Implementation Roadmap and Timeline

Agency implementation of the minimum functional requirements and data and technology standard that are part of this Action Plan will require planning for necessary resource allocation, including budgetary and staffing considerations. CEQ will work with agencies as they develop implementation plans to assist with prioritizing implementation actions and will provide templates and guidance for agencies to use in implementation planning. As agencies develop their implementation plans, they should consider the information contained in CEQ’s E-NEPA Report to Congress, specifically section 2.5.2 De-Risking the Development of NEPA and Permitting Technology.

Pursuant to the Presidential Memorandum, agencies shall adopt and begin implementing CEQ’s data and technology standard and minimum functional requirements by August 28, 2025 (ninety days from the issuance of this Permitting Technology Action Plan). To meet this requirement, agencies will:

• Identify the concepts in the data and technology standard in their existing NEPA and related permitting systems, conduct a cross-walk between those systems and the data and technology standard, and provide estimated completion dates for data retrieval capabilities and API implementation;
• Assess their current technological capabilities across the ten minimum functional requirements;
• Develop and submit to CEQ an implementation plan which lays out actionable steps necessary to achieve the foundational, emerging, and leading-edge practices identified in the Minimum Functional Requirements and Implementation Paths section; and
• Begin taking actions identified in their agency implementation plan.

Agency implementation plans should focus on NEPA and related authorization processes an agency is responsible for implementing. Agency plans should reflect incremental steps to achieve the leading-edge capabilities associated with each minimum functional requirement. Where a particular capability is not applicable given the agency’s program requirements, an explanation to that effect should be provided. The specific actions in a given agency’s implementation plan will depend on their existing technological capabilities, but agencies should plan to make meaningful progress towards the next stage of the maturity model for each minimum functional requirement in the next six to nine months. Agencies will provide periodic implementation updates no less than twice annually. CEQ will work with agencies to provide guidance and a format for these updates. As discussed in the Governance section, CEQ will use the Federal Permitting Improvement Steering Council to ensure agency views are represented in the development of updates to the data and technology standard and implementation of this Action Plan.

Concurrent with agency implementation, CEQ’s Permitting Innovation Center will work with agencies on prototype tool development. The goal of this prototyping process is to design, test, demonstrate, and move to production tools that meet certain of the minimum functional requirements. CEQ will engage with agencies during the prototype development process so that agencies can inform the development process and use the prototypes to implement their own systems and reduce duplication of effort. The Permitting and Innovation Center will also look for opportunities to partner with agencies around the development of shared services, provide technical assistance, engage with agency Chief Information Officers, and assist with training and change management associated with technology implementation.

Private sector software and technology solutions will be a necessary component of the successful implementation of this Permitting Technology Action Plan. CEQ’s Permitting Innovation Center will engage with private sector firms to provide demonstrations to agencies of commercial-off-the-shelf software, provide input on the solutions being sought by the Federal government, and solicit prototypes that can be acquired by agencies to fulfill the requirements of this Action Plan.

Effective implementation will require a range of innovative methods beyond traditional technology procurement and development, including:

• Rapid, agile prototyping and piloting of minimum-viable solutions;
• Prize and challenge competitions that disrupt traditional thinking and evolve what is possible; and
• Multi-agency procurements that more efficiently provision innovative shared services.

The following timeline lays out the key implementation steps necessary for agencies to take in order to meet this directive and implement the Permitting Technology Action Plan: