Project timeline savings under BAAJA

Potential time saved under the permitting bill by project type (as measured in months)

Time saved if agencies meet deadlines (in months)Time saved with delays and challenges (in months)

Each archetype is a composite of recorded cases intended to illustrate how BAAJA could change project timelines. They are not representative of projects currently proposed or being built. Estimated time savings may not apply to all projects or all types of energy projects. The estimates count only months saved, not projects that BAAJA might have enabled to proceed but that current law stopped.

Compare Timelines: Current Law vs. the Bill

Select a project type and scenario. In the timeline, the grey bar represents current law, and the colored bar below it represents BAAJA. The chip next to each step shows how much sooner it would be completed under BAAJA. A black tick marks the median timeline for a step based on recorded cases, where available. Hover over or tap any bar to view its basis and source.

Project type

Scenario

Each bar is one provision's share of time saved in the selected scenario. The bars run end to end and add up to the total. Because provisions overlap, each share reflects the provision's average contribution across all orders in which it could take effect. Hover over or tap a bar to see how much time the provision saves on its own and when added last.

What's included

Project-specific environmental impact statements (EISs) for the six project types in the Council on Environmental Quality's (CEQ) 2010 to 2024 data, one solar EIS missing from that dataset (Crimson), three EISs still under review, and 25 BLM geothermal exploration reviews.

How project timelines are recalculated

Each project's recorded dates are replayed under the bill's proposed deadlines: 28 months from the notice of intent (NOI) for the EIS, including the two-year deadline plus a four-month sponsor suit, two months after the final EIS for the decision, the bill's deadlines for the BLM to issue the NOI, and two months for test-well permits. Months the bill would excuse or would not cut, such as a developer's redesign or a funding lapse that began before a deadline, remain in the timeline.

How to read this interactive

Each row represents one project, sorted by months saved. The grey bar shows the recorded review from the NOI—or, if the replay includes a wait before the NOI, from when that wait begins—to the federal decision. The blue bar below shows when the decision would be made under BAAJA, and the chip next to the project name shows how much time was saved. Because the replays end at the federal decision, they exclude the state siting and the Federal Energy Regulatory Commission (FERC) backstop permit (Sec. 2101), which account for most of the projected time savings for the transmission archetype. Up to the federal decision, that archetype saves 64 months. Hover over or tap a bar to view its dates and an explanation of why the process took so long.

Project type

The replays end at the federal decision because the records do not show when projects were built. They assume agencies and developers behave as they did in the past, except that developers refuse extensions they did not cause. On the Permitting Dashboard, developers usually agreed to such extensions. Reviews still under way use the agency's current schedule. The comma-separated values (CSV) include every project and its sources.

Key assumptions and how they compare

Criteria	This Analysis	Published Literature
EIS length, all agencies	The timeline uses the two-year statutory cap when deadlines are met and historical case data when they are not.	The median time from NOI to final EIS was 2.8 years for 2019–2024 and 2.2 years for 2024; 41 percent of 2024 final EISs were completed within two years (CEQ). Among EISs finished after the 2023 deadline, 39 percent met the two-year deadline (BPC).
Before the review starts	Developer work took equal amounts of time under both current law and BAAJA. When deadlines were met, BLM processing took six months for solar and four months for wind and transmission. Under BAAJA, processing would take four months for wind and solar (30 days plus 90 days) and two months for transmission (the NOI issued 60 days after BLM receives the requested materials). When delays and challenges occurred, processing took 24 months for solar and five months for wind after the developer's final filing.	In all five recent solar cases, the developer was still filing amended applications, revising plans, or answering BLM's questions between five days and seven months before the NOI. BLM's own delays included 15 months before its first request for more information at Rough Hat Clark (and longer at Arica and Victory Pass, which was reviewed alongside it in an environmental assessment, or EA). Across six projects of all types, the time from completed application to the start of review took 1.5 to 15 months, with a median of about seven months (BLM case records).
Solar on BLM land	These projects took 22 months from the NOI to the final EIS, 24 months from the NOI to the decision, and 48 months from application to decision.	Across 32 EISs from different agencies, the average time from the NOI to the final decision was 27 months. Approximately 75 percent of the EISs were for BLM projects (Resources for the Future, RFF). The average time from first action to decision was 57.9 months (NAM and FAI). Of 21 projects, 12 waited more than 2 years for an NOI (RFF). For the five applications filed between 2019 and 2021, the time from application to NOI was 30 to 55 months, with a median of 35 months (BLM case records; See data).
Onshore wind on BLM land	These projects took 24 months from the NOI to the final EIS, another three months to reach a decision, and 37 months from application to decision when deadlines were met. When deadlines were not met, the time from NOI to final EIS was 34 months (Lava Ridge).	Across eight wind farms on BLM land, the median time from NOI to final EIS was 27.5 months, with about another three months to reach a decision. This excludes West Butte, where the BLM approved only a road and transmission line for a wind farm on private land. The two longest projects—at 47 and 48 months, respectively—reflect developer redesigns (this page, from the CEQ dataset and Federal Register). Average time from NOI to decision across agencies was 45 months, with half of the projects taking over two years (RFF). Average time from first action to decision was 52.6 months (NAM and FAI). All 13 wind projects with full records reached the NOI within two years (RFF). Lava Ridge and Borderlands each took about 18 months from application to NOI, though most of that time elapsed before the developer submitted a revised plan or complete application. These came two and five months before the NOI, respectively (BLM case records).
Interstate transmission	When deadlines are met, the timeline is capped at two years; otherwise, it takes 52 months from NOI to final EIS and 71 months to decision (TransWest), plus 30 months for a FERC backstop permit.	To date, FERC has not issued a backstop permit. For large new gas pipelines, the process from approval to begin pre-filing to certificate issuance took a median of 31 months (range: 24 to 39 months; FERC eLibrary). Across 30 lines with both dates recorded (of 33) from 2010 to 2020, the median time from NOI to decision was 3.7 years and the average was 4.3 years. Each additional 100 miles added about 5 months (Niskanen). Greenlink West took 21 months from application to NOI, 15 of which elapsed after the project application was complete (BLM case records).
Gas pipeline	These projects required 10 months for pre-filing, 22 months from NOI to final EIS, and another four months to receive a certificate. The total time from application to certificate was 20 months.	Twelve large new pipelines received certificates between 2014 and 2023. Median timelines across projects with each record were 9.7 months of pre-filing (10), 21.9 months from NOI to final EIS (11), 3.9 months from final EIS to certificate (11), 21.4 months from application to certificate, and 31 months from pre-filing to certificate (10) (FERC eLibrary; See data). For 42 FERC pipeline EISs from 2010 to 2024, the median time was 11 months from NOI to final EIS and 17 months from NOI to decision. For EISs completed since 2019, the median time to final EIS was less than 10 months (this page, from the CEQ dataset). Across all FERC EISs between 2010 and 2018, the median time from NOI to decision was 2.29 years (CEQ). For 20 pipeline-sector EISs, half of which were FERC reviews, the average was 2.42 years (Permitting Council, cited by NAM and FAI).
Geothermal development review	10 months (EA)	The median review timeline for these projects was 302 days (NREL 2014). For projects reviewed between 2010 and 2023, estimates of the average timeline were 14 months (RFF) and 14.6 months (NAM and FAI).
Offshore wind	These projects are subject to a two-year timeline cap if the requirements are met; otherwise, the timeline from NOI to final EIS is 36 months (SouthCoast).	Across 11 Atlantic projects, the median timeline from NOI to decision was 30.8 months, with none reaching a final EIS in under 24 months (this page, from Federal Register dates). Seven projects averaged 44.3 months to obtain all federal permits (Liskow); Vineyard Mid-Atlantic's current schedule projects 39 months from NOI to final EIS (Permitting Dashboard).
ESA consultation, offshore wind	The projects take 13 months, ending one month before the final EIS, when deadlines are met, compared with seven months under the bill. If delays and challenges occur, the timeline is 14 months.	For 11 Atlantic projects between 2020 and 2024, the median timeline from the first draft biological assessment to the opinion was 14 months (range: 12–25, 9 projects with a first draft on record). The median duration of formal consultation was 153 days (range: 112–246, 10 projects), slightly above the 150-day timeline adopted by the Bureau of Ocean Energy Management (BOEM) and the National Marine Fisheries Service (NMFS). Ten of 11 opinions were issued before the final EIS and all 11 were issued before the decision. Vineyard Wind 1 and Revolution Wind had consultations reopened after approval (NOAA biological opinions, See data).
Share of projects sued	The share of projects subject to lawsuits is not estimated; the "delays and challenges" scenario assumes a lawsuit is filed.	Between 2010 and 2018, 28 percent of large energy and transport EISs were litigated, including about 66 percent of solar EISs, 50 percent of pipeline EISs, 38 percent of wind EISs, and 31 percent of transmission EISs (Bennon and Wilson). For solar and wind EISs specifically, 12 of 32 solar EISs and 8 of 16 wind EISs were litigated (RFF). Across all NEPA decisions between 2001 and 2013, about one in 450 was litigated (Ruple and Race).
Length of lawsuits	Under the bill, the average time from filing to a ruling would be nine months. By comparison, lawsuits involving pipeline, geothermal, and wind typically take nine to 12 months; transmission lawsuits take about two years; and offshore wind lawsuits and solar appeals take about three years.	Lawsuits in district courts take about one year to resolve, while appeals take at least three years (RFF). The median length of lawsuits is 23 months when the government wins and 30 months when the plaintiff wins (Liscow 2024, via Hochman). From approval to a final decision, lawsuits take about two years on average, with 7 percent lasting more than six years (IFP). From the environmental document to the end of an appeal, the timeline average is 4.2 years (Breakthrough).
Sponsor lawsuits over delay	Under the bill, project sponsors can file a lawsuit once the EIS deadline passes; a ruling is due within four months.	One sponsor lawsuit was filed under the 2023 NEPA deadline provision but was held premature 196 days after filing because the deadline had not passed (Signal Peak, 2024). In 2025 and 2026, developers and trade groups gained relief through lawsuits challenging added reviews and freezes, obtaining preliminary injunctions limited to the plaintiffs and their members within 119 days (Renew Northeast, D. Mass.) and a nationwide stay within 67 days (Renewable Northwest v. Hegseth, D. Or.) (See data).
Who wins, and what it costs	Vacatur is presented as a high-end case under current law.	Among 387 appellate NEPA cases between 2013 and 2022, agencies won about 80 percent (Breakthrough). Agencies also won more than 80 percent of 44 court decisions applying Seven County, with courts leaning toward remand without vacatur (WilmerHale). Litigated wind and solar projects reached operation in 41.2 months, compared with 40.9 for unlitigated projects. Litigation contributed to the termination of three projects in RFF's sample. For offshore wind, plaintiffs won one of 15 cases and none of seven injunction motions (CATF).
After the federal decision	Once a federal decision is made, the timeline to a notice to proceed is two to four months when deadlines are met and three to six months under the delays and challenges scenario; interconnection is not included.	Among solar projects, seven of 16 received a notice to proceed within one month. Nine of 24 solar projects and seven of 14 wind projects took four or more years after the federal decision to reach operation (RFF). For plants built in 2025, the median time from interconnection request to operation was 61 months (LBNL).
Other agencies' permits	Under current law, the last permit from an agency other than the lead is issued seven months after the final EIS for pipeline projects, five months after for offshore wind projects, and six months after for other projects. Under the bill, the last permit must be issued within 90 days. State water quality certifications, drawn with the Corps permit on the transmission chart, follow separate timelines: up to one year under current law and nine months under the bill.	Across 23 FAST-41 energy projects, the median timeline from final EIS to final decision was 6.2 months. The median was 7.1 months for eight gas pipelines and five months for 10 offshore wind farms (this page, from the Permitting Dashboard)
Time to the first suit	The median time to the first suit for each project type is marked on each window to sue but is not included in the timeline calculations.	The median time from approval to the first lawsuit was about one month for 10 solar and three months for six wind projects, with 22 of 27 solar and wind suits filed within 120 days (RFF). The median was 3.8 months for 15 of 20 large pipelines, 3.5 months for all 11 approved Atlantic offshore wind farms, and 8.6 months for seven of 16 transmission lines (this page, from court records)
Deadline compliance	The "deadlines met" scenario assumes compliance with deadlines, while the "delays and challenges" scenario assumes extensions followed by a lawsuit.	Between June 2023 and June 2025, agencies reported two EISs and 153 assessments that missed deadlines (CEQ). Among 46 FAST-41 timetables, 23 were extended, including 14 by more than a year (Permitting Council). Among 40 FAST-41 wind, solar, transmission, and gas pipeline projects, 20 were completed or scheduled to be completed more than one month after their original timetable, with six delayed by more than a year. FAST-41 timetables are set when a project joins the program, sometimes partway through its review. This measure therefore reflects whether agencies met their own schedules (Permitting Dashboard, downloaded Oct. 6, 2026; See data).

Limitations

Composite projects. Each archetype combines steps from several real cases. No single project followed every step as drawn.
Review scope. The charts review the entire line or pipeline under both laws, excluding any time savings from limiting historic review to the federally controlled segment (Sec. 2301). The sensitivity table in the data download quantifies this effect for the transmission line.
Geothermal wells. The charts retain development wells in the plant's EA under both laws, excluding any time savings from Sec. 2229's exemption for wells at recently drilled pads. The sensitivity table in the data download estimates the potential gain in time at 0 to 10 months in service.
No change in behavior. The replays and charts apply the bill's deadlines to historical dates. They do not account for agencies delaying completeness notices to avoid starting the clock, sponsors agreeing to extensions, or reviews written to a deadline drawing more suits or remands.
Survivors only. The replays include projects that reached an EIS—or, for geothermal exploration, a BLM review—and, in nearly all cases, a decision. Projects that stalled before an NOI, where the bill's NOI deadlines might have the greatest impact, are absent.
Decision, not service. The replays measure time to the federal decision, while the archetype charts extend to the in-service date. The replays therefore exclude state siting and the FERC backstop permit (Sec. 2101), which account for most of the transmission archetype's 96-month timeline. The bill reduces the timeline to the federal decision by 64 months in the archetype, compared with 60.7 months in the largest replay (Bordertown to California, a 10-mile, 120 kV line).
The EIS clock in the replays. The replays start the two-year clock at the NOI because the records rarely date the completeness notice. Under the bill, the clock starts at the earlier completeness notice, so the replays' EIS cap is generous to current law and understates the time savings.
Causes from public records. Agencies rarely record why a step took longer than expected; the Permitting Dashboard cites reasons for fewer than one in five delayed milestones. For many reviewed projects, the record identifies who held up the review but not why.
Date conventions. CEQ's final EIS date is based on EPA's notice of availability. CEQ's decision dates were checked against decision records and corrected where they differed. Dates recorded only by month or year are counted from the end of that period. Most geothermal exploration start dates are proxies: the operator's plan or notice, or BLM's earliest dated record of the proposal.
Pending projects. Bonanza, Mosey, and Vineyard Mid-Atlantic use the agency's current schedule, which may change.
Collection method. Records were collected using AI coupled with author review through secondary sources where available.
Bill text. The analysis reflects the September 30, 2026 text. Amendments would change the bill_provisions table in the data download and possibly the charts.