七县基础设施联盟诉鹰县案

In 2020, the Seven County Infrastructure Coalition, a group of seven Utah counties, petitioned the Surface Transportation Board (STB) for approval to construct an 88-mile railroad in Utah's Uinta Basin to connect the oil-rich region to the national rail network. The STB prepared a 3,600-page Environmental Impact Statement (EIS) but did not fully analyze the environmental effects of increased upstream oil drilling or downstream refining. Eagle County, Colorado, and environmental groups challenged the STB's approval, and the D.C. Circuit vacated the EIS and approval order, finding NEPA violations. The Supreme Court reversed unanimously (8-0), holding that the D.C. Circuit failed to afford the STB substantial deference and that NEPA does not require agencies to consider environmental effects of separate upstream or downstream projects.

The Supreme Court reversed the D.C. Circuit's decision and remanded the case. The Court held that courts must afford substantial deference to agency decisions regarding the scope of an EIS, and that NEPA does not require analysis of upstream or downstream effects of separate projects distinct in time or place. Justice Kavanaugh delivered the majority opinion, joined by Chief Justice Roberts and Justices Thomas, Alito, and Barrett. Justice Sotomayor filed a concurring opinion, joined by Justices Kagan and Jackson. Justice Gorsuch recused himself. The rail project's authorization remained vacated and was sent back to the D.C. Circuit for further proceedings.

Whether the National Environmental Policy Act (NEPA) requires a federal agency to study environmental impacts beyond the proximate effects of the action over which the agency has regulatory authority—specifically, whether the STB was required to analyze the environmental effects of upstream oil drilling and downstream oil refining resulting from the proposed railway.

The decision significantly narrowed the scope of NEPA environmental reviews, potentially streamlining approvals for energy and infrastructure projects by freeing agencies from analyzing far-off environmental consequences. Critics argue this may result in environmental reviews that fail to capture the full picture of projects' environmental effects. The ruling also reinforced judicial deference to agency decision-making in the post-Chevron era, marking a major "course correction" in NEPA jurisprudence.