First Look at CEQ’s Permitting Technology Action Plan
Technical Depth Beyond the Soundbites
The tl;dr: A first look at the Council on Environmental Quality’s (CEQ) Permitting Technology Action Plan, which aims to modernize federal permitting processes. The plan includes data standards for interoperability between agencies, service delivery standards for workflow automation and digital documents, and a maturity model for agencies to gauge their progress. Key highlights include implementing data standards, improving document management, and using GitHub for open collaboration. We note the potential for multi-agency procurement and prize competitions and outline potential impacts for agencies, applicants, and vendors. We express cautious optimism due to the plan's technical depth, interoperability focus, and use of existing work but also note concerns about talent gaps and the aggressive initial 90-day implementation timeline.
A month ago, we cautiously applauded Trump's Presidential Memo on updating permitting technology, calling it "promising ideas, implementation TBD." Today, with the release of the Council on Environmental Quality’s (CEQ) Permitting Technology Action Plan, we can say the implementation details are starting to take shape—and they go beyond the “...drill more, map more, mine more, and build more” (Sec of the Interior Doug Burgum) soundbites from the press release from the initial Presidential Memo.
The action plan, launched by CEQ alongside a new Permitting Innovation Center and Permitting Data and Technology Standard, moves beyond the memo's high-level directives to provide concrete frameworks, data standards, and timelines. Most importantly, it includes something we've been advocating: actual data standards to enable interoperability between agencies. For non-technical readers; this is an attempt to go from the world of “What format is your document? Do we have that software? Can you save it as something else and re-send it?” to “everyone can open, edit, and share” the same document over and over.
It's important to note that the Permitting Technology Action Plan formalizes the great work of the agencies modernizing permits over the last few years. We applaud the continuity of focusing on bi-partisan technological approaches to permitting from the previous administration.
The Highlights
CEQ covers all the pillars of innovation as we described in our innovation indicators.
Pairing technical talent with subject matter experts
Developing and documenting the standards for technical and non-technical folks
Working in the open by using GiThub to host toolkist, documentation, and more
Paving the way for prize competitions and challenges
The Permitting Innovation Center is setting the stage for possible multi-agency procurement for shared services
Agencies have 90 days to adopt and begin implementing the standards and requirements
Data Standards
The data standard CEQ shared is not about functional environmental data but about information generated by the tasks and decision gates that go into permitting. The data standard focuses on the information that identifies content and context. It is about sharing the details of the project and the stages of the work instead of data on samples, monitoring, or impact analysis. Metadata is the "secret sauce" to help agencies, applicants, and the public collaborate, automate, and publish their findings faster.
Current applicants may have to submit the same documentation to multiple agencies via different tools or platforms.
A future with shared document management means an applicant can share one submission across federal agencies.
Currently GIS data is available in different formats and with custom layers and metadata, making comprehensive analysis time-consuming.
A future with standard location and GIS data integrated into multiple web applications used by agencies and shared with the public.
The NEPA and Permitting Data and Technology Standard is a 19-page technical document (and GitHub repository!) that defines how agencies should structure data across nine core entities: projects, processes, documents, comments, public engagement events, case events, GIS data, user roles, and legal structures. This isn't just bureaucratic box-checking; it's the foundation that could finally solve the "warehouse in Indiana Jones" problem we've written about, where valuable permitting data gets buried and never reused.
[check for a gif from a previous Becca post]
Service Delivery Standards
The action plan also establishes four service delivery standards that echo our smart permitting fundamentals: business process modernization, workflow automation, digital-first documents, minimizing timeline uncertainty, and using resources like GitHub to share information with the broader public. Sound familiar? We've been recommending these components, from eliminating paper applications to creating transparent and predictable timelines like Virginia's successful PEEP system. Given that approximately 1.5 million permitting actions occur during each presidential term, with 400,000 categorical exclusions under NEPA alone, standardized data and automated workflows could dramatically reduce the administrative burden on both agencies and applicants. We want all parties to get to yes or no faster.
The plan further documents ten areas for minimum functional requirements for agencies to meet, and a roadmap and timeline for reaching these minimums. Rather than using highly detailed requirements, CEQ has shared a maturity model to help gauge an agency's progress. The model defines the stages as follows:
Foundational Capabilities > Emerging > Leading Edge Practices
CEQ then lays out definitions for each stage across the ten areas of minimum functional requirements:
Minimum functional requirements and implementation paths
Implement data standards
Application data sharing
Automated project screening
Access to screening criteria
Automated case management tools
Integrated GIS analysis tools
Improved document management
Automated comment compilation and analysis
Administrative record management
Adopt common or interoperable agency services
Foundational
All relevant entities and data standard concepts are mapped to existing agency NEP and permitting systems
Emerging
Existing and new NEPA and permitting systems can retrieve standards-aligned data
Leading-Edge
Existing and new NEPA and permitting systems can (when authorized) read and write fully standards-aligned data to systems via API
An example of the maturity model applies to implementing data standards
Areas of Impact
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The Permitting Innovation Center will be a key resource to monitor as they expand their work into prototyping and software evaluation. GSA’s Technology Transformation Services (TTS) has given CEQ engineering support to the challenges ahead, but the demand for their services may be overwhelming. If you have a technology team or partner working on these issues, this could be an opportunity to collaborate on refining work in progress or raise use cases ideal for prototyping and testing. If you don't have a tech or innovation team available, this could be an opportunity to work with the Permitting Innovation Center's team on ideas and works-in-progress that your team hasn't been able to address yet.
CEQ also states it is considering establishing prize and challenge competitions to pursue further innovation. We’re fans of using federal challenges to solve stubborn problems, and look forward to seeing if and how they are applied here. Competitions have the potential to get funding to teams embedded at agencies faster than traditional procurement.
The action plan also notes the possibility of multi-agency procurement for software that provisions shared services. This one-line item could be the most impactful detail in the action plan if it opens the door to software for secure information exchange between agencies and all the benefits downstream.
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As we’ve said before, we need both permit applicants and regulators on the same page from the start. Quality applications = quality decisions. This work aims to help applicants navigate the permitting process with more transparency and collaboration from federal agencies. When done right, data standards should also help federal agencies share information with state and local authorities, but those use cases and exchanges will take time to develop and publish.
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Multi-agency procurement could present an opportunity for vendors to participate in the work to come by sharing standards and definitions of success. By laying out the minimum functional requirements for agencies, vendors should be able to demonstrate how they meet or exceed those standards. Once agencies submit plans, we hope there will be clear signals on what services and support are needed and where.
Vendors with existing agency relationships can likely assist with documenting how their current implementation works with the framework and paths to moving further along the maturity model's spectrum. If the new administration reduces the barrier to procurement, it could allow for rapid deployment across agencies and teams. We should see meaningful progress if the administration follows this approach and the work outlined above.
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Several elements suggest this action plan could produce tangible results and lasting improvements:
Real technical depth: The data standard genuinely understands permitting workflows and information architecture. The plan isn't a consultant-driven PowerPoint—it was developed by technologists in partnership with NEPA practitioners.
Interoperability focus: The emphasis on "seamless information exchange between agencies" addresses permitting's biggest inefficiencies. If agencies can share data in "an integrated, interoperable digital ecosystem of NEPA and permitting technology systems," we could eliminate the duplicative surveys and analyses that waste hundreds of thousands of dollars per project.
Learning from existing work: The plan mentions, “This Permitting Technology Action Plan is informed by CEQ's E-NEPA Report to Congress required by 42 U.S.C. 4336d.” We take it as a great sign they're building on what works rather than starting from scratch.
A focus on infrastructure, but not solely on energy infrastructure: While the press release features the expected quotes from energy and agriculture secretaries about "energy dominance," the actual technical documents are neutral, focusing on infrastructure. The action plan directs agencies to "make maximum use of technology in environmental review and permitting processes for infrastructure projects of all kinds, such as roads, bridges, mines, factories, power plants, and others."
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Adopting and implementing these standards in 90 days is aggressive by any standard. CEQ's decision to use a functional maturity model to help identify the scenarios and functionality in each stage (foundational, emerging, and leading-edge practice) should help agencies match their systems to the desired levels. The model also allows leadership to look across agencies and determine where to focus efforts. Still, mapping agency systems architecture will require the resources and focus of the Permitting Innovation Center.
Establishing the Permitting Innovation Center is a step in the right direction, but our original concerns about the dissolution of 18F and tech talent gaps remain valid. The action plan acknowledges this by partnering with TTS. Still, TTS has become the holding pen for previously assigned 18F projects, so we weigh our optimism against TTS's talent and staffing in the face of the unknown.
EPIC is breaking down the capabilities defined in the minimum functional requirements and implementation paths in the action plan to help agencies better see how they fit in the new framework. For starters, we’ve created a consolidated checklist of the service delivery standards by maturity stage to review against current capabilities and see where to focus future efforts.
[Link to maturity model spreadsheet final doc]
In the coming weeks, EPIC and other partners will gather steps agencies could take to adopt and begin implementing the new standards and minimal functional requirements.
We'll track implementation progress and provide deeper analysis as agencies begin rolling out these systems. Have questions about specific technical aspects of the plan or are interested in collaborating on implementation? Reach out to Boon Sheridan