I'm extremely skeptical of the Department of Interior's attempt at using emergency authorities to speed NEPA reviews up to 28/14 days.

Ironically, DOI is relying on an authority that only ever existed in CEQ regs which are now gone... I expect courts will throw this idea out.

But CEQ not having a chairman is undermining this process. The agency isn't empowered so they can't move forward with new regs.

-The initial EO set a 30 day deadline that was blown past before CEQ had any staff at all.
-Today's EO refers to a Chairman that still doesn't exist!

If anything, even the average understates NEPA costs. Uncertainty has a chilling effect on investment. Companies can’t know ahead of time when their investments will be built or whether NEPA will be co-opted by political interests seeking to delay their project. (6/9)

Second, CEQ decided to use median time to complete an EIS instead of average time. They argue this better represents the typical EIS.

But median time under-represents the cost to developers in the tail of the graph: the potential to take 5-15 years creates painful uncertainty for developers. (5/9)

First CEQ chose to measure NEPA timelines from the Notice of Intent (NOI) to the Final EIS rather than NOI to the Record of Decision — the final decision to move forward with a project.

IMO this undercounts the delay in the NEPA process. (3/9)

CEQ headlines the statistic that median EIS timelines (2019-2024) shrank to 2.8 years, down from 3.2 years (2010-2018).

But these findings rely on some questionable methodological decisions. (2/9)

The Council on Environmental Quality claims to show reduced permitting timelines.

But the data suggests not much has changed.

Here's why NEPA data is tricky: 🧵 (1/9)

I-95’s repairs showed the benefits of centralized permitting authority.

The Baltimore Bridge shows the benefit of a quick and painless NEPA process.

Both can be applied to broader reforms (6/7).

But even when speed is prioritized for disaster rebuilds the momentum rarely translates.

For example Governor Moore is already back to siding with NIMBYs against the Maryland Piedmont transmission line. (4/7)

America can still build fast! …but only after disasters.

In my piece for The New Atlantis (now unpaywalled) I look at the Baltimore Bridge rebuild and ask why we can’t build fast all the time.

Disaster rebuilds offer some lessons for a better infrastructure process. 🧵 (1/7)