The organizer of the
railway construction project applied to the administrative body for approval of
the project. Environmental protection legislation stipulates that in such
cases, an environmental impact assessment of the project must be conducted. The
administrative body carried out the relevant procedure and approved the
project. An environmental protection organization appealed to the court to
invalidate the decision of the administrative body. The court concluded that
the administrative body had not conducted a thorough analysis of the
consequences of this project increasing oil extraction and processing in the
region. However, the US Supreme Court concluded that such a thorough analysis
was not necessary, and that the Court should show greater deference to the
decision of the administrative body, which is a specialist in this matter.
In Seven County Infrastructure Coalition v. Eagle
County, decided on May 29, 2025, the Supreme Court (SCOTUS) limited the scope
of environmental review mandated by the National Environmental Policy Act
(NEPA). Reversing the lower court, the decision stipulated that NEPA cases
require substantial judicial deference, preventing courts from separately
analyzing the environmental impacts of upstream and downstream projects
connected to a proposed project.
Seeking to build an 88-mile railroad in Utah's Uinta
Basin, the Seven County Infrastructure Coalition (Coalition) applied to the
U.S. Surface Transportation Board (Board) for approval, as mandated by federal
law. The proposed railroad aimed to connect Utah to the national freight rail
network, facilitating crude oil transport to the Gulf Coast.
Under the National Environmental Policy Act (NEPA),
the Board was required to prepare an Environmental Impact Statement (EIS)
addressing significant environmental impacts and exploring mitigation
alternatives. The Board finalized a
3,600-page EIS, subsequently approving the railroad project based on its
conclusion that transportation and economic benefits outweighed potential
environmental consequences.
Several environmental groups and a Colorado county
challenged the Board's approval in the U.S. Court of Appeals for the D.C.
Circuit. The D.C. Circuit found the EIS deficient for neglecting to assess
environmental impacts from increased upstream oil drilling and downstream
refining, and therefore vacated the EIS and the project's approval.
The EIS acknowledged potential environmental impacts
from increased oil drilling and refining, but deemed in-depth analysis
unnecessary.
The Supreme Court (SCOTUS) then reviewed the case,
emphasizing that the NEPA is a procedural statute requiring only the preparation
of an EIS, not the imposition of substantive environmental obligations. SCOTUS
criticized overly intrusive judicial reviews of
NEPA cases, advocating for substantial deference to agency choices
within a "broad zone of reasonableness." The Court reasoned that
analyzing environmental effects of upstream drilling was unnecessary because
the railroad project itself wasn't for oil or well drilling, and NEPA only
requires evaluating the proposed project, not separate ones. Similarly,
analyzing downstream refining effects was unnecessary because oil refining
projects rely on other markets and the Board lacks authority over oil
production and refining.