Before shovels hit the ground on any clean energy project or transmission line, developers must navigate a complex web of approvals. At both the state and federal levels, environmental review is a central part of that process. It’s also known for delaying critically needed clean energy projects. 

Programmatic review has emerged as a promising tool to speed up the process. By allowing multiple projects to rely on a shared environmental analysis, it has the potential to cut red tape and speed up project timelines. But so far, evidence at the federal level has been mixed. And as Washington and California look to apply this approach to clean energy projects themselves, it’s fair to ask: will programmatic reviews speed up the permitting process? 

To answer that, it helps to understand how we got here. 

The Roots of Environmental Review 

The foundation of environmental review in the U.S. was laid in 1970, when President Richard Nixon signed the National Environmental Policy Act (NEPA) into law. Its core idea was simple: before federal agencies act, they must evaluate the environmental consequences of their actions. 

Often referred to as the “Magna Carta of Environmental Law,” NEPA has had far-reaching influence. Dozens of states followed suit, adopting their own versions, known as state NEPAs, or SEPAs. 

Over time, both federal and state governments have looked for ways to make environmental review more efficient, often borrowing from each other’s playbooks. One tool to emerge from this cross-pollination is the programmatic review. 

What Is a Programmatic Review? 

At its core, a programmatic review is a broad environmental analysis that future projects can build off of, sometimes referred to as “tiering”. Rather than starting from scratch every time, developers and agencies can build on a shared foundation. 

That’s the theory. In practice, implementation has proven to be more complicated. 

The Federal Context 

Federal agencies have long had the authority to conduct programmatic reviews, but they aren’t often used. Agency staff have frequently questioned their value, were unsure how to implement them, or didn’t know how long the findings would remain valid.  

A 2003 NEPA task force identified these issues, but it wasn’t until 2014 that the Council on Environmental Quality issued formal guidance. Even then adoption remained limited. Congress tried again in 2023 to give legal certainty to agencies by explicitly stating in the Fiscal Responsibility Act that programmatic reviews can be used for up to five years.  

Still today, the best available data suggests only a handful of programmatic reviews are completed each year. One of the most ambitious attempts, the Bureau of Land Management’s Western Solar Plan, illustrates both the promise and pitfalls of the approach. 

The Western Solar Plan 

In response to a surge of interest in solar development on federal lands after the 2005 Energy Policy Act, the Bureau of Land Management launched the Western Solar Plan (WSP). In essence, the WSP was a programmatic review. Finalized in 2012, it assessed more than 17 million acres across six southwestern states. It designated select areas as “Solar Energy Zones” (SEZs), aiming to channel development into regions with low environmental conflict and easy access to grid infrastructure. 

In theory, the WSP promised faster reviews by allowing individual projects to build off a broader environmental analysis. And in a few early cases, it worked. In Nevada’s Dry Lake SEZ, for example, three projects were approved in less than ten months. The Department of Interior claimed that was less than half the time of traditional review. But those fast-track successes proved to be the exception, not the rule.  

In the decade after the WSP was finalized, very few utility-scale solar projects were built using its framework. In fact, developers have continued to seek approval outside the designated zones, often because the SEZs were not well-aligned with solar resource availability or market demand. 

This gap between ambition and implementation underscores a critical lesson: for a programmatic review to work, it must be paired with developer interest, clear incentives, and timely follow-through. Otherwise, it’s may not worth the effort. 

Washington’s HB 1216 

In 2023, Washington’s State Legislature passed House Bill 1216, directing the state’s Department of Ecology to develop three programmatic reviews: one for solar energy, one for onshore wind energy, and one for green electrolytic and renewable hydrogen projects. The programmatic reviews are supposed to be published by June 30, 2025. This timeline gives the agency a two-year runway to work with stakeholders, gather data, and target viable sites. 

The program structure is a strength thanks to a clear legislative mandate. By setting clear directives and a deadline, Washington is avoiding the pitfalls of open-ended planning. Early drafts are already available, suggesting steady progress. But the real test will come after 2025: Will developers actually use these reviews to fast-track projects? Will permitting timelines improve? These are still open questions, but there’s reason to be optimistic. 

California’s SB 254 

The California legislature is also looking to bolster the use of programmatic reviews with a recently introduced bill, SB 254. If passed, it would push the California Energy Commission (CEC) to prepare programmatic reviews for specific classes of clean energy facilities. No new authorities are assigned to the CEC. No specific technologies are named. No deadlines are set. 

This flexibility could be a virtue. It would allow the CEC to tailor its efforts to evolving needs, focusing on technologies or regions where programmatic reviews offer the greatest leverage. That flexibility, however, comes with a trade-off. Without a clear mandate or timeline, there’s a risk these reviews may not materialize fast enough to support California’s near-term clean energy buildout. 

Given California’s ambitious clean energy targets, time is a critical variable. Drawing lessons from Washington’s more structured approach may help California enhance its own process and avoid delays. 

Conclusion: Getting It Right 

Programmatic reviews are not a silver bullet. But they can be a powerful tool to accelerate clean energy deployment if backed by clear authority, designed around market realities, and implemented on a firm timeline. Washington is setting a promising example with a targeted, time-bound approach. California, while taking a different path, has an opportunity to learn from these efforts and adapt accordingly. Only time will tell if these tools help manifest real-world progress.