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“America’s AI Action Plan”: Federal Blueprint for Multi-Trillion Dollar Opportunity

“America’s AI Action Plan”: Federal Blueprint for Multi-Trillion Dollar Opportunity

The Plan Proposes Policies to Streamline Regulation and Spur Construction of “American AI Infrastructure”

On July 23, 2025, the White House unveiled Winning the Race: America's AI Action Plan. The Plan outlines a sweeping federal policy for boosting domestic AI development across three pillars: (1) Accelerate AI Innovation, (2) Build American AI Infrastructure, and (3) Lead in International AI Diplomacy and Security.

Technology companies have already announced over $1.5 trillion in planned investments in data centers and hardware manufacturing facilities, according to the Wall Street Journal. As the Plan stimulates further investment around AI technology over the next decade, that figure is projected to rise significantly.

For the construction industry, the “Build American AI Infrastructure” pillar of the Plan represents a multi-trillion-dollar opportunity: accelerating the development of so-called AI infrastructure — data centers, state-of-the-art hardware fabrication facilities, and the energy systems that power them. While the Plan offers grandiose proclamations with Trump-ian flair, its ultimate success will depend on strong interagency and intragovernmental coordination — a challenge even optimistic observers acknowledge.

The Build American AI Infrastructure Pillar

The Build American AI Infrastructure pillar of the Plan is intended to further stimulate surging AI growth through policies that expedite permitting processes, open federal lands for construction of AI infrastructure, produce skilled workers to build these projects, and establish stringent security standards to protect them.

1.  Streamlined Regulations For AI Infrastructure Projects

The Plan's regulatory streamlining policies, titled “Create Streamlined Permitting for Data Centers, Semiconductor Manufacturing Facilities, and Energy Infrastructure while Guaranteeing Security” (Plan, pp. 14-15), include the following:

  • Agencies shall “establish new Categorical Exclusions under NEPA to cover data center-related actions that normally do not have a significant effect on the environment.”
  • The administration will “expand the use of the FAST-41 process to cover all data center and data center energy projects eligible under the Fixing America's Surface Transportation Act of 2015.”
  • Relevant agencies shall “explore the need for a nationwide Clean Water Act Section 404 permit for data centers.”
  • Agencies will “make Federal lands available for data center construction and the construction of power generation infrastructure.”

These directives gained immediate legal force through an Executive Order on Accelerating Federal Permitting of Data Center Infrastructure, signed by President Trump the same day his administration published the Plan.  The Executive Order confers “Qualifying Project” status on any “Data Center Project”1 or “Covered Component Project”2  that satisfies any one of the following four requirements:

  1. Capital Threshold: $500 million or more in committed project expenditures.
  2. Energy Threshold: entails incremental electric load addition of greater than 100MW.
  3. National Security Designation: Projects deemed to protect national security.
  4. Agency Designation: Projects selected by the Secretary of Defense, Secretary of the Interior, Secretary of Commerce, or the Secretary of Energy.

Qualifying Projects receive significant benefits: broad, presumptive NEPA exemptions when federal funding remains below 50% of total costs, programmatic Endangered Species Act consultation pre-clearing 10 years of construction activities, and possible fast-tracking under FAST-41 within 30 days of designation — all potentially reducing years of permitting review to months. The Order even opens environmentally contaminated lands— so-called “Superfund” and “Brownsfield” sites3  — for the development of Qualifying Projects.

2. Development of Energy Infrastructure to Support AI-Related Projects

The “Develop a Grid to Match the Pace of AI Innovation” (Plan, pp. 15-16), the section outlines a three-pronged approach to energy infrastructure:

  1. “Stabilize the grid of today” by preventing “premature decommissioning of critical power generation resources.”
  2. “Optimize existing grid resources” through “advanced grid management technologies and upgrades to power lines.”
  3. “Prioritize the interconnection of reliable, dispatchable power sources” including “enhanced geothermal, nuclear fission, and nuclear fusion.”

These energy directives translate to robust demand for construction of new geothermal facilities, nuclear projects, and massive grid updates.  

3. Labor Force Training and Development Programs to Build AI-Related Projects

The “Train a Skilled Workforce for AI Infrastructure” (Plan, p. 17) section includes directives instructing the Department of Labor and Department of Commerce to:

  • “Create a national initiative to identify high-priority occupations essential to the buildout of AI-related infrastructure.”
  • Support “industry-driven training programs that address workforce needs tied to priority AI infrastructure occupations.”
  • Partner with education and workforce system stakeholders to expand early career exposure programs and expand Registered Apprenticeships for occupations critical to AI-infrastructure.

The Plan specifically identifies “electricians, advanced HVAC technicians, and a host of other high-paying occupations” as critical to AI-infrastructure development. 

4. Security Standards to Protect AI-Related Projects

For government projects, the Plan mandates creation of “new technical standards for high-security AI data centers” (Plan, p. 16) through collaboration between the Department of Defense, Intelligence Community, National Security Council, and the National Institute of Standards and Technology. These requirements apply only to a subset of data center projects but could create a specialized market for contractors with appropriate security credentials.

Impacts and Opportunities

The scope and scale of the Plan suggests that its impact on the construction industry will be seen over a period of 10-years or more, with the opportunities for well-positioned firms compounding over time.

Near Term (1 Year)

In the near term, the implementation of accelerated permitting may compress project timelines: data centers that would previously require 16-24 months of environmental review could qualify for streamlined processing as early as in a year or less.

The Department of Energy could already be in discussions with project owners regarding potential siting access on federal lands.  Hours after the White House released the Plan, the DOE issued an announcement on Site Selection for AI Data Center and Energy Infrastructure Development on Federal Lands, stating that it had “selected four sites — Idaho National Laboratory, Oak Ridge Reservation, Paducah Gaseous Diffusion Plant and Savannah River Site — to move forward with plans to invite private sector partners to develop cutting edge AI data center and energy generation projects.” According to the Department of Energy's announcement, “partners could be selected by the end of the year.”

Medium Term (2 to 3 Years)

Demand for AI infrastructure is expected to see sustained growth. Federal agencies identification of available federal lands will continue on a rolling basis, though implementation may take lag as legal challenges play out.

The Plan’s workforce development initiatives may begin producing additional skilled workers within one to two years.  New security standards will likely be rolled out within a similar timeframe, potentially establishing new baseline requirements for federal data center projects and creating a new market opportunity for construction firms that are proactive in obtaining appropriate credentials.

Long Term (3 to 10 Years+)

The Plans longer-term implications extend beyond regulatory reform. If the Plan is successfully implemented, the AI-infrastructure construction market will shift from project-by-project to a sustained cycle of development – requiring significant upfront investment for supply to keep up with demand. The Plans emphasis on emerging energy technologies — particularly enhanced geothermal and nuclear — means that construction specifications and expertise requirements for Qualifying Projects may evolve significantly as these technologies are adopted at commercial sale. 

Conclusion

The Plan’s Build American AI Infrastructure pillar aims to reduce regulatory barriers and attract sustained investment in high-value AI development projects. Realizing the Plans ambitious vision will depend on cohesive interagency coordination, and only time will tell whether or to what extent state and local governments will stick to the Plan.

However, if the Plan is successful, it promises to unlock a generational opportunity for construction firms agile enough to navigate evolving regulations and adopt integrated delivery models at scale — positioning them to lead in a multi-trillion-dollar development cycle.


1 These include projects that are “dedicated to AI inference, training, simulation, or synthetic data generation”.

2 These projects include energy infrastructure (e.g., transmission lines, pipelines, and nuclear and geothermal power facilities) and hardware production facilities (e.g., semiconductor, networking equipment, and data storage systems).

3 As those terms are as defined under 42 U.S.C. Sections 9604, 9606 or 9620, and Section 9601(39), respectively.

For More Information, Please Contact:

Joe Offenhauser Headshot
Joseph Offenhauser
Associate
San Francisco, CA

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