National Association of Manufacturers Foundation for American Innovation

America
On Hold

How Permitting Delays Stall Manufacturing Progress
A Joint Report with the Foundation for American Innovation
Download the Report Key Findings

The NAM and the Foundation for American Innovation set out to answer a question manufacturers have long borne the brunt of: what does the federal permitting system actually cost the manufacturing sector? Our findings paint a stark picture—billions in direct and indirect costs from federal permitting alone, every single year. To arrive at that number, the study surveyed manufacturers across the country on real out-of-pocket expenses and delay costs across every major federal permit type, modeled those costs against publicly available federal permit volume data, and scaled the results across a decade of permit counts to produce a conservative, sector-wide estimate of the annual burden.

$7.9B+
Annual cost to manufacturers from permitting delays
10mo
Weighted average
approval time
80%
Say permitting complexity
harms investment
Watch

The Case for Permitting Reform

66% of manufacturers would increase U.S. investment with faster, more predictable permitting.

American manufacturers want to produce more here at home and create stronger supply chains, more jobs, and greater economic resilience. But our federal permitting system treats routine industrial upgrades like novel developments, subjects renewals to the same scrutiny as first-time applications, and leaves firms unable to forecast if or when a decision will come.

The result is years of delay and skyrocketing costs that kill investment before it starts.

“Projects that strengthen our energy system can face years of unnecessary delays under the current NEPA framework. Uncertain timelines, duplicative reviews, overly expansive analyses, and lengthy litigation can stall or even cancel critical infrastructure. Modernizing NEPA is a critical step toward providing greater certainty for developers and communities so we can deliver the energy needed to support American jobs, strengthen supply chains, and keep energy affordable for families and businesses.”

— Toby Z. Rice, President & CEO, EQT

“We were the first mining project covered under the federal government’s FAST-41 permitting program in 2024. From start to finish, the process will take just over two years. We have seen the benefits that streamlining and coordinating federal efforts under NEPA provides to projects like Hermosa. When there is a collective will to support a project needed for national security, the resources are put in place to ensure the defined timeline milestones are met with the same, if not more, amount of rigor and efficiency. By responsibly modernizing NEPA in a bipartisan manner, more critical projects can move forward to support communities, provide jobs, and deliver for America.”

— Pat Risner, President, Hermosa Project, South32
NEPA review timelines for Solar and Wind projects showing Environmental Assessment averaging 22 months and full Environmental Impact Statement averaging 53 to 58 months from initiation to Record of Decision
Where the burden falls

The permits manufacturers hit most

Clean Air Act

73%

of projects require an air permit — ranked #1 most burdensome by half of all respondents. Average approval: 10+ months.

Clean Water Act

82%

of facility expansions trigger CWA permits (NPDES, §404, §401). Scope creep and unclear timelines are the primary friction points.

NEPA / ESA / NHPA

4.1yr

Average EIS completion time for manufacturing projects — nearly double the national average. When triggered, these overlay laws compound every other delay.

A practical reform agenda

Eight priorities for Congress and the administration

1
Make routine changes routine againMinor upgrades should face proportional review — not novel-project scrutiny.
2
Make renewals boringUnchanged operations should trigger verification, not full re-permitting.
3
Make timelines predictableStatutory deadlines once an application is complete — no open-ended queues.
4
Reform NEPAExpand categorical exclusions, narrow scope, expedite judicial review.
5
Modernize the Clean Air ActWorkable PM2.5/ozone standards, realistic review cycles, regional credit trading.
6
Streamline the Clean Water ActClarify §401/§404 timelines, scope, and expand use of general permits.
7
Raise the bar for injunctionsProcedural litigation should only halt operations when irreparable harm is imminent.
8
Create durable permit certaintyLegally permitted projects must stay permitted. Limit revocation risk.
Infrastructure and energy grid
Related Campaign

Building to Win

Permitting reform is a cornerstone of NAM’s infrastructure agenda. Our Building to Win campaign unites manufacturers behind the policies needed to modernize America’s infrastructure and strengthen the industrial base.

Learn More

This report is an attempt to bring the permitting conversation back to first principles: how manufacturers really feel about the U.S. permitting system, what laws and permits do manufacturers interact with most, and which permitting roadblocks are most burdensome and what reforms are needed to change real-world investment decisions.