Preliminary Phase 1 Findings
March 05, 2026
Phase 1 Deliverables
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.
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
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
| 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
Decarbonization-related projects by review type
Energy type breakdown across all federal projects
Project counts by NEPA process and energy type
Share of process types within each energy classification
Technology by NEPA process type
Process type mix by lead department
Process type mix — DOE and BLM only (comprehensive coverage)
Top 20 states by decarbonization project count
Categorical Exclusions by county
Environmental Assessments by county
Environmental Impact Statements by county
There are three types of reviews in the NEPA process:
Review type distribution across EA/EIS
Share of non-standard reviews by lead agency
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.
Timeline completeness (projects with both initiation + decision dates):
Capacity distribution (stacked)
Violin + boxplot by process
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
Department collaboration hub scores
Cross-department project flows. Lead department on the left, partner on the right.
FRA 2023 Page Limits
The Fiscal Responsibility Act of 2023 (FRA) established the first statutory page limits for NEPA documents. This section examines whether lengths changed after FRA and how well current documents comply.
| Standard | Complex | |
|---|---|---|
| EA | 75 pp | — |
| EIS | 150 pp | 300 pp |
Regulatory pages = body word count ÷ 500 (excludes appendices, tables, maps, citations per 40 C.F.R. § 1508.1(bb))
Slight decline right FRA but then an uptick. EA mean fell ~22% and EIS fell ~25% post-FRA, but then the rolling average trends up afterwards — causation is uncertain.
Small post-FRA sample: only 33 EAs and 42 EISs completed after June 2023.
Pre vs. Post-FRA page count comparison
Compliance rates (post-FRA only)
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.
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.
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 2 Directions
Discussion Questions
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
Exclusion 2 — Military & Defense + Nuclear
Exclusion 3 — Nuclear + Waste Management
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.
CE — Technology distribution
EA — Technology distribution
EIS — Technology distribution
Timeline coverage breakdown by review process — share of projects with each combination of initiation and decision dates present or missing.
Two-Stage BERT Pipeline
Selection rules:
Coverage Limitations
Warning
Model: BERT (bert-base-uncased), fine-tuned on manually annotated NEPA document sentences. Class imbalance for initiation dates is a known limitation.
Categorical Exclusions (CE) — multi-state project types
Environmental Assessments (EA) — multi-state project types
Environmental Impact Statements (EIS) — multi-state project types
Categorical Exclusions (CE) — 20 multi-agency projects
Environmental Assessments (EA) — 14 multi-agency projects
Environmental Impact Statements (EIS) — multi-agency projects (majority of portfolio)
Regulatory Page Calculation
Scale of difference:
Known Edge Cases
Warning
Transmission length (miles) by action type
NEPA duration (days) by action type
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.
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).
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.
| 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
NEPA Decarbonization Technologies Analysis — Phase 1 | See full analysis on website → | PRELIMINARY — NOT FOR EXTERNAL DISTRIBUTION