Quantifying the Opportunity of Reforming the Federal Communications Commission’s National Environmental Policy Act and National Historical Preservation Act Rules

The National Environmental Policy Act (NEPA) requires federal agencies to consider the reasonably foreseeable environmental impacts of “major federal actions.” The Federal Communications Commission (FCC) incorporated NEPA into its decision-making process by establishing procedures for reviewing such actions, which can include the deployment and modification of communications infrastructure, including towers and other macrocell locations, and small cell sites. With recent statutory and other changes applicable to NEPA, the FCC is considering revising its policies. In addition, the Commission is taking a look at its implementation procedures for the National Historical Preservation Act (NHPA). This related legislation requires that the FCC and other federal agencies consider the effects of federal “undertakings” on historic properties. However, there are no recent data on the costs that wireless providers face when complying with NEPA and NHPA. The objective of this study is to fill this gap and help the FCC to make informed policy decisions that simplify and accelerate the permitting of towers, small cells, and other wireless facilities, as envisioned in its August 14, 2025, Notice of Proposed Rulemaking (NPRM). The study principally uses data and information obtained through surveys and working sessions with major mobile wireless providers. It finds that under the legacy regulatory NEPA and NHPA frameworks, mobile wireless providers would spend over $2.2 billion on regulatory compliance in the next decade alone. Additionally, complying with NEPA and NHPA regulations takes time, causing an estimated five-month delay in deploying new technologies and service upgrades. These rollout delays negatively affect jobs and economic growth, leading to a reduction in overall GDP, job losses, and significant decreases in consumer welfare, such as lower service quality and abandoned projects. The overall economic harm from the current policies amounts to at least $7.5 billion in welfare and economic activity loss over the next ten years. This amount includes the outof-pocket expenses, the welfare loss associated with out-of-pocket expenses, and the welfare loss due to compliance delays. The welfare loss associated with the out-of-pocket expenses equals $4.0 billion and the welfare loss from the compliance delay amounts to $1.3 billion. Reform would promote faster and wider deployment of mobile wireless facilities to the direct benefit of the millions of US consumers.