White House Directs Modernization of NEPA Permitting to Accelerate Environmental Reviews

Consistent with the Trump administration’s broader efforts to rapidly overhaul and modernize the federal environmental review framework and support the development of new infrastructure projects, the Memorandum directs an aggressive implementation schedule. CEQ must develop a centralized action plan supported by digital infrastructure by May 30, 2025, with agencies implementing updated standards by August 28, 2025.

Permitting Technology Action Plan
Pursuant to the Memorandum, CEQ, in consultation with the National Energy Dominance Council, must deliver a Permitting Technology Action Plan by May 30, 2025. The Action Plan will establish technological standards, software criteria and governance structures necessary for modernizing federal permitting processes. Key directives include:

• Unified Permitting Data System. Develop a roadmap to integrate permitting via interoperable platforms to support consistent and coordinated environmental reviews.
• Minimum Technology Requirements. Establish functional standards for permitting software, including digital case management, automation tools for low-risk reviews and standardized formats for environmental documentation.
• Data Standardization and Performance Monitoring. Implement common data formats, analytics and reporting tools to reduce uncertainties, accelerate reviews and enhance interagency decision-making.
• Governance and Implementation Timeline. Create an interagency oversight framework, including a clear schedule for agency adoption.

Even though CEQ formally rescinded its government-wide NEPA regulations on April 11, 2025, it will continue coordinating with agency NEPA personnel to support rollout of the Action Plan. Forthcoming guidance is expected to assist agencies in aligning their procedures with the Trump administration’s broader streamlining and modernization objectives.

To support implementation of the Action Plan, CEQ will establish and lead a Permitting Innovation Center by April 30, 2025. The Center will design and test prototype tools, such as case management systems, application portals and automation features, to streamline NEPA and related permitting reviews. Furthermore, by August 28, 2025, agencies within the Federal Permitting Improvement Steering Council (FPISC), including the Department of Energy, Nuclear Regulatory Commission, Federal Energy Regulatory Commission and Environmental Protection Agency, must begin implementing CEQ’s data and technology standards across new and existing review systems. CEQ will coordinate this effort in partnership with agency permitting and information technology leadership to ensure consistent integration.

Policy Continuity from the First Trump Term
The Memorandum continues a policy trajectory launched during President Trump’s first term. On August 15, 2017, President Trump issued Executive Order 13807, which introduced the “One Federal Decision” framework, requiring a lead agency for major infrastructure reviews, unified project timelines and a goal of completing environmental reviews within two years. That effort culminated in CEQ’s 2020 update to NEPA’s implementing regulations. The 2020 rule, the first comprehensive revision since 1978, removed requirements to consider cumulative and indirect environmental effects, established firm page and time limits for environmental documents, expanded the role of project applicants in drafting reviews, and narrowed the scope of “major federal actions” subject to NEPA.

The Memorandum’s policy framework also parallels recommendations in Project 2025, which advocated for a stronger FPISC, standardized review schedules and CEQ-led regulatory revisions emphasizing efficiency. Many of these proposals are reflected in the Memorandum’s directives.

Key Considerations for Federally Reviewed Critical Infrastructure Projects
As NEPA implementation evolves, infrastructure stakeholders should consider how agency-level changes may affect project planning, documentation strategies and regulatory engagement. The shift from centralized regulations to individualized agency procedures, combined with the integration of permitting technology, introduces new dynamics that will influence how environmental reviews are initiated, conducted and evaluated. Project stakeholders should be aware of the following:

• Expedited Project Timelines. The digitization of permitting and increased interagency coordination envisioned under the Action Plan could help accelerate approvals for energy infrastructure projects, including generation, transmission and storage facilities, sectors where NEPA compliance has traditionally posed complex and time-consuming challenges.
• Improved Navigability of NEPA for Project Developers. By standardizing documentation formats and review procedures, the forthcoming technological upgrades may reduce the procedural uncertainty that often affects energy developers, particularly those navigating multi-agency reviews or pursuing projects in emerging sectors, like hydrogen, advanced nuclear or carbon capture.
• Agency-Specific Procedures. Although CEQ’s NEPA regulations have been rescinded and each agency must exclusively operate under its own procedures, the Memorandum’s initiatives, such as interoperable platforms and standardized data, are intended to support greater interagency coordination and consistency across NEPA review, which may help project developers navigate multi-agency approvals more efficiently.
• Technology-Based Review Systems. The Action Plan is expected to introduce new digital tools, submission platforms and data standards. While these systems are designed to streamline reviews over time, project developers may initially face added burdens adapting their documentation to fit new standardized formats and digital workflows.
• Ongoing Procedural Updates. Agencies will be revising their NEPA processes over the course of 2025. Project timelines, documentation requirements and points of agency engagement may shift as new internal procedures are implemented, which could affect critical infrastructure projects already in early-stage planning or permitting.
• Sponsor-Prepared Documentation. Consistent with the 2020 NEPA rule, agencies may allow or encourage project sponsors to prepare or aid in preparing environmental documents. Stakeholders with in-house or consultant environmental teams should assess how agency-specific expectations align with their internal capabilities and project strategies.
• Legal Framework in Transition. As NEPA implementation shifts from a centralized regulatory model to one based on agency guidance, courts and litigants may encounter new procedural questions. Given the environmental complexity and visibility of many critical infrastructure projects, developers should closely monitor how agencies apply the revised framework and emerging case law interpretations.

Stakeholders may benefit from revisiting internal permitting strategies in light of evolving documentation formats and agency expectations. Legal, environmental and project development teams should remain aligned as technology-based systems come online.

Next Steps
CEQ is expected to release the Action Plan by May 30, 2025, with implementation by FPISC-member agencies required by August 28, 2025. Correspondingly, federal agencies will continue revising their NEPA procedures in line with CEQ guidance. These developments may impact permitting timelines, technical requirements and agency coordination processes. Pillsbury is closely monitoring these changes and remains available to assist clients in evaluating agency-specific updates, preparing for procedural shifts and engaging with federal permitting authorities.