On May 29, 2025, SCOTUS delivered a unanimous decision in Seven County Infrastructure Coalition v. Eagle County, Colorado.

The project involved a railway linking the Uinta Basin in Utah to the national rail network. The Surface Transportation Board (Board) prepared an EIS under NEPA to analyze the railway’s construction and operation impacts. However, it did not fully consider the potential environmental effects of increased upstream oil drilling or downstream crude oil refining. 

The Board approved the rail line, finding its transportation and economic benefits outweighed environmental impacts. A Colorado county and environmental groups challenged this approval. The D.C. Circuit ruled that the Board violated NEPA by failing to address foreseeable upstream and downstream environmental effects in the EIS.

The Supreme Court reversed the D.C. Circuit’s decision on the basis that the Board was entitled to substantial judicial deference and was only required to address the railway's effects. It did not need to analyze the environmental effects of upstream and downstream projects unrelated in time and place to the new railway.

Key themes emerged in the Supreme Court’s decision:

1. NEPA is governed by the rule of reason.
2. Courts should afford substantial deference to agencies and should not “micromanage” agency choices.
3. NEPA’s focus is on the project at hand. An agency does not necessarily need to assess the environmental effects of a separate project that is separate in time or place.
4. An agency’s jurisdiction limits its review over separate projects outside of its jurisdiction.