Updating Permitting Technology for the 21st Century

On April 15, 2025, President Trump signed the Presidential Memorandum, Updating Permitting Technology for the 21st Century to address the lack of transparency, fragmented data management, and outdated technology in the Federal environmental review and permitting process. The Presidential Memorandum calls on the Council on Environmental Quality (CEQ) to establish a Permitting Innovation Center and develop a Permitting Technology Action Plan to leverage modern technology to effectively, efficiently, and expeditiously navigate the Federal environmental review and permitting process for infrastructure projects. This Permitting Technology Action Plan will guide the government-wide implementation of 21st-century technology to eliminate needless delays to important infrastructure projects, protecting the economic well-being and welfare of the American people.

The Presidential Memorandum directs Federal agencies to make maximum use of technology in environmental review and permitting processes for infrastructure projects of all kinds. Given that direction, CEQ encourages all agencies to work towards the service delivery standards outlined in this Permitting Technology Action Plan. However, the Presidential Memorandum specifically directs the agencies listed in 42 U.S.C. 4370m-1(b)(2)(B)(i)-(xii) to adopt and begin implementing the data and technology standard and minimum functional requirements within 90 days of this plan’s issuance.

Permitting Technology Action Plan

The Permitting Technology Action Plan will guide Federal agencies as they make maximum use of technology to digitize permit applications, expedite reviews, enhance interagency coordination on projects, and give sponsors more transparency and predictability on project review schedules. This Permitting Technology Action Plan contains:

• Minimum functional requirements for environmental review and permitting systems;
• An initial NEPA and permitting data and technology standard;
• A 90-day timeline and implementation roadmap for the agencies listed in 42 U.S.C. 4370m-1(b)(2)(B)(i)-(xii) to adopt and begin implementation of the data and technology standard and minimum functional requirements; and
• A governance structure for implementation.

To make maximum use of technology in environmental review and permitting processes, Federal agencies need to move toward developing and employing an integrated, interoperable digital ecosystem of NEPA and permitting technology systems. In order to achieve this interoperability, agencies should plan to build systems on modern cloud-based technology stacks wherever possible. This will allow seamless information exchange between agencies, simplify interactions for applicants, and deliver transparent information to stakeholders.

E-NEPA Report to Congress

This Permitting Technology Action Plan is informed by CEQ’s E-NEPA Report to Congress1 required by 42 U.S.C. 4336d. The report found that because agency practice relies often on outdated systems, fragmented data management, and disconnected digital tools, technology has tremendous potential to increase the efficiency and effectiveness of agency NEPA and permitting practices. To realize that potential, CEQ’s E-NEPA Report to Congress recommended:

• Creating common standards for data associated with NEPA processes and documents;
• Developing a common model for how to structure data and design agency systems that will enable sharing of information;
• Supporting agency adoption of shared NEPA tools through iterative development of new and existing software applications; and
• Automating the exchange of data among agency systems to provide a unified experience.

This Permitting Technology Action Plan integrates these core recommendations.

Permitting Innovation Center

On April 30, 2025, CEQ established the Permitting Innovation Center that will be staffed and led by CEQ, and supported by the General Services Administration Technology Transformation Service. The Permitting Innovation Center will coordinate with agencies on implementing this Permitting Technology Action Plan, including through designing and testing prototype tools and providing technical support for implementation. Prototyping efforts will focus on case management systems, application submission and tracking portals, automation of application and review processes, data exchange between agency systems, and acceleration of complex reviews.

CEQ will make information available on these efforts at: Permitting.Innovation.gov.

Service Delivery Standards for Modern NEPA and Permitting Technology

In order to deliver effective and efficient environmental review and permitting processes for the 21st century, the Federal government must leverage technology to tackle longstanding problems—for example, reliance on outdated systems, fragmented data management, and disconnected digital tools, as identified in the E-NEPA Report. The solutions laid out in this Permitting Technology Action Plan will achieve a unified interagency environmental review and permitting data system consisting of interconnected agency systems and shared services. CEQ has identified four service delivery standards—high-level goals for environmental review and permitting systems—and ten core capabilities necessary to enable modern service delivery (see Minimum Functional Requirements and Implementation Paths section). As agencies consider the use of artificial intelligence (AI) in their NEPA and permitting software systems, they should reference the Office of Management and Budget memorandum M-25-21 on Accelerating Federal Use of AI through Innovation, Governance, and Public Trust.

To achieve a modern standard for efficient, effective, and agile service delivery for NEPA and other permitting processes, agencies should identify available resources to prioritize innovation in four key areas:

1. Business Process Modernization

Environmental review and permitting processes are comprised of a variety of business processes – workflows, tasks, and structured activities – that can be managed as a series of actions and events. Agency use of modern software that can track the full lifecycle of these processes is critical for effective project management and process improvement; enabling workflow automation, transparency, and tracking, and simplifying reporting requirements. CEQ’s study of NEPA and permitting technology shows that, while some agencies have implemented detailed case management systems that track progress and tasks over time, many agencies rely on a variety of manual processes for managing reviews. Agencies should implement modern business process management systems that track workflows. These systems should also produce interoperable event, task, and other milestone data that can be shared with other agencies’ systems. Modern systems can reduce costs and improve performance for all agencies, whether they process high volumes of low-impact project reviews or manage more complex, multi-stakeholder reviews, or both. Case management systems are essential tools for managing the tasks and activities associated with evaluation of environmental review and permit processing, and provide agencies more data and insight into these processes (e.g., to identify wait time/touch time ratios, flag potential bottlenecks, or highlight opportunities for process improvement interventions).

2. Workflow Automation

Even low-impact project reviews, such as categorical exclusions, may require frontline staff to consider multiple data sources and workflow steps before making a decision. Well-defined business rules can enable process automation that allows agencies to expedite routine review tasks and workflows. CEQ’s Permitting and Innovation Center can assist agencies with developing the policy and governance structures necessary to build, update, and maintain business rules related to permitting workflow automation. Existing best-in-class environmental review and permitting tools use defined decision logic, derived from statutory and regulatory requirements and supplemented by subject matter expertise, to create business rules that can assist staff by walking them through the applicable criteria and necessary information requirements for an agency decision. For instance, the U.S. Fish and Wildlife Service’s Information for Planning and Consultation system uses determination keys—a logically structured set of questions—to determine whether a project qualifies for a pre-approved consultation outcome based on existing programmatic consultations. Similar systems can employ automation through predefined geospatial data queries and the development and storage of a decision record that supports the agency permit or review determination. These tools are particularly useful for lower-complexity reviews (e.g., the application of a previously established categorical exclusion under NEPA) where the actions, conditions, and circumstances that must be analyzed are pre-defined.

3. Digital-First Documents

The existing practice of preparing environmental review and permitting documents, even when technology is used, is often still a digitized paper-based process. Agencies should design environmental review and permitting documents to deliver structured and readily usable data, with a traditional document format being just one application of that data. Taking a digital-first perspective will improve document quality, lead to more concise reports, and enable the reuse and accessibility of the data underpinning the agency analysis and decision. One method that agencies can use to achieve this digital-first approach is the creation of structured data packages as part of the environmental analysis. These data packages should follow a standard format, use consistent metadata structures, reference existing data sources used in the analysis, and where novel studies or models were conducted, include that information as supplemental documentation. CEQ’s NEPA and Permitting Data and Technology Standard provides a basic document-level metadata structure for agencies to follow. Structuring environmental review and permitting documents as data will enable objective, technology-assisted evaluation of environmental impacts, analysis, and documentation, and accelerate future document drafting.

4. Minimizing Timeline Uncertainty

Agency leadership, project sponsors, and the public should have access to up-to-date information on the status of project reviews and accurate timelines for process completion. Timeline data should include milestones for agency actions as well as project sponsor actions, such as the submission of required information for application processing. In addition to tracking major milestones associated with the formal, publicly available project schedule, agency case management systems should also track events and milestones that occur before and after these major process milestones to assist with internal agency planning and ongoing process improvement. Implementing automated data collection and reporting from case management systems enables program and office leadership within an agency to have access to predictive analytics that reduce or eliminate risk in reaching a decision. This information can assist agencies with improving transparency and accuracy of timeline estimates, which in turn can help project sponsors better plan for their application preparation and their project delivery milestones.