In a significant ruling that is expected to reshape the landscape of environmental reviews for federal projects, the United States Supreme Court issued its decision in Seven Cty. Infrastructure Coal. v. Eagle Cty. on May 28, 2025. The case centered around the scope of review under the National Environmental Policy Act (NEPA), a landmark environmental law signed into effect in 1970. The Court’s decision has far-reaching implications for how federal agencies conduct environmental impact assessments and how courts review those assessments in the future.
At the heart of the case was a dispute over the construction of an 88-mile railroad line in northeastern Utah, known as the Uinta Basin Railway. The project, proposed by the Seven County Infrastructure Coalition, aimed to connect the Uinta Basin, rich in crude oil, with the interstate rail network, facilitating more efficient transportation of oil to refineries across the country. Before approving the project, the United States Surface Transportation Board (the Board) conducted a NEPA review and published a final Environmental Impact Statement (EIS) that analyzed various adverse environmental impacts, including effects on land use, air quality, wetlands, wildlife, and outdoor recreation.
However, the plaintiffs—comprising a Colorado county and several environmental organizations—argued that the EIS failed to adequately assess the direct, indirect, and cumulative impacts of approving the railroad project. Specifically, they contended that the Board had not fully analyzed the environmental impacts of future oil and gas drilling and crude oil refining that could result from the project’s approval. The D.C. Circuit Court of Appeals initially sided with the plaintiffs, concluding that the Board had not fully examined all the “foreseeable impacts” of the railroad project and overturning the EIS and the Board’s approval.
The Supreme Court’s decision reversed the D.C. Circuit’s ruling, upholding the EIS and the Board’s approval of the Uinta Basin Railway. The Court found that the D.C. Circuit had failed to grant the Board the “substantial judicial deference required in NEPA cases.” Moreover, the Court clarified that NEPA does not require agencies to consider the environmental impacts of “upstream and downstream projects” that are separate in time and place from the proposed action.
The Supreme Court emphasized that NEPA is a purely procedural statute, mandating a process rather than a particular outcome. The Court stated that when reviewing an agency’s EIS, a court’s role is limited to determining whether the agency has analyzed the environmental impacts and reasonable alternatives to the proposed action. The Court noted that agencies must necessarily make choices based on relevant facts, context, and policy when drafting an EIS.
The decision is likely to have significant implications for future NEPA reviews and litigation. By clarifying the scope of review and emphasizing the need for substantial deference to agency decisions, the Supreme Court has provided guidance that will shape how courts handle challenges to NEPA reports going forward. The ruling underscores the procedural nature of NEPA, ensuring that agencies have the discretion to make reasoned judgments about the environmental impacts of their actions without fear of excessive judicial second-guessing.
As the agricultural and energy sectors continue to evolve, the Supreme Court’s decision in Seven Cty. Infrastructure Coal. v. Eagle Cty. will play a crucial role in balancing environmental considerations with the need for infrastructure development. The ruling is expected to streamline the NEPA review process, providing agencies with clearer guidelines and reducing the likelihood of protracted litigation. However, it also raises questions about the extent to which agencies will be held accountable for the broader environmental impacts of their actions, particularly those that occur beyond the immediate scope of their regulatory authority.