A February 2026 survey by Crux, a clean energy capital platform, put numbers to what CFOs and project finance teams have been navigating for the better part of two years. Every single developer and permitting professional surveyed reported federal permitting issues affecting at least one project in the prior 12 months. Across the 50 respondents, those impacts represented roughly 11 gigawatts (GW) of affected clean energy capacity, and 100% reported higher project costs as a direct result, with 58% citing cost increases of 6% to 10% of total project value.

That is not an abstract regulatory finding. For a project carrying $200 million in pre-development investment, a 6 to 10% cost overrun attributable to permitting delay represents $12 million to $20 million in value at risk before a shovel hits the ground. Add financing carry costs at current rates across an 18- to 36-month delay, and the math becomes difficult to ignore at the board level.

Permitting Delays Are Stranding Pre-Development Capital at Scale

The Crux survey documented a range of delay patterns, but the directional finding was consistent: the most common delay lasted six months or longer, with 8% of affected projects facing setbacks measured in multiple years. One anonymous respondent described a Nevada geothermal project that stalled indefinitely after an interagency disagreement over mitigation requirements, after three years and nearly $5 million in pre-development investment. Another recounted a utility-scale solar project delayed more than a year by litigation following federal approval, which triggered equipment rebids as prices escalated and locked up capital through multiple rounds of appeals.

These are not edge cases. Capital committed to pre-development is illiquid by nature, and the longer regulatory review extends, the further the project's financial model drifts from the conditions it was built on. Equipment pricing moves. Offtake counterparties who agreed to terms in 2023 are negotiating differently in 2026. Debt costs have not come down the way developers modeled them two years ago. By the time a federal approval finally arrives, the project it clears may not be the project the original investment committee approved.

Eighty Percent of Developers Are Redesigning Projects to Avoid Federal Triggers

One of the more operationally significant findings in the Crux analysis is that 80% of surveyed developers reported intentionally siting projects to avoid triggering federal permitting requirements under the National Environmental Policy Act (NEPA) and related frameworks. That is a rational response to unpredictability, but it carries its own costs. Avoided federal sites are not always the best sites. Siting decisions driven by permitting avoidance rather than resource quality or grid proximity can produce projects with higher development costs, lower capacity factors, or longer interconnection queues.

For capital planning teams evaluating a project pipeline, this pattern is worth understanding. A developer that has structured a project to avoid federal review may have done so at the expense of site quality or grid access. That tradeoff should be visible in due diligence, and it often is not.

What Mid-Year Capital Reviews Should Actually Be Testing

The question heading into the second half of 2026 is not whether permitting delays are a problem at the portfolio level. The Crux data makes that case plainly. The harder question is whether the financial models currently in use reflect what permitting actually costs, or whether they were built on timeline assumptions that predate the conditions developers are operating in now.

Duration assumptions are the most common gap. Pre-development cost models typically carry a permitting phase of defined length, often drawn from historical regional averages. Those averages have not kept pace with what the Crux survey found on the ground: most delays ran six months or longer, and for 8% of projects the setbacks extended across multiple years. A financing structure built around a projected commercial operation date absorbs that slippage through compounding carry costs on credit facilities, hedging arrangements that drift out of alignment, and equipment delivery contracts that require rebidding as prices move. Each of those interactions is individually manageable. Together, across a timeline that runs two years longer than planned, they can move a project from viable to marginal without any single line item flagging the change.

The World Economic Forum (WEF) identified regulatory complexity and permitting uncertainty as emerging barriers to energy transition investment specifically, and the Crux findings are consistent with that framing. What developers said they wanted most was not weaker environmental review. It was predictability: a timeline they could commit capital against with reasonable confidence. Seventy-two percent of respondents named that as their top ask. The money is available. The uncertainty about when and whether projects will clear review is what keeps it from moving.

When Holding a Stalled Project Stops Making Sense

Some projects currently sitting in federal review are approaching a decision point that capital planning teams have been deferring. The combination of extended timelines, higher carry costs, input price inflation on steel and copper, and narrowing Inflation Reduction Act (IRA) incentive windows has compressed the period in which a stalled project remains financeable on its original terms. That compression is not hypothetical. It shows up in the rebidding that Crux respondents described, in the offtake renegotiations that accompany long delays, and in the project cancellations that E2 has tracked across the clean energy sector in 2026.

For projects where the gap between original assumptions and current conditions has grown wide enough to require a fresh investment committee review, the sooner that review happens the more options remain on the table. Redeployment into projects with shorter or cleaner regulatory paths is a live choice right now. It becomes less live the longer pre-development capital sits committed to a timeline that keeps extending.