An astonishing fact that most policymakers working on energy permitting reform don’t realize: Clean energy & transmission projects have National Historic Preservation Act (NHPA) review areas about 10 times larger than fossil fuel projects and are more than 8 times as likely to receive an "adverse effect" finding --triggering additional process, delay, and mitigation obligations. Before joining @IFP, I spent 10 years litigating infrastructure and energy cases at DOJ and saw this firsthand. Now, IFP has analyzed ~100 energy projects and built an interactive tool to explore the data so you can see this disparity for yourself: nhpa-ape-stats.org The source of this discrepancy is the National Historic Preservation Act’s Section 106 process. Here’s how it works: 1. Every Section 106 review has an "Area of Potential Effects," or APE: the area where an agency determines that a project could affect historic properties. 2. The APE is not limited to the construction footprint. It can include every place from which a project might be visible. 3. Wind turbines and transmission towers are tall. Pipelines are generally buried. A facially neutral rule tying review to visibility therefore produces much larger APEs for the infrastructure needed to build a clean grid. 4. The differences are striking: The median visual APE for offshore wind was 40 miles from the project. The median indirect APE for gas and LNG projects was 0.5 miles. 5. A 40-mile-radius circle encompasses about 5,000 square miles. A half-mile-radius circle encompasses about 0.8 square miles -- a 6,400-fold difference. 6. Larger APEs mean more land to survey, more potentially eligible historic properties to evaluate, more parties to consult, and more effects to document. They also make adverse effect findings and mitigation obligations more likely. 7. The current rules create a structural clean energy disadvantage -- one that Congress can address while leaving the Tribal consultation portion of NHPA *entirely unchanged.* 8. Congress could establish reasonable limits on visual APEs, require visual changes to materially impair the characteristics that make a property historically significant, and prevent the designation of an entire landscape from automatically expanding review to every acre and every view. The APE Explorer lets users compare projects, filter by energy source, and trace the findings back to the underlying federal documents. If you'd like to learn more, our broader report explains how Section 106 works and presents a more comprehensive reform agenda: ifp.org/reforming-section-10…