Technology and NEPA: A Roadmap for Innovation

Improving American competitiveness, security, and prosperity depends on private and public stakeholders’ ability to responsibly site, build, and deploy proposed critical energy, infrastructure, and environmental restoration projects. Some of these projects must undergo some level of National Environmental Policy Act (NEPA) review, a process that requires federal agencies to consider the environmental impacts of their decisions. 

Technology and data play an important role in and ultimately dictate how agencies, project developers, practitioners and the public engage with NEPA processes. Unfortunately, the status quo of permitting technology falls far short of what is possible in light of existing technology. Through a workstream focused on technology and NEPA, the Federation of American Scientists (FAS) and the Environmental Policy Innovation Center (EPIC) have described how technology is currently used in permitting processes, highlighted pockets of innovation, and made recommendations for improvement. 

Key findings, described in more detail below, include: 

Introduction

The Federation of American Scientists (FAS) is a nonprofit, nonpartisan organization that works to embed science, technology, innovation, and experience into government and public discourse. The Environmental Policy Innovation Center (EPIC) is a nonprofit, nonpartisan organization focused on building policies that deliver spectacular improvement in the speed of environmental progress. 

FAS and EPIC have partnered to evaluate how agencies use technology in permitting processes required by NEPA. We’ve highlighted pockets of innovation, talked to stakeholders working to streamline NEPA processes, and made evidence-based recommendations for improved technology practices in government. This work has substantiated our hypothesis that technology has untapped potential to improve the efficiency and utility of NEPA processes and data. 

Here, we share challenges that surfaced through our work and actionable solutions that stakeholders can take to achieve a more effective permitting process.

Background

NEPA was designed in the 1970s to address widespread industrial contamination and habitat loss. Today, it often creates obstacles to achieving the very problems it was designed to address. This is in part because of an emphasis on adhering to an expanding list of requirements that adds to administrative burdens and encourages risk aversion. 

Digital systems and tools play an important role at every stage of the permitting process and ultimately dictate how federal employees, permit applicants, and constituents engage with NEPA processes and related requirements. From project siting and design to permit application steps and post-permit activities, agencies use digital tools for an array of tasks throughout the permitting “life-cycle”—including for things like permit data collection and application development; analysis, surveys, and impact assessments; and public comment processes and post-permit monitoring. 

Unfortunately, the current technology landscape of NEPA comprises fragmented and outdated data, sub-par tools, and insufficient accessibility.  Agencies, project developers, practitioners and the public alike should have easy access to information about proposed projects, similar previous projects, public input, and up-to-date environmental and programmatic data to design better projects. 

Our work has largely been focused on center-of-government agencies and actions agencies can take that have benefits across government. 

Key actors include: 

Below, we outline key challenges identified through our work and propose actionable solutions to achieve a more efficient, effective, and transparent NEPA process.

Challenges and Solutions

Product management practices are not being applied broadly to the development of technology tools used in NEPA processes. 

Applying product management practices and frameworks has potential to drastically improve the return on investment in permitting technology and process reform.  Product managers help shepherd the concept for what a project is trying to achieve and get it to the finish line, while project managers ensure that activities are completed on time and on budget.  In a recent blog post, Jennifer Pahlka (Senior Fellow at the Federation of American Scientists and the Niskanen Center) contrasts the project and product funding models in government. Product models, executed by a team with product management skills, facilitate iterative development of software and other tools that are responsive to the needs of users. 

Throughout our work, the importance of product management as a tool for improving permitting technology has become abundantly clear; however there is substantial work to be done to institutionalize product management practices in policy, technology, procurement, and programmatic settings.

Solutions: 

Siloed, fragmented data and systems cost money and time for governments and industry

As one partner said, “NEPA is where environmental data goes to die.” Data is needed to inform both risk analysis and decisions; data can and should be reused for these purposes. However, data used and generated through the NEPA process is often siloed and can’t be meaningfully used across agencies or across similar projects. Consequently, applicants and federal employees spend time and money collecting environmental data that is not meaningfully reused in subsequent decisions.   

Solutions: 

Technology tools used in NEPA processes fall far short of their potential

The status quo of permitting technology falls far short of what is possible in light of existing technology. Permitting tools we identified in our inventory range widely in intended use cases and maturity levels. Opportunities exist to reduce feature fragmentation across these tools and improve the reliability of their content. Additionally, many software tools are built and used by a single agency, instead of being efficiently shared across agencies. Consequently, technology is not realizing its potential to improve environmental decision-making and mitigation through the NEPA process. 

Solutions: 

Existing NEPA technology tools are difficult for agencies, applicants, and constituents to use 

Agencies generally do not conduct sufficient user research in the development of permitting technology. This can be because agencies do not have the resources to hire product management expertise or train staff in product management approaches. Consequently, agencies may only engage users at the very end (if at all), or not think expansively about the range of users in the development of technology for NEPA applications. Advocacy groups and permit applicants aren’t well considered as tools are being developed. As a consequence, permitting forms and other tools are insufficiently customized for their sectors and audiences.

Solutions: 

Poor understanding of the costs and benefits of NEPA processes

Costs and benefits of the federal permitting sector have to date been poorly quantified, which makes it difficult to decide where to invest in technology, process reform, talent, or a combination. Applying technology solutions in the wrong place or at the wrong time could make processes more complicated and expensive, not less. For instance, automating a process that simply should not exist would be a waste of resources. At the same time, eliminating processes that provide critical certainty and consistency for developers while delivering substantial environmental benefits would work against goals of achieving greater efficiency and effectiveness.

A more reliable, comprehensive accounting of NEPA costs and benefits will help us design solutions that cost less for taxpayers, better account for public input, and enable rapid yet responsible deployment of energy infrastructure and other critical projects. 

Solutions: 

Conclusion

Policymakers, agencies, and permitting stakeholders should recognize the important role that systems and digital tools play in every stage of the permitting process and take steps to ensure that these technologies meet user needs. Developing data standards and a data fabric should be a high priority to support agency innovation and collaboration, while case management systems and a cohesive NEPA database are essential for supporting policy decisions and ensuring that data generated through NEPA is reusable. Leveraging technology in the right place at the right time can support permitting innovation that improves American competitiveness, security, and prosperity.

Building a Comprehensive NEPA Database to Facilitate Innovation

The Inflation Reduction Act and the Infrastructure Innovation and Jobs Act are set to drive $300 billion in energy infrastructure investment by 2030. Without permitting reform, lengthy review processes threaten to make these federal investments one-third less effective at reducing greenhouse gas emissions. That’s why Congress has been grappling with reforming the National Environmental Policy Act (NEPA) for almost two years. Yet, despite the urgency to reform the law, there is a striking lack of available data on how NEPA actually works. Under these conditions, evidence-based policy making is simply impossible. With access to the right data and with thoughtful teaming, the next administration has a golden opportunity to create a roadmap for permitting software that maximizes the impact of federal investments.

Challenge and Opportunity

NEPA is a cornerstone of U.S. environmental law, requiring nearly all federally funded projects—like bridges, wildfire risk-reduction treatments, and wind farms—to undergo an environmental review. Despite its widespread impact, NEPA’s costs and benefits remain poorly understood. Although academics and the Council on Environmental Quality (CEQ) have conducted piecemeal studies using limited data, even the most basic data points, like the average duration of a NEPA analysis, remain elusive. Even the Government Accountability Office (GAO), when tasked with evaluating NEPA’s effectiveness in 2014, was unable to determine how many NEPA reviews are conducted annually, resulting in a report aptly titled “National Environmental Policy Act: Little Information Exists on NEPA Analyses.”

The lack of comprehensive data is not due to a lack of effort or awareness. In 2021, researchers at the University of Arizona launched NEPAccess, an AI-driven program aimed at aggregating publicly available NEPA data. While successful at scraping what data was accessible, the program could not create a comprehensive database because many NEPA documents are either not publicly available or too hard to access, namely Environmental Assessments (EAs) and Categorical Exclusions (CEs). The Pacific Northwest National Laboratory (PNNL) also built a language model to analyze NEPA documents but contained their analysis to the least common but most complex category of environmental reviews, Environmental Impact Statements (EISs).

Fortunately, much of the data needed to populate a more comprehensive NEPA database does exist. Unfortunately, it’s stored in a complex network of incompatible software systems, limiting both public access and interagency collaboration. Each agency responsible for conducting NEPA reviews operates its own unique NEPA software. Even the most advanced NEPA software, SOPA used by the Forest Service and ePlanning used by the Bureau of Land Management, do not automatically publish performance data.

Analyzing NEPA outcomes isn’t just an academic exercise; it’s an essential foundation for reform. Efforts to improve NEPA software have garnered bipartisan support from Congress. CEQ recently published a roadmap outlining important next steps to this end. In the report, CEQ explains that organized data would not only help guide development of better software but also foster broad efficiency in the NEPA process. In fact, CEQ even outlines the project components that would be most helpful to track (including unique ID numbers, level of review, document type, and project type).

Put simply, meshing this complex web of existing softwares into a tracking database would be nearly impossible (not to mention expensive). Luckily, advances in large language models, like the ones used by NEPAccess and PNNL, offer a simpler and more effective solution. With properly formatted files of all NEPA documents in one place, a small team of software engineers could harness PolicyAI’s existing program to build a comprehensive analysis dashboard.

Plan of Action

The greatest obstacles to building an AI-powered tracking dashboard are accessing the NEPA documents themselves and organizing their contents to enable meaningful analysis. Although the administration could address the availability of these documents by compelling agencies to release them, inconsistencies in how they’re written and stored would still pose a challenge. That means building a tracking board will require open, ongoing collaboration between technologists and agencies.

Conclusion

The stakes are high. With billions of dollars in federal climate and infrastructure investments on the line, a sluggish and opaque permitting process threatens to undermine national efforts to cut emissions. By embracing cutting-edge technology and prioritizing transparency, the next administration can not only reshape our understanding of the NEPA process but bolster its efficiency too.

This action-ready policy memo is part of Day One 2025 — our effort to bring forward bold policy ideas, grounded in science and evidence, that can tackle the country’s biggest challenges and bring us closer to the prosperous, equitable and safe future that we all hope for whoever takes office in 2025 and beyond.

PLEASE NOTE (February 2025): Since publication several government websites have been taken offline. We apologize for any broken links to once accessible public data.

Frequently Asked Questions
Why is it important to have more data about Environmental Assessments and Categorical Exclusions?

It’s estimated that only 1% of NEPA analyses are Environmental Impact Statements (EISs), 5% are Environmental Assessments (EAs), and 94% are Categorical Exclusions (CEs). While EISs cover the most complex and contentious projects, using only analysis of EISs to understand the NEPA process paints an extremely narrow picture of the current system. In fact, focusing solely on EISs provides an incomplete and potentially misleading understanding of the true scope and effectiveness of NEPA reviews.


The vast majority of projects undergo either an EA or are afforded a CE, making these categories far more representative of the typical environmental review process under NEPA. EAs and CEs often address smaller projects, like routine infrastructure improvements, which are critical to the nation’s broader environmental and economic goals. Ignoring these reviews means disregarding a significant portion of federal environmental decision-making; as a result, policymakers, agency staff, and the public are left with an incomplete view of NEPA’s efficiency and impact.