DOI Memorandum on review of Wind and Solar Energy Facilities
Written by Amardeep Dhanju
On July 15, 2025, the Department of Interior (DOI) issued a new memorandum, titled, “Department Review Procedures for Decisions, Actions, Consultations, and Other Undertakings Related to Wind and Solar Energy Facilities.” The memorandum establishes additional and more centralized review procedures, effective immediately, for wind and solar projects proposed on public lands and the Outer Continental Shelf (OCS) managed by DOI. Specifically, a broad range of project-related decisions, actions, and consultations must now be submitted to the Office of the Executive Secretariat and Regulatory Affairs, proceed through the Office of the Deputy Secretary, and receive final review by the Office of the Secretary. This marks a significant shift from DOI’s prior review process, which delegated many decisions and approvals to the agency, bureau, or even program level, typically managed in close collaboration with program specialists, subject matter experts, and project proponents.
According to the Bureau of Land Management (BLM), as of January 2025, 38 wind and solar energy projects with a combined installation capacity of more than 23 GW are under review. Meanwhile, multiple offshore wind projects on the OCS are currently progressing through environmental review. These reviews face an added layer of complexity due to a recent Presidential Memorandum, issued on January 20, 2025, which temporarily withdraws certain OCS areas from wind leasing and calls for a comprehensive review of federal wind energy permitting practices. Additionally, new lease sales for land-based projects are also subject to enhanced review process.
The new DOI memorandum specifies 69 types of decisions, actions, and consultations now requiring elevated departmental review. These include, but are not limited to, cost recovery agreements, the preparation and evaluation of draft and final environmental assessments and impact statements, findings of no significant impact, records of decision, approval letters, development plans, site assessments plans, preconstruction surveys, supplemental environmental reports, and “any other similar or related decisions, actions, consultations, or undertakings.” Notably, the memorandum also includes a catch-all clause, allowing the Department at its discretion to elevate other similar undertakings for review.
This additional layer of oversight could lengthen the approval process as developers race to meet deadlines for the Inflation Reduction Act (IRA) renewable energy tax credits now amended with an accelerated phase-out schedule introduced in the recently enacted “One Big Beautiful Bill Act.”
Aspen Environmental Group is closely monitoring these regulatory developments. Drawing on decades of experience with renewable energy projects on federal lands and the OCS, our team has thoroughly analyzed this memorandum and related Executive Orders and Presidential Memorandums. We are ready to help clients successfully navigate these evolving requirements and keep projects moving forward in this rapidly changing regulatory landscape.