NEPA Delays in Geothermal Exploration and the Categorical Exclusion Myth: Evidence from 133 Bureau of Land Management Reviews

August 18, 2026

Geothermal technology could provide 12–20 percent of US electricity by 2050, but environmental regulations such as the National Environmental Policy Act (NEPA) make much of that potential electricity unavailable. Using a newly compiled dataset of geothermal exploration projects subject to Bureau of Land Management–led NEPA review, this working paper examines how NEPA operates at the exploration stage of geothermal projects.

Key Findings:

  • NEPA timelines vary widely at the exploration stage: across 133 projects, the median review took 105 days, and the mean was 210 days.
  • Ostensibly streamlined processes still have delays. Of projects approved via determination of NEPA adequacy, 15.4 percent took more than 100 days. Of projects approved via a categorical exclusion, 37.5 percent took more than 100 days.
  • NEPA duration has almost no relationship with acres disturbed and a weak relationship with number of wells drilled.

Policy Implications:

  • By setting a statutory deadline—of, say, one month—for categorical exclusions, Congress can ensure that categorical exclusions take less time than environmental assessments and environmental impact statements, which both require more work to complete. Furthermore, policymakers interested in allowing more electricity generation should consider whether a purely procedural law such as NEPA can produce environmental benefits that outweigh its costs.

 

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