Report on the Proposed AI Action Plan and its Implications for the National Environmental Policy Act (NEPA) and Sustainable Development Goals (SDGs)

1.0 Introduction

A recently announced AI Action Plan proposes significant revisions to the National Environmental Policy Act (NEPA) to accelerate the development of artificial intelligence infrastructure, particularly data centers. This report analyzes the proposal’s direct conflict with several United Nations Sustainable Development Goals (SDGs) by prioritizing rapid industrial growth over environmental protection and public participation.

2.0 The Proposed Policy and its Target: NEPA

The AI Action Plan aims to streamline environmental reviews for data centers by granting them “categorical exclusions” from NEPA requirements. This action is intended to remove perceived barriers to development and achieve “maximum efficiency” in permitting.

• National Environmental Policy Act (NEPA): A 55-year-old foundational U.S. law requiring federal agencies to assess and disclose the environmental impacts of proposed projects.
• Public Participation: NEPA provides a critical mechanism for the public to be informed and to comment on projects before approval.
• Proposed Change: The plan seeks to bypass this review process for data centers, which are known for their significant environmental footprint.

3.0 Analysis of Impacts on Sustainable Development Goals (SDGs)

The proposed weakening of NEPA directly challenges the integrated nature of the SDGs, creating a tension between industrial innovation and environmental and social sustainability.

3.1 Conflict with SDG 13 (Climate Action) and SDG 7 (Affordable and Clean Energy)

The plan’s most significant impact is on climate-related goals. Data centers are major energy consumers, and relaxing oversight could exacerbate climate change.

• Undermining Climate Action (SDG 13): NEPA has become an essential tool for requiring agencies to consider a project’s contribution to climate change via greenhouse gas emissions. The administration has already withdrawn guidance on this, and the AI Action Plan would further institutionalize a disregard for climate impacts.
• Jeopardizing Clean Energy (SDG 7): The vast energy requirements of data centers, if fast-tracked without environmental review, could increase reliance on fossil fuels, undermining the transition to affordable and clean energy sources.

3.2 Conflict with SDG 6 (Clean Water) and SDG 12 (Responsible Consumption)

The resource intensity of data centers poses a direct threat to water security and sustainable consumption patterns.

• Threats to Water Resources (SDG 6): Data centers consume vast quantities of water for cooling. Bypassing NEPA reviews removes a key safeguard for assessing and mitigating the impact of this consumption on local water supplies, directly threatening progress on clean water and sanitation.
• Ignoring Responsible Consumption (SDG 12): The plan promotes a model of production that is resource-intensive, running counter to the principles of responsible consumption and production by failing to account for the full environmental cost of energy and water usage.

3.3 Conflict with SDG 11 (Sustainable Communities) and SDG 16 (Peace, Justice, and Strong Institutions)

The proposal undermines the institutional frameworks that empower communities and ensure environmental justice.

• Eroding Community Rights (SDG 11): Data center projects have faced strong opposition in communities due to their environmental impact. NEPA is often the only legal avenue for local governments and stakeholders to voice concerns. Removing this opportunity threatens the development of safe, resilient, and sustainable communities.
• Weakening Strong Institutions (SDG 16): NEPA is described as a “Magna Carta for the environment” and a cornerstone of environmental law. Weakening it represents an erosion of strong, accountable institutions and removes a key tool for ensuring justice and public access to information and decision-making.

3.4 Conflict with SDG 15 (Life on Land)

The broader environmental protections afforded by NEPA are crucial for protecting biodiversity.

• Risk to Ecosystems: NEPA forces a consideration of less harmful alternatives. Historical examples, such as the case involving Douglas fir trees and red alders in Oregon, demonstrate how the NEPA process led to better environmental outcomes and protected interdependent species, directly supporting the goal of protecting life on land.

4.0 Stakeholder Perspectives

The debate over NEPA reform highlights a deep divide between economic interests and environmental stewardship advocates.

1. Government and Business Interests: Proponents of the change, including the White House and the U.S. Chamber of Commerce, argue that NEPA is a “broken permitting system” that causes unreasonable delays and hinders economic development and U.S. leadership in AI.
2. Environmental and Legal Advocates: Groups like Food & Water Watch, the Center for Biological Diversity, and Earthjustice argue that weakening NEPA harms communities, the environment, and the scientific integrity of decision-making. They contend that decisions will be less informed and that sidelining the law could paradoxically lead to more litigation and delays.

5.0 Conclusion

The AI Action Plan’s proposal to exempt data centers from NEPA review prioritizes rapid infrastructure development (an element of SDG 9) at the expense of critical environmental and social safeguards. This approach directly conflicts with the core principles of SDG 13 (Climate Action), SDG 6 (Clean Water), SDG 11 (Sustainable Communities), and SDG 16 (Strong Institutions). By removing requirements for environmental assessment and public input, the plan threatens to lock in unsustainable patterns of energy and water consumption, undermine climate goals, and disempower communities, ultimately hindering progress toward a balanced and sustainable future.

1. Which SDGs are addressed or connected to the issues highlighted in the article?

SDG 6: Clean Water and Sanitation

• The article directly connects the development of data centers to significant resource consumption, stating they demand “vast amounts of… water.” This highlights the tension between technological infrastructure development and the sustainable management of water resources.

SDG 7: Affordable and Clean Energy

• The article notes that data centers require “vast amounts of energy.” It also mentions that the permitting reform debate affects the approval timeline for various development projects, including “clean energy” projects, linking industrial energy needs to the broader energy policy landscape.

SDG 9: Industry, Innovation, and Infrastructure

• The core of the article revolves around a plan to “boost artificial intelligence and data centers” and streamline permitting for “related infrastructure” like roads, bridges, and railways. This directly addresses the goal of building resilient infrastructure and fostering innovation, while questioning the sustainability of the approach.

SDG 13: Climate Action

• The article emphasizes NEPA’s role in “requiring consideration of a project’s possible contributions to climate change.” The debate over weakening the law, specifically the withdrawal of guidance to consider “effects of planet-warming greenhouse gas emissions,” connects directly to integrating climate change measures into national policies and planning.

SDG 15: Life on Land

• The article discusses NEPA’s function in protecting ecosystems. It provides examples of its application in forestry (replanting Douglas fir trees, protecting red alders from herbicides), species protection (Endangered Species Act), and habitat restoration (“aspen restoration on Monroe Mountain in Utah”). Weakening NEPA is presented as a threat to these protections.

SDG 16: Peace, Justice, and Strong Institutions

• The article frames the National Environmental Policy Act (NEPA) as a “bedrock law” and “our Magna Carta for the environment.” The law’s process, which “allows the public to be heard” and gives “communities and impacted stakeholders… to weigh in,” is central to the discussion. The conflict over strengthening or weakening NEPA is a direct reflection of the challenge of building effective, accountable, and inclusive institutions for environmental governance.

2. What specific targets under those SDGs can be identified based on the article’s content?

SDG 6: Clean Water and Sanitation

• Target 6.4: By 2030, substantially increase water-use efficiency across all sectors and ensure sustainable withdrawals and supply of freshwater to address water scarcity. The article’s mention of data centers demanding “vast amounts of… water” directly relates to the need for water-use efficiency in the technology industry.

SDG 7: Affordable and Clean Energy

• Target 7.2: By 2030, increase substantially the share of renewable energy in the global energy mix. The article notes that permitting reform, which is at the center of the debate, can delay “clean energy” projects, thus impacting the ability to increase the share of renewables.

SDG 9: Industry, Innovation, and Infrastructure

• Target 9.1: Develop quality, reliable, sustainable and resilient infrastructure… to support economic development and human well-being. The article discusses building infrastructure (data centers, railways) but questions its sustainability by highlighting the push to bypass environmental reviews.
• Target 9.4: By 2030, upgrade infrastructure and retrofit industries to make them sustainable… with all countries taking action in accordance with their respective capabilities. The debate over NEPA is about whether new infrastructure, like data centers, will be developed sustainably by considering environmental impacts or by prioritizing “maximum efficiency” in permitting.

SDG 13: Climate Action

• Target 13.2: Integrate climate change measures into national policies, strategies and planning. The article explicitly discusses the role of NEPA in this integration, citing the former requirement for agencies to “consider the effects of planet-warming greenhouse gas emissions when conducting NEPA reviews,” a practice that is now being rolled back.

SDG 15: Life on Land

• Target 15.1: By 2020, ensure the conservation, restoration and sustainable use of terrestrial and inland freshwater ecosystems and their services. The article’s examples of NEPA’s use in forest management and aspen restoration directly align with this target.
• Target 15.5: Take urgent and significant action to reduce the degradation of natural habitats. The core function of NEPA, as described, is to study and mitigate the environmental impacts of projects, thereby preventing habitat degradation. Weakening the act is presented as a threat to this goal.

SDG 16: Peace, Justice, and Strong Institutions

• Target 16.6: Develop effective, accountable and transparent institutions at all levels. NEPA is presented as an institutional mechanism for accountability and transparency in federal projects. The debate is about the effectiveness and nature of this institution.
• Target 16.7: Ensure responsive, inclusive, participatory and representative decision-making at all levels. The article highlights that NEPA “allows the public to be heard” and provides an “opportunity for communities and impacted stakeholders… to weigh in,” which are key elements of participatory decision-making.
• Target 16.10: Ensure public access to information and protect fundamental freedoms. NEPA’s requirement for environmental impact statements and public comment periods is a direct mechanism for ensuring public access to information about potential environmental harm.

3. Are there any indicators mentioned or implied in the article that can be used to measure progress towards the identified targets?

SDG 6 & 7: Clean Water and Energy

• Implied Indicator: Volume of water and energy consumed by data centers. The article refers to “vast amounts of energy and water,” implying that the quantity of these resources used by the industry is a key metric for assessing its sustainability.

SDG 9: Industry, Innovation, and Infrastructure

• Implied Indicator: Length of the permitting process for infrastructure projects. The article mentions that projects “often take five years or more to complete” as a criticism of NEPA, suggesting that the duration of environmental reviews is used as a measure of efficiency.

SDG 13: Climate Action

• Mentioned Indicator: Inclusion of greenhouse gas emissions in environmental reviews. The article explicitly mentions the withdrawal of “guidance that federal agencies should consider the effects of planet-warming greenhouse gas emissions when conducting NEPA reviews.” Whether this consideration is mandatory or not serves as a direct indicator of climate action integration in policy.

SDG 15: Life on Land

• Mentioned Indicator: Requirement to conduct and write an environmental impact statement. The article discusses how a court required an agency to “redo their analysis and they ultimately had to write a new environmental impact statement,” indicating that the existence and thoroughness of these statements are a measure of environmental protection.

SDG 16: Peace, Justice, and Strong Institutions

• Mentioned Indicator: Existence of laws and procedures for public participation. The article centers on NEPA, a law that “allows the public to be heard” and provides an “opportunity for communities… to weigh in.” The strength and enforcement of such laws are indicators of participatory governance.
• Implied Indicator: Number of projects granted “categorical exclusions” from environmental reviews. The plan to give such exclusions to data centers implies that the frequency of these exemptions can be tracked as an indicator of reduced public oversight and transparency.

4. SDGs, Targets and Indicators Table

Source: abcnews.go.com