Common Permitting Risks — Avoiding Project Delays

These are the most frequent weaknesses in draft permit documents that trigger agency delays and legal challenges on energy and infrastructure projects.

Top Permitting Risks

• Inadequate alternatives analysis: CEQ regulations require a rigorous range of alternatives. Thin alternatives sections are the #1 target in NEPA litigation.
• Mitigation gaps: Proposed mitigation measures that are vague, unenforceable, or inconsistent with agency guidance.
• Cumulative impact analysis omissions: Failing to account for nearby projects or regional environmental stressors.
• Environmental Justice omissions: EJ analysis is increasingly scrutinized — omissions trigger agency supplemental review requests.
• Cross-agency coordination failures: When NEPA lead agency and cooperating agencies (USACE, USFWS, EPA) have conflicting requirements not reconciled in the document.
• Biological assessment inconsistencies: Species habitat descriptions that contradict project impact zones.

Permica detects these risks in minutes. Contact: [email protected]