Docket ID No. FRL-13178-01-OCFO
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Introduction
The U.S. Environmental Protection Agency’s (EPA) FY2027 Evidence Plan outlines the Agency’s priorities for evidence-building, evaluation, and organizational learning in support of its strategic goals. The Evidence Plan identifies key research questions, evaluation activities, and data collection efforts intended to improve agency decision-making, program performance, and operational effectiveness. The Plan serves as EPA’s annual implementation agenda under the Foundations for Evidence-Based Policymaking Act4 and identifies how the Agency intends to generate and use evidence to improve outcomes for the public and the environment.
The EPA Evidence Plan focuses on three priority areas. First, EPA seeks to develop and pilot evidence-based approaches for assessing whether certain high-funded FY2026 grant programs are achieving environmental and public health outcomes while serving as effective stewards of taxpayer resources. To support this effort, the Agency plans to refine performance metrics, strengthen evaluation methodologies, identify data limitations, and pilot new approaches in at least one grant program. Second, EPA aims to identify permitting reforms that could reduce the time, uncertainty, and costs associated with environmental permitting. Building on information collected in FY2026, the Agency will conduct document reviews, interviews with subject matter experts, and internal reviews to determine which permitting improvements merit further exploration, testing, evaluation, or broader implementation. Third, EPA seeks to examine opportunities to expand automation and artificial intelligence within permitting operations by identifying common requirements and existing automated processes across the Electronic Permitting System (EPS) and the National Pollutant Discharge Elimination System (NPDES), with the goal of improving efficiency, consistency, and transparency in permitting workflows.
The Evidence Plan has implications for a wide range of stakeholders. Affected parties include EPA program offices, State and Tribal environmental agencies, regulated industries that rely on environmental permits, grant recipients, and members of the public.The permitting initiatives may be particularly consequential for businesses and infrastructure projects that depend on timely permit approvals, while the grant evaluation efforts could influence future funding priorities and resource allocation decisions. Similarly, the Agency’s exploration of automation and AI may affect how permitting and compliance activities are administered in the future.
The topics selected by EPA suggest potentially significant long-term implications. Improvements in grant effectiveness could influence the allocation of billions of dollars in federal environmental funding, while permitting reforms may affect investment timelines, regulatory certainty, administrative efficiency, and environmental outcomes. Likewise, successful deployment of automation and AI technologies could substantially alter agency operations and reduce administrative burdens across permitting programs. As a result, the Evidence Plan represents an important opportunity to strengthen evidence-based governance and improve both regulatory implementation and program performance across the Agency. However, one area that could benefit from improved valuation methods is regulation.
While the Evidence Plan identifies important evidence-building priorities, several opportunities exist to strengthen the Agency’s approach to evaluation and learning. This commentary focuses on three areas. First, it discusses how EPA can improve grant evaluations by developing stakeholder-informed theories of change and standardized outcome frameworks. Second, it examines how evaluation methods can be more systematically incorporated into permitting reform efforts to assess whether proposed changes actually reduce permitting timelines, costs, and uncertainty while maintaining environmental protections. Third, it considers how EPA can evaluate automation and AI initiatives through clear performance metrics, stakeholder engagement, and ongoing monitoring to ensure these technologies improve administrative effectiveness without creating unintended consequences. The suggestions in each of these areas are also relevant to improving ex-post regulatory evaluation.