A Model for Estimating the Economic Effects ofChanges in Permitting Requirements Working Paper 2026-10 July 2026 To enhance the transparency of the work of the Congressional Budget Office and to encourage externalreview of that work, CBO’s working paper series includes papers that provide technical descriptions ofofficial CBO analyses as well as papers that represent independent research by CBO analysts. Papers in thisseries are available athttps://tinyurl.com/CBOWorkingPapers. This paper benefited greatly from suggestions and guidance from Dorian Carloni, Nicholas Chase, RonGecan, Evan Herrnstadt, Joseph Kile, Jeffrey Kling, and Heidi Williams. Abstract This paper describes a structural model for estimating how changes in permitting requirementsaffect private investment. The model’s framework is a representative sector composed ofprojects that are identical at the outset and must undergo an uncertain permitting process beforeproduction can begin. Permitting delays and outcomes are governed by idiosyncratic shocks thatgenerate uncertainty in both the probability of a project’s approval and the timing of a project’scompletion. The model’s framework shows how longer or more uncertain permitting processesincrease the user cost of capital and reduce investment, with the elasticity of investment beinggoverned by the demand elasticity for output. The model is calibrated using sectoral data andsolved numerically to evaluate the macroeconomic effects of policy changes that would alterpermitting duration, costs, or approval probabilities. Keywords:investment, regulations, time to build, user cost of capital JEL Classification:D24, E22, Q58, R38 Contents 1.Overview................................................................................................................................. 12.A Model of the Permitting Process......................................................................................... 22.1Distribution of a Project’s Time to Build ....................................................................... 32.2Present Value of Upfront Costs ...................................................................................... 42.3Present Value of Capital Cost ......................................................................................... 62.4Present Value of Total Revenue ..................................................................................... 62.5Project Entry and Investment.......................................................................................... 72.6Aggregation..................................................................................................................... 73.The User Cost of Capital......................................................................................................... 94.Calibration............................................................................................................................. 105.Solution ................................................................................................................................. 126.References Cited ................................................................................................................... 12 1. Overview This working paper describes a model the Congressional Budget Office developed to estimatehow changes in permitting requirements would affect private investment in capital-intensiveprojects.1CBO applied this model as part of its assessment of the expected response of privateinvestment to a permitting provision included in the House-passed version of the 2025reconciliation act. That provision would have allowed project sponsors to pay an “opt-in” fee inexchange for faster processing times for some environmental assessments, which would not havebeen subject to judicial review.2Additional details about that provision and its estimatedbudgetary effects are available in a cost estimate.3 The model focuses on the investment behavior of capital-intensive projects within arepresentative sector. The sector is composed of projects that are identical at the outset (ex ante);they produce a homogeneous commodity (or good) using only capital as an input, anddifferences between projects arise from uncertainty during the permitting process. Each project has a sponsor, and before a project can start earning revenue, its sponsor mustobtain a permit, the process for which lasts an uncertain number of waiting periods and has anuncertain outcome. Each outcome is uncertain because a project can be approved and completedor it can be terminated. The time a project spends in the permitting queue, and the outcome afterwaiting in the queue, are determined by a set of idiosyncratic events, or shocks, that arriveunexpectedly and are exogenous (that is, they originate from external factors). Although projectsponsors know the distribution of shocks and form rational expectations about outcomes, thetime spent waiting and the final outcome o