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Regulatory Alerts

Department of the Interior Imposes Sweeping Review Process for Wind and Solar Projects

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Posted

July 23, 2025

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On July 15, 2025, the U.S. Department of the Interior (DOI) issued a memo titled Departmental Review Procedures for Decisions, Actions, Consultations, and Other Undertakings Related to Wind and Solar Energy Facilities. This directive, issued in accordance with recent executive and secretarial orders, requires that all decisions, actions, consultations, and approvals related to wind and solar energy projects with a DOI nexus undergo review at the highest levels of the agency. Routine permitting and review activities must now be elevated to the Secretary’s office, significantly altering standard review timelines and agency workflows.

The memo lists 69 categories of actions now subject to this additional review and approval process including National Environmental Protection Act (NEPA) documentation, right-of-way approvals, lease actions, consultation under the Endangered Species Act (ESA) and National Historic Preservation Act (NHPA), visual impact assessments, and more. This directive may also extend to coordination with state or local environmental review processes, as well as to other types of infrastructure that primarily support or are functionally tied to wind or solar projects.

Why It Matters

Federal agencies, including the U.S. Fish and Wildlife Service (USFWS), have already begun implementing this directive. For example, USFWS has temporarily disabled automated tools in the IPaC system for renewable energy projects, affecting official species lists generation and consultation workflows. These and other disruptions are beginning to impact project schedules and create uncertainty across the industry.

What You Can Do

SWCA is actively tracking this policy’s implementation and working with our clients to navigate the resulting uncertainty and determine impacts to project schedules, costs, and overall timeframes for development. We recommend the following steps:

  • Review your project to determine if it may be subject to the DOI memo.
  • Identify any remaining actions or coordination needed with the relevant DOI agency.
  • Assess and update project schedules and workflows to account for possible changes in review timelines.
  • Engage SWCA permitting and policy specialists to develop contingency strategies.
  • Consider alternative options for the siting, routing, and permitting of your project, if appropriate.
  • Record and track project impacts to support effective planning and communication as additional guidance becomes available.

SWCA Can Help

SWCA is closely monitoring DOI’s implementation of the memo and its effects across regions and agencies. We are ready to help you assess project exposure, communicate with federal partners, and manage risk in your development timeline.

Please reach out to your project manager or any of SWCA’s regulatory specialists to the left to discuss how this directive may affect your projects and how we can partner with you to support your long-term objectives. SWCA remains committed to providing consistent and in-depth expertise as the regulatory landscape evolves.

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