags (at least 1 required AND no Fossil Fuel tags)

Tag
Carbon Capture and Sequestration
Conventional Energy Production — Nuclear
Conventional Energy Production — Other
Electricity Transmission
Nuclear Technology
Renewable Energy Production — Biomass
Renewable Energy Production — Energy Storage
Renewable Energy Production — Geothermal
Renewable Energy Production — Hydrokinetic
Renewable Energy Production — Hydropower
Renewable Energy Production — Solar
Renewable Energy Production — Wind (Offshore)
Renewable Energy Production — Wind (Onshore)
Utilities (electricity, gas, telecommunications)

Fossil Energy Tags (any 1 excludes)

Tag
Conventional Energy — Coal
Conventional Energy — Land-based Oil & Gas
Conventional Energy — Offshore Oil and Gas
Conventional Energy — Rural Energy
Pipelines

Three additional exclusions were applied after reviewing co-occurring tag combinations:

Exclusion 1 — Utilities + non-energy only

  • 1,623 projects tagged only as Utilities AND with non-energy tags (broadband, waste management, land development) were excluded since they are utility-adjacent infrastructure.

Exclusion 2 — Military & Defense + Nuclear

  • 481 projects tagged as Nuclear AND Military/Defense were excluded, since they were mostly defense-related activities.

Exclusion 3 — Nuclear + Waste Management

  • ~4,000 nuclear waste projects reviewed; those sponsored by DOE’s NNSA, Office of Environmental Management, and Office of Legacy Management were excluded. Only 34 projects from this category were retained.

D1-Process Type by Lead Department (All Agencies vs Verified Agencies)

Process type mix — DOE and BLM only (comprehensive coverage)

Process type mix by lead department (all agencies)

Coverage note: Only DOE and BLM have comprehensive CE, EA and EIS data so the second figure limits to those departments/agencies for a clearer picture.

D1-Technology Distribution — Deep Dive by Process Type

CE — Technology distribution

EA — Technology distribution

EIS — Technology distribution

  • CE is dominated by utilities/transmission and nuclear — reflecting DOE’s vast categorical exclusion program for grid and facility upgrades.
  • EA reviews show more technology diversity: solar, wind, and geothermal appear prominently alongside transmission, suggesting EAs are triggered by larger renewable buildouts.
  • EIS reviews concentrate on high-impact technologies: large transmission, wind, and hydro projects — the ones most likely to require full environmental impact analysis due to scale or site sensitivity.

D3-Timeline Coverage Mix by Review Process

Timeline coverage breakdown by review process — share of projects with each combination of initiation and decision dates present or missing.

D3-Timeline Extraction Methodology

Two-Stage BERT Pipeline

  1. Date extraction — identify all dates in document text with surrounding sentence context (±2 sentences)
  2. Classification — fine-tuned BERT model assigns each date to:
    • Initiation — NOI, application received, scoping notice
    • Review — draft publication, comment period
    • Decision — ROD, FONSI, approval signature
    • Other — expiration dates, referenced past actions

Selection rules:

  • Decision: prioritize strong signature/approval cues
  • Initiation: NOI > application > scoping (in priority order)
  • Fallback: use earliest review date when no initiation found

Coverage Limitations

Warning

  • CE (30%): Short documents have less temporal information
  • EIS (48%): RODs often issued as separate documents not linked in dataset
  • EA (62%): Best coverage; FONSIs typically included in the same document

Model: BERT (bert-base-uncased), fine-tuned on manually annotated NEPA document sentences. Class imbalance for initiation dates is a known limitation.

D4-Multi-State Projects — Project Type Word Clouds

Categorical Exclusions (CE) — multi-state project types

Environmental Assessments (EA) — multi-state project types

Environmental Impact Statements (EIS) — multi-state project types

  • Utilities and Electricity Transmission dominate three review types — confirming multi-state coordination is fundamentally a transmission story.

D4-Multi-Agency Projects — Project Type Word Clouds

Categorical Exclusions (CE) — 20 multi-agency projects

Environmental Assessments (EA) — 14 multi-agency projects

Environmental Impact Statements (EIS) — multi-agency projects (majority of portfolio)

  • Utilities and Electricity Transmission dominate three review types
  • CE and EA samples are very small (20 and 14 projects respectively) — their word clouds reflect a narrow slice of project types and should be interpreted cautiously.

D5-FRA Regulatory vs. Raw Pages Methodology

Regulatory Page Calculation

  1. Extract body text from OCR’d PDF
  2. Detect appendix boundaries using section-header patterns (e.g., “Appendix A”, “References”, “List of Preparers”)
  3. Count words in body text (pre-appendix sections only)
  4. Regulatory pages = body word count ÷ 500

Scale of difference:

  • EAs: regulatory pages ≈ 45–55% of raw page count
  • EISs: regulatory pages ≈ 70–80% of raw page count

Known Edge Cases

Warning

  • OCR errors in scanned legacy documents may produce NULL word counts
  • Non-standard appendix headers may not be detected
  • ~5% of cases: regulatory pages exceed raw pages (OCR text extraction artifact in table-heavy documents)
  • Waivers and “extraordinary complexity” exceptions are not distinguished from standard non-compliance

D6-Transmission: Length and Duration by Action Type

Transmission length (miles) by action type

NEPA duration (days) by action type

  • Upgrades dominate — most transmission NEPA activity is replacements and upgrades, not greenfield construction.
  • New builds are relatively rare but tend toward longer lines.

D6-Transmission — Duration by Region

Regional variation reflects differences in project scale, agency staffing, and land status (federal vs. private). Western regions show both the highest median durations and the widest variance.

D6-Geothermal Phase Distribution

Phase classification uses regex keyword matching on project title and description. Projects matching 2+ phase keyword sets are classified as “multi-phase.” Projects with no keyword match fall back to process type (CE → drilling; EA/EIS → exploration).

D6-Pipeline Length vs. Duration

Modest positive correlation between pipeline length and NEPA duration across all types. High variance throughout. Natural gas provides the most statistically reliable trend line given sample size.

NEPA Policy Context 2025–2026

Date Event
Jan 20, 2025 EO 14154 revokes CEQ NEPA regulation authority; instructs agencies to eliminate permitting delays
Feb 25, 2025 CEQ issues interim rule removing NEPA regulations from CFR
Apr 23, 2025 DOI emergency permitting: review timelines reduced to under 1 month
May 29, 2025 Supreme Court (Seven County v. Eagle County): agencies may limit NEPA scope to decisional authority
Jul 4, 2025 Reconciliation bill signed — pay-to-play expedited reviews enacted
Jul 3, 2025 DOE, DOI, USDA, Army Corps, DOT, FERC convert NEPA regulations to nonbinding guidance
Jul 23, 2025 AI Action Plan: EO directs new CEs, NEPA exemption when federal funding < 50%
Dec 18, 2025 SPEED Act passes House — limits on judicial review, new NEPA exemptions proposed
Dec 22, 2025 DOI issues stop-work orders for 5 offshore wind projects including Vineyard Wind 1
Jan 8, 2026 CEQ adopts final rule: all NEPA regulations removed from Federal Register

Source: CATF NEPA & Permitting Reform Timeline. The Phase 1 analysis predates most of these actions. Phase 2 data collection will capture their effects on permitting patterns.

Clean Air Task Force NEPA Decarbonization Technologies Analysis — Phase 1

Full Analysis Website   |   NEPATEC 2.0 Data

Download PDF Version