Seven County Infrastructure Coalition v. Eagle County

P R E L I M I N A R Y P R I N T
Volume 605 U. S. Part 1
Pages 168–203
OFFICIAL REPORTS
OF
T H E S U P R E M E C O U R T
May 29, 2025
REBECCA A. WOMELDORF
reporter of decisions
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the bound volume is published. Users are requested to notify the Reporter
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pio@supremecourt.gov, of any typographical or other formal errors.

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168 OCTOBER
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Syllabus
SEVEN COUNTY INFRASTRUCTURE COALITION
et
al. v. EAGLE COUNTY, COLORADO, et al.
certiorari to the united states court of appeals for
the district of columbia circuit
No. 23–975. Argued December 10, 2024—Decided May 29, 2025
Under federal law, new railroad construction and operation must frst
be approved by the U. S. Surface Transportation Board. 49 U. S. C.
§ 10901. In 2020, the Seven County Infrastructure Coalition applied to
the Board for approval of an 88-mile railroad line connecting Utah's oil-
rich Uinta Basin to the national freight rail network, facilitating the
transportation of crude oil to refneries along the Gulf Coast. As part
of its project review, the Board prepared an environmental impact state-
ment (EIS) that addressed signifcant environmental effects of the proj-
ect and identifed feasible alternatives that could mitigate those effects,
as required by the National Environmental Policy Act (NEPA). The
Board issued a draft EIS and invited public comment. After holding
six public meetings and collecting more than 1,900 comments, the Board
prepared a 3,600-page EIS that analyzed numerous impacts of the rail-
way's construction and operation. Relevant here, the EIS noted, but
did not fully analyze, the potential environmental effects of increased
upstream oil drilling in the Uinta Basin and increased downstream re-
fning of crude oil. The Board subsequently approved the railroad line,
concluding that the project's transportation and economic benefts out-
weighed its environmental impacts. Petitions challenging the Board's
action were fled in the D. C. Circuit by a Colorado county and several
environmental organizations. The D. C. Circuit found “numerous
NEPA violations arising from the EIS.” 82 F. 4th 1152, 1196. Spe-
cifcally, the D. C. Circuit held that the Board impermissibly limited
its analysis of the environmental effects from upstream oil drilling and
downstream oil refning projects, concluding that those effects were rea-
sonably foreseeable impacts that the EIS should have analyzed more
extensively. Based on the defciencies it found in the EIS, the D. C.
Circuit vacated both the EIS and the Board's fnal approval order.
Held: The D. C. Circuit failed to afford the Board the substantial judicial
deference required in NEPA cases and incorrectly interpreted NEPA
to require the Board to consider the environmental effects of upstream
and downstream projects that are separate in time or place from the
Uinta Basin Railway. Pp. 177–192.

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169
Syllabus
(a) NEPA ensures that agencies and the public are aware of the envi-
ronment
al consequences of certain proposed infrastructure projects.
As a purely procedural statute, NEPA “does not mandate particular
results, but simply prescribes the necessary process” for an agency's
environmental review of a project. Robertson v. Methow Valley Citi-
zens Council, 490 U. S. 332, 350. Some federal courts reviewing NEPA
cases have assumed an aggressive role in policing agency compliance
with NEPA, and have not applied NEPA with the judicial deference
demanded by the statutory text and the Court's cases.
When, as here, a party argues that an agency action was arbitrary
and capricious due to a defciency in an EIS, the “only role for a court”
is to confrm that the agency has addressed environmental consequences
and feasible alternatives as to the relevant project. Strycker's Bay
Neighborhood Council, Inc. v. Karlen, 444 U. S. 223, 227. Further, the
adequacy of an EIS is relevant only to the question of whether an
agency's fnal decision (here, to approve the railroad project) was rea-
sonably explained.
Judicial deference in NEPA cases extends to an agency's determina-
tion of what details are relevant in an EIS. While NEPA requires an
EIS to be “detailed,” 42 U. S. C. § 4332(2)(C), and the meaning of “de-
tailed” is a legal question, see Loper Bright Enterprises v. Raimondo,
603 U. S. 369, 391–392, what details need to be included in any given
EIS is a factual determination for the agency. The textual focus of
NEPA is the “proposed action”—the project at hand—not other sepa-
rate projects. § 4332(2)(C). Courts should defer to agencies' discre-
tionary decisions about where to draw the line when considering indi-
rect environmental effects and whether to analyze effects from other
projects separate in time or place. See Department of Transportation
v. Public Citizen, 541 U. S. 752, 767. In sum, when assessing signifcant
environmental effects and feasible alternatives for purposes of NEPA,
an agency will invariably make a series of fact-dependent, context-
specifc, and policy-laden choices about the depth and breadth of its in-
quiry—and also about the length, content, and level of detail of the re-
sulting EIS. Courts should afford substantial deference and should not
micromanage those agency choices so long as they fall within a broad
zone of reasonableness. Even a defcient EIS does not necessarily re-
quire vacating an agency's project approval, absent reason to believe
that the agency might disapprove the project if it added more to the
EIS. Cf. 5 U. S. C. § 706. Pp. 177–185.
(b) Contrary to the D. C. Circuit's NEPA analysis, the Board's deter-
mination that its EIS need not evaluate possible environmental effects
from upstream and downstream projects separate from the Uinta Basin

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VEN COUNTY INFRASTRUCTURE COALITION v.
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Syllabus
Railway complied with NEPA's procedural requirements, particularly
NEP
A's textually mandated focus on the “proposed action” under
agency review. While indirect environmental effects of the project it-
self may fall within NEPA's scope even if they might extend outside the
geographical territory of the project or materialize later in time, the
fact that the project might foreseeably lead to the construction or in-
creased use of a separate project does not mean the agency must con-
sider that separate project's environmental effects. See Public Citi-
zen, 541 U. S., at 767. This is particularly true where, as here, those
separate projec ts fa l l outside the agency's reg u latory author ity.
Pp. 186–191.
(c) NEPA does not allow courts, “under the guise of judicial re-
view” of agency compliance with NEPA, to delay or block agency
projects based on the environmental effects of other projects separate
from the project at hand. Vermont Yankee Nuclear Power Corp.
v. Na tura l Reso urces De fen se Co unc i l, Inc., 435 U. S. 519, 558.
P. 192.
82 F. 4th 1152, reversed and remanded.
Kavanaugh, J., delivered the opinion of the Court, in which Roberts,
C. J., and Thomas, Alito, and Barrett, JJ., joined. Sotomayor, J., fled
an opinion concurring in the judgment, in which Kagan and Jackson, JJ.,
joined, post, p. 192. Gorsuch, J., took no part in the consideration or
decision of the case.
Paul D. Clement argued the cause for petitioners. With
him on the briefs were Matthew D. Rowen, Kevin Wynosky,
Jay C. Johnson, and Fred R. Wagner.
Deputy Solicitor General Kneedler argued the cause for
federal respondents urging reversal in part. With him on
the briefs were Solicitor General Prelogar, Assistant Attor-
ney General Kim, Colleen E. Roh Sinzdak, Robert J. Lund-
man, Justin D. Heminger, Anika Sanders Cooper, and Bar-
bara Miller.
William M. Jay argued the cause for respondent Eagle
County et al. With him on the brief were Jordan Bock,
Nathaniel H. Hunt, Beth Oliver, and Christina Hooper.
Kirti Datla fled a brief for environmental respondents.
With her on the brief were Benjamin Chagno n, Linnet

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171
Counsel
Davis-Stermitz, Eric Glitzenstein, Wendy Park, and Ed-
w
ard B. Zukoski.*
*Briefs of amici curiae urging reversal were fled for the State of Loui-
siana et al. by Elizabeth B. Murrill, Attorney General of Louisiana, J.
Benjamin Aguiñaga, Solicitor General, Kelsey L. Smith, Deputy Solicitor
General, and Caitlin A. Huettemann, Assistant Solicitor General, and by
the Attorneys General for their respective States as follows: Steve Mar-
shall of Alabama, Treg Taylor of Alaska, Tim Griffn of Arkansas, Ashley
Moody of Florida, Christopher M. Carr of Georgia, Raúl R. Labrador of
Idaho, Theodore E. Rokita of Indiana, Brenna Bird of Iowa, Russell Cole-
man of Kentucky, Lynn Fitch of Mississippi, Andrew Bailey of Missouri,
Austin Knudsen of Montana, Michael T. Hilgers of Nebraska, Drew H.
Wrigley of North Dakota, Dave Yost of Ohio, Gentner Drummond of Okla-
homa, Alan Wilson of South Carolina, Marty Jackley of South Dakota,
Jonathan Skrmetti of Tennessee, Ken Paxton of Texas, Jason Miyares of
Virginia, Patrick Morrisey of West Virginia, and Bridget Hill of Wyo-
ming; for the State of Utah by Sean D. Reyes, Attorney General of Utah,
and Stan ford E. Purser, Solicitor General; for the American Exploration
and Mining Association et al. by Michael R. Huston, Christopher D.
Thomas, and Andrea J. Driggs; for the American Forest Resource Council
et al. by Ivan L. London; for the Americans for Prosperity Foundation
et al. by Michael Pepson and Dan Greenberg; for the Association of Amer-
ican Railroads by Daniel Saphire; for the Center for American Liberty by
Harmeet K. Dhillon; for the Center for Environmental Accountability by
Paul E. Salamanca; for the Chamber of Commerce of the United States of
America et al. by Kyle D. Hawkins, Michael B. Schon, Andrew R. Varcoe,
Stephanie A. Maloney, Ellen Steen, and Travis Cushman; for Energy
Transfer LP by William S. Scherman and Matthew X. Etchemendy; for
Law Professors by Mario A. Loyola and Richard A. Epstein; for the
NACCO Natural Resources Corp. by Charles T. Wehland and Jeffery D.
Ubersax; for NextDecade LNG, LLC, by Richard M. Loeb and Andrew D.
Silverman; and for U. S. Sen. John Barrasso et al. by Michael Busch-
bacher. Jeffrey S. Rasmussen fled a brief for the Ute Indian Tribe of
the Uintah and Ouray Reservation et al. urging vacatur.
Briefs of amici curiae urging affrmance were fled for the State of
Colorado et al. by Philip J. Weiser, Attorney General of Colorado, Natalie
Hanlon Leh, Chief Deputy Attorney General, Shannon W. Stevenson, So-
licitor General, Kurtis T. Morrison and Scott Steinbrecher, Deputy Attor-
neys General, Carrie Noteboom, Assistant Deputy Attorney General,
Cory Haller, Assistant Solicitor General, and Brea Hinricks, Assistant

172 SE
VEN COUNTY INFRASTRUCTURE COALITION v.
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Opinion of the Court
Justice Kavanaugh delivered the opinion of the Court.
Some
55 years ago, Congress passed and President Nixon
signed the National Environmental Policy Act, known as
NEPA. For certain infrastructure projects that are built,
funded, or approved by the Federal Government, NEPA re-
quires federal agencies to prepare an environmental impact
statement, or EIS. The EIS must address the signifcant
environmental effects of a proposed project and identify fea-
sible alternatives that could mitigate those effects.
NEPA was the frst of several landmark environmental
laws enacted by Congress in the 1970s. Subsequent stat-
utes included the Clean Air Amendments of 1970, the Clean
Water Act of 1972, and the Endangered Species Act of 1973,
among others.
Attorney General, by Brian Schwalb, Attorney General of the District of
Columbia, and by the Attorneys General for their respective States as
follows: William Tong of Connecticut, Kathy Jennings of Delaware,
Kwame Raoul of Illinois, Aaron M. Frey of Maine, Andrea Joy Campbell
of Massachusetts, Dana Nessel of Michigan, Keith Ellison of Minnesota,
Aaron D. Ford of Nevada, Matthew J. Platkin of New Jersey, Letitia
James of New York, Ellen Rosenblum of Oregon, Peter Neronha of Rhode
Island, Charity R. Clark of Vermont, and Robert W. Ferguson of Washing-
ton; for Colorado Communities by William S. Eubanks II, Matthew R.
Arnold, and Barbara Green; for the Constitutional Accountability Center
by Elizabeth B. Wydra and Brianne J. Gorod; for Former Council on Envi-
ronmental Quality Offcials by Sean H. Donahue, Megan M. Herzog, Keri
R. Davidson, and David T. Goldberg; for the Howard University School of
Law Civil Rights Clinic by Amit Jain; for the Institute for Policy Integ-
rity at New York University School of Law by Jason A. Schwartz; and for
30 Members of the U. S. House and Senate by Xiao Wang and Cale Jaffe.
Briefs of amici curiae were fled for the American Petroleum Institute
et al. by Hadassah M. Reimer, Sarah Bordelon, and Tina R. Van Bockern;
for the American Planning Association by John M. Baker and Katherine
M. Swenson; for the Anschutz Exploration Corp. by Tina R. Van Bockern
and Mark D. Gibson; for Former Senior Federal Offcials by Beth C. Neit-
zel; for the Interstate Natural Gas Association of America et al. by Donald
P. Salzman and James P. Danly; and for the Property and Environment
Research Center by Jonathan Wood.
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173
Opinion of the Court
Unlike those later-enacted laws, however, NEPA imposes
no
substantive environmental obligations or restrictions.
NEPA is a purely procedural statute that, as relevant here,
simply requires an agency to prepare an EIS—in essence, a
report. Importantly, NEPA does not require the agency to
weigh environmental consequences in any particular way.
Rather, an agency may weigh environmental consequences
as the agency reasonably sees ft under its governing statute
and any relevant substantive environmental laws.
Simply stated, NEPA is a procedural cross-check, not a
substantive roadblock. The goal of the law is to inform
agency decisionmaking, not to paralyze it.
In this case, the U. S. Surface Transportation Board con-
sidered a proposal by a group of seven Utah counties for
the construction and operation of an approximately 88-mile
railroad line in northeastern Utah. Under federal law, the
Board determines whether to approve construction of new
railroad lines. The railroad line here would connect Utah's
oil-rich Uinta Basin—a rural territory roughly the size of
the State of Maryland—to the national rail network. By
doing so, the new railroad line would facilitate the transpor-
tation of crude oil from Utah to refneries in Louisiana,
Texas, and elsewhere. And the project would bring signif-
cant economic development and jobs to the isolated Uinta
Basi n by better connec ti ng the Basi n to the nati ona l
economy.
For that proposed 88-mile Utah railroad line, the Board
prepared an extraordinarily lengthy EIS, spanning more
than 3,600 pages of environmental analysis. The Board's
EIS addressed the environmental effects of the railroad line.
But the U. S. Court of Appeals for the D. C. Circuit nonethe-
less faulted the EIS for not suffciently considering the envi-
ronmental effects of projects separate from the railroad line
itself—primarily, the environmental effects that could ensue
from (i) increased oil drilling upstream in the Uinta Basin

174 SE
VEN COUNTY INFRASTRUCTURE COALITION v.
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Opinion of the Court
and (ii) increased oil refning downstream along the Gulf
Coast
of Louisiana and Texas.
On that basis, the D. C. Circuit vacated the Board's EIS
and the Board's approval of the 88-mile railroad line. As a
result, construction still has not begun even though the
Board approved the project back in December 2021.
We reverse. First, the D. C. Circuit did not afford the
Board the substantial judicial deference required in NEPA
cases. Second, the D. C. Circuit ordered the Board to ad-
dress the environmental effects of projects separate in time
or place from the construction and operation of the railroad
line. But NEPA requires agencies to focus on the environ-
mental effects of the project at issue. Under NEPA, the
Board's EIS did not need to address the environmental ef-
fects of upstream oil drilling or downstream oil refning.
Rather, it needed to address only the effects of the 88-mile
railroad line. And the Board's EIS did so.
I
Under federal law, new railroad construction and opera-
tion must frst be approved by the U. S. Surface Transporta-
tion Board. 49 U. S. C. § 10901. After receiving an applica-
tion for a new railroad line, the Board issues a public notice
and initiates an agency proceeding to review the proposal;
alternatively, the Board may streamline approval through a
statutory exemption process. §§ 10101, 10502, 10901. In
addition, for covered projects, NEPA compels the Board to
prepare an environmental impact statement, or EIS.
In 2020, the Seven County Infrastructure Coalition—a
group of seven Utah counties—applied to the Board for ap-
proval of an 88-mile railroad line in northeastern Utah. The
new railroad line would connect the Uinta Basin with the
interstate freight rail network—and via that network, to re-
fneries in Louisiana, Texas, and other destinations.
The Uinta Basin contains signifcant quantities of crude
oil and other fossil fuels. The Uinta Basin Railway would
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Opinion of the Court
provide oil producers a more effcient option for transporting
oi
l out of the Basin to refneries. As of now, oil from the
Basin is carried by trucks that must navigate mountain
passes on narrow roads, a diffcult and slow journey in any
season.
The Board's environmental review of the Uinta Basin Rail-
way followed standard NEPA procedures. In October 2020,
the Board issued a draft EIS and invited public comment.
During the public comment period, the Board held six public
meetings and collected more than 1,900 comments. In Au-
gust 2021, the Board published its fnal EIS.
All told, the Board's fnal EIS clocked in at more than 3,600
pages. The EIS identifed and analyzed numerous “signif-
cant and adverse impacts that could occur as a result” of the
railroad line's construction and operation—including disrup-
tions to local wetlands, land use, and recreation. App. 121;
see id., at 94–105, 121–126, 206–347. The EIS likewise ad-
dressed several “minor impacts,” such as air pollution and
big-game movement around the construction site. Id., at
126; see id., at 126–134, 251–259, 309–325.
The EIS also noted, but did not fully analyze, the potential
effects of increased upstream oil drilling in the Uinta Basin
and increased downstream refning of crude oil carried
by the railroad. Id., at 135, 348–482, 511–516, 520–534,
539–543.
As to the environmental effects of upstream oil drilling,
the EIS explained why further analysis of those “potential
future, as yet unplanned, oil and gas development projects”
was not needed. Id., at 520. To begin with, the project at
issue was an 88-mile railroad line, not an oil well or a drilling
permit in the Uinta Basin. Moreover, the Board possesses
“no authority or control over potential future oil and gas de-
velopment” in the Basin. Id., at 522. Future projects
would be “subject to the approval processes of other federal,
state, local, and tribal agencies.” Ibid. In any event, the
environmental effects of future oil and gas development in
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Opinion of the Court
the Basin are “speculative” and attenuated from the project
at
hand. Id., at 525; see id., at 525–527 (citing Department
of Transportation v. Public Citizen, 541 U. S. 752, 767–768,
770 (2004)).
As for the environmental effects of downstream oil refn-
ing projects, the Board recognized that “trains originating
on the proposed rail line would transport crude oil to mar-
kets in other regions of the United States,” such as Louisiana
and Texas, and that oil refning (and the associated effects
on the environment) could increase in those locations as a
result. App. 477; see id., at 477–482. But the identity of
specifc destinations “would depend on the ability and will-
ingness of refneries in other markets to receive rail cars
carrying Uinta Basin crude oil and process the oil in their
refneries.” Id., at 477. Moreover, the Board “would have
no role in approving or regulating the production, refning,
or use” of Uinta Basin crude oil. Id., at 540–541. So the
Board did not fully evaluate the effects of additional oil re-
fning along the Gulf Coast.
In December 2021, a few months after issuing the fnal
EIS, the Board approved the construction and operation of
the Uinta Basin Railway. Recognizing that “rail construc-
tion projects are in the public interest,” the Board concluded
that the new railroad line would “have substantial transpor-
tation and economic benefts,” and that those benefts out-
weighed the environmental impacts identifed in the EIS.
App. to Pet. for Cert. 121a, 119a; see id., at 118a–121a.
In the wake of the Board's fnal approval, a Colorado
county and several environmental organizations sued by fl-
ing petitions for review in the U. S. Court of Appeals for the
D. C. Circuit.
The D. C. Circuit found “numerous NEPA violations aris-
ing from the EIS.” Eagle Cty. v. Surface Transp. Bd., 82
F. 4th 1152, 1196 (2023). In the court's view, the Board
“failed” to take “the requisite `hard look' at all of the envi-
ronmental impacts of the Railway.” Id., at 1175.
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Opinion of the Court
Specifcally, the Court of Appeals held that the Board im-
per
missibly limited its analysis of upstream and downstream
projects. The court concluded that the environmental ef-
fects from oil drilling in the Uinta Basin and oil refning
along the Gulf Coast were “ `reasonably foreseeable im-
pacts' ” that the EIS should have analyzed more extensively.
Id., at 1177. The court rejected the Board's argument that
those effects would arise from other projects (upstream oil
drilling, downstream oil refning, and the like) that are sepa-
rate from the current project and regulated by other agen-
cies. Id., at 1177–1180 (citing Sierra Club v. FERC, 867
F. 3d 1357, 1372–1375 (CADC 2017) (Sabal Trail)).
Based on the defciencies it found in the EIS, the Court of
Appeals vacated the EIS and the Board's fnal approval
order. 82 F. 4th, at 1196. The Coalition and the Uinta
Basin Railway sought review in this Court, and we granted
certiorari. 602 U. S. 1038 (2024).
II
For certain infrastructure projects that are built, funded,
or approved by the Federal Government, NEPA requires
federal agencies to prepare an environmental impact state-
ment, or EIS, identifying signifcant environmental effects of
the projects, as well as feasible alternatives. The law en-
sures that the agency and the public are aware of the envi-
ronmental consequences of proposed projects. Properly ap-
plied, NEPA helps agencies to make better decisions and to
ensure good project management.
Importantly, however, NEPA is purely procedural. In ul-
timately deciding whether to build, fund, or approve a proj-
ect, an “agency is not constrained by NEPA from deciding
that other values outweigh the environmental costs.” Rob-
ertson v. Methow Valley Citizens Council, 490 U. S. 332, 350
(1989). Otherwise stated, NEPA “does not mandate partic-
ular results, but simply prescribes the necessary process” for
an agency's environmental review of a project. Ibid.; see
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Opinion of the Court
Department of Transportation v. Public Citizen, 541 U. S.
752,
756–757 (2004); Marsh v. Oregon Natural Resources
Council, 490 U. S. 360, 370–372 (1989); Baltimore Gas &
Elec. Co. v. Natural Resources Defense Council, Inc., 462
U. S. 87, 97–98 (1983); Strycker's Bay Neighborhood Council,
Inc. v. Karlen, 444 U. S. 223, 227–228 (1980); Vermont Yankee
Nuclear Power Corp. v. Natural Resources Defense Council,
Inc., 435 U. S. 519, 558 (1978); Kleppe v. Sierra Club, 427
U. S. 390, 410, n. 21 (1976).
1
Here, the Board's EIS evaluated the environmental effects
of the proposed 88-mile railroad line in Utah's rural Uinta
Basin. But the D. C. Circuit, following Circuit precedent
applying NEPA, concluded that the EIS did not suffciently
address the reasonably foreseeable environmental impacts of
increased upstream oil drilling in the Uinta Basin, as well as
the environmental effects of increased downstream oil refn-
ing along the Gulf Coast. 82 F. 4th, at 1196.
1
As it was phrased at the time of the Board's EIS (before a 2023 amend-
ment to the statute, see n. 3, in fra), NEPA directed federal agencies to
“include in every recommendation or report on proposals for legisla-
tion and other major Federal actions signifcantly affecting the quality
of the human environment, a detailed statement by the responsible off-
cial on—
“(i) the environmental impact of the proposed action,
“(ii) any adverse environmental effects which cannot be avoided
should the proposal be implemented,
“(iii) alternatives to the proposed action,
“(iv) the relationship between local short-term uses of man's environ-
ment and the maintenance and enhancement of long-term productivity,
and
“(v) any irreversible and irretrievable commitments of resources
wh ich wou ld be i nvolved i n the proposed ac ti on shou ld it be
implemented.
“Prior to making any detailed statement, the responsible Federal offcial
shall consult with and obtain the comments of any Federal agency which
has jurisdiction by law or special expertise with respect to any environ-
mental impact involved.” § 102(2)(C), 83 Stat. 853, as amended, 42
U. S. C. § 4332(2)(C) (2018).
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Opinion of the Court
As we will explain, we disagree with the D. C. Circuit's
decisi
on on two grounds. First, the court did not afford the
Board the substantial judicial deference required in NEPA
cases. Second, the court incorrectly interpreted NEPA to
require the Board to consider the environmental effects of
upstream and downstream projects that are separate in time
or place from the Uinta Basin Railway.
A
Since the early 1970s, federal courts have reviewed NEPA
cases. Over time, some courts have assumed an aggressive
role in policing agency compliance with NEPA. Other
courts have adopted a more restrained approach. In light
of the continuing confusion and disagreement in the Courts
of Appeals over how to handle NEPA cases, we think it im-
portant to reiterate and clarify the fundamental principles of
judicial review applicable in those cases. As we will ex-
plain, the central principle of judicial review in NEPA cases
is deference.
2
As a general matter, when an agency interprets a statute,
judicial review of the agency's interpretation is de novo.
See Loper Bright Enterprises v. Raimondo, 603 U. S. 369,
391–392 (2024). But when an agency exercises discretion
granted by a statute, judicial review is typically conducted
2
Some have debated whether Congress and the President in 1970 actu-
ally intended or anticipated judicial review of agency compliance with
NEPA. See R. Lazarus, The National Environmental Policy Act in the
U. S. Supreme Court: A Reappraisal and a Peek Behind the Curtains, 100
Geo. L. J. 1507, 1515 (2012) (describing the history). In any event, an
early D. C. Circuit case concluded that an agency's compliance with NEPA
was judicially reviewable. See Calvert Cliffs' Coordinating Comm., Inc.
v. U. S. Atomic Energy Comm'n, 449 F. 2d 1109 (1971). And this Court's
cases have treated NEPA compliance as judicially reviewable. That said,
courts must conduct their review with signifcant deference to the agency.
When reviewing compliance with NEPA, “courts are to play only a limited
role.” Vermont Yankee Nuclear Power Corp. v. Natural Resources De-
fense Council, Inc., 435 U. S. 519, 558 (1978).
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Opinion of the Court
under the Admi nistrative Procedure Ac t's deferentia l
arbitrary-and-capr
icious standard. Under that standard, a
court asks not whether it agrees with the agency decision,
but rather only whether the agency action was reasonable
and reasonably explained. See Motor Vehicle Mfrs. Assn.
of United States, Inc. v. State Farm Mut. Automobile Ins.
Co., 463 U. S. 29, 43 (1983); FCC v. Prometheus Radio Proj-
ect, 592 U. S. 414, 423 (2021).
When a party argues that an agency action was arbitrary
and capricious due to a defciency in an EIS, the reviewing
court must account for the fact that NEPA is a purely proce-
dural statute. Under NEPA, an agency's only obligation is
to prepare an adequate report. “NEPA requires no more.”
Strycker's Bay Neighborhood Council, 444 U. S., at 228.
Unlike a plethora of other federal environmental statutes
(such as the Clean Air Act, the Clean Water Act, etc.), NEPA
imposes no substantive constraints on the agency's ultimate
decision to build, fund, or approve a proposed project. So
when reviewing an agency's EIS, “the only role for a court”
is to confrm that the agency has addressed environmental
consequences and feasible alternatives as to the relevant
project. Id., at 227; see Vermont Yankee, 435 U. S., at 551,
555. Because an EIS is only one input into an agency's deci-
sion and does not itself require any particular substantive
outcome, the adequacy of an EIS is relevant only to the ques-
tion of whether an agency's fnal decision (here, to approve
the railroad) was reasonably explained.
In short, when determining whether an agency's EIS com-
plied with NEPA, a court should afford substantial deference
to the agency.
In practice, judicial deference in NEPA cases can take sev-
eral forms. For example, NEPA says that the EIS should
be “detailed.” 42 U. S. C. § 4332(2)(C). Of course, the
meaning of “detailed” is a question of law to be decided by a
court. Loper Bright, 603 U. S., at 391–392. But what de-
tails need to be included in any given EIS? For the most
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part, that question does not turn on the meaning of “de-
t
ailed”—instead, it “involves primarily issues of fact.”
Marsh, 490 U. S., at 377. The agency is better equipped to
assess what facts are relevant to the agency's own decision
than a court is. As a result, “agencies determine whether
and to what extent to prepare an EIS based on the useful-
ness of any new potential information to the decisionmaking
process.” Public Citizen, 541 U. S., at 767 (emphasis
added). So the question of whether a particular report is
detailed enough in a particular case itself requires the exer-
cise of agency discretion—which should not be excessively
second-guessed by a court. Brevity should not be mistaken
for lack of detail. A relatively brief agency explanation can
be reasoned and detailed; an EIS need not meander on for
hundreds or thousands of pages. So courts should not insist
on length as a prerequisite for fnding an EIS to be detailed.
3
The EIS also must identify signifcant environmental im-
pacts and feasible alternatives. But there too, an agency
exercises substantial discretion. An agency must make pre-
dictive and scientifc judgments in assessing the relevant im-
pacts (what are the likely impacts; do they rise to the level
of “signifcant”?) and alternatives (what are the potential al-
ternatives; are they really “feasible”?). As this Court has
said, “the term `alternatives' is not self-defning,” and “[c]om-
mon sense” should be brought to bear. Vermont Yankee,
3
Indeed, federal law now strictly prohibits an agency's EIS from going
on endlessly. In 2023, two years after the Board issued its fnal EIS for
the Uinta Basin Railway, Congress passed and President Biden signed
an Act amending NEPA meaningfully titled the “Building United States
Infrastructure through Limited Delays and Effcient Reviews Act of
2023.” Pub. L. 118–5, Div. C, Tit. III, § 321, 137 Stat. 38–39. Under that
BUILDER Act, an EIS “shall not exceed 150 pages” and must be com-
pleted in “2 years” or less. Id., at 41–42 (42 U. S. C. §§ 4336a(e)(1)(A),
(g)(1)(A)). That Act strongly reinforces the basic principles that NEPA,
correctly interpreted, already embodied but that have been too often over-
looked. The analysis in this opinion thus applies to NEPA as amended
by the BUILDER Act.
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435 U. S., at 551. Black-letter administrative law instructs
that
when an agency makes those kinds of speculative as-
sessments or predictive or scientifc judgments, and decides
what qualifes as signifcant or feasible or the like, a review-
ing court must be at its “most deferential.” Baltimore
Gas & Elec., 462 U. S., at 103; see Marsh, 490 U. S., at 378;
State Farm, 463 U. S., at 43.
In preparing an EIS, an agency also must determine the
scope of the environmental effects that it will address. The
textual focus of NEPA is the “proposed action”—that is, the
project at hand. 42 U. S. C. § 4332(2)(C) (2018). The agency
therefore will obviously seek to assess signifcant effects
from the project at issue. But how far will the agency go in
considering the indirect effects that might occur outside the
area of the immediate project—for example, due to emissions
or run off from the project carried elsewhere by air or water?
And will the agency evaluate the environmental effects from
other future or geographically separate projects that may be
initiated (or expanded) as a result of or in the wake of the
current project? And what if another agency also possesses
regulatory authority over a related project?
In analyzing those scope questions, it is critical to disag-
gregate the agency's role from the court's role. So long as
the EIS addresses environmental effects from the project at
issue, courts should defer to agencies' decisions about where
to draw the line—including (i) how far to go in considering
indirect environmental effects from the project at hand and
(ii) whether to analyze environmental effects from other
projects separate in time or place from the project at hand.
On those kinds of questions, as this Court has often said,
agencies possess discretion and must have broad latitude to
draw a “ `manageable line.' ” Public Citizen, 541 U. S., at
767 (quoting Metropolitan Edison Co. v. People Against Nu-
clear Energy, 460 U. S. 766, 774, n. 7 (1983)).
To tie all of this together: When assessing signifcant envi-
ronmental effects and feasible alternatives for purposes of
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NEPA, an agency will invariably make a series of fact-
dependent,
context-specifc, and policy-laden choices about
the depth and breadth of its inquiry—and also about the
length, content, and level of detail of the resulting EIS.
Courts should afford substantial deference and should not
micromanage those agency choices so long as they fall within
a broad zone of reasonableness. As the Court has empha-
sized on several occasions, and we doubly underscore again
today, “inherent in NEPA . . . is a `rule of reason,' which
ensures that agencies determine whether and to what extent
to prepare an EIS based on the usefulness of any new poten-
tial information to the decisionmaking process.” Public
Citizen, 541 U. S., at 767. A reviewing court may not “sub-
stitute its judgment for that of the agency as to the environ-
mental consequences of its actions.” Kleppe, 427 U. S., at
410, n. 21.
Some courts have strayed and not applied NEPA with the
level of deference demanded by the statutory text and this
Court's cases. Those decisions have instead engaged in
overly intrusive (and unpredictable) review in NEPA cases.
Those rulings have slowed down or blocked many projects
and, in turn, caused litigation-averse agencies to take ever
more time and to prepare ever longer EISs for future
projects.
The upshot: NEPA has transformed from a modest proce-
dural requirement into a blunt and haphazard tool employed
by project opponents (who may not always be entirely moti-
vated by concern for the environment) to try to stop or at
least slow down new infrastructure and construction proj-
ects. Some project opponents have invoked NEPA and
sought to enlist the courts in blocking or delaying even those
projects that otherwise comply with all relevant substantive
environmental laws. Indeed, certain project opponents
have relied on NEPA to fght even clean-energy projects—
from wind farms to hydroelectric dams, from solar farms to
geothermal wells. See, e. g., Brief for Chamber of Com-
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merce of the United States of America, et al. as Amici Cu-
r
iae 19–20.
All of that has led to more agency analysis of separate
projects, more consideration of attenuated effects, more ex-
ploration of alternatives to proposed agency action, more
speculation and consultation and estimation and litigation.
Delay upon delay, so much so that the process sometimes
seems to “borde[r] on the Kafkaesque.” Vermont Yankee,
435 U. S., at 557. Fewer projects make it to the fnish line.
Indeed, fewer projects make it to the starting line. Those
that survive often end up costing much more than is antici-
pated or necessary, both for the agency preparing the EIS
and for the builder of the project. And that in turn means
fewer and more expensive railroads, airports, wind turbines,
transmission lines, dams, housing developments, highways,
bridges, subways, stadiums, arenas, data centers, and the
like. And that also means fewer jobs, as new projects be-
come diffcult to fnance and build in a timely fashion.
A 1970 legislative acorn has grown over the years into
a judicial oak that has hindered infrastructure development
“under the guise” of just a little more process. Id., at 558.
A course correction of sorts is appropriate to bring judicial
review under NEPA back in line with the statutory text and
common sense. Id., at 525. Congress did not design NEPA
for judges to hamstring new infrastructure and construction
projects. On the contrary, as this Court has stressed, courts
should and “must defer to `the informed discretion of the
responsible federal agencies.' ” Marsh, 490 U. S., at 377.
Critically, as the Government and the Coalition explained
at oral argument, courts not only must defer to the agency's
reasonable choices regarding the scope and contents of the
EIS, but also must keep in mind that review of an agency's
EIS is not the same thing as review of the agency's fnal
decision concerning the project. See Tr. of Oral Arg. 31–32,
70–71. That, too, follows from NEPA's status as a purely
procedural statute. The ultimate question is not whether
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an EIS in and of itself is inadequate, but whether the
agency'
s fnal decision was reasonable and reasonably ex-
plained. Review of an EIS is only one component of that
analysis. Even if an EIS falls short in some respects, that
defciency may not necessarily require a court to vacate the
agency's ultimate approval of a project, at least absent rea-
son to believe that the agency might disapprove the project
if it added more to the EIS. Cf. 5 U. S. C. § 706. For exam-
ple, in a case like this one, even if the EIS drew the line on
the effects of separate upstream or downstream projects too
narrowly, that mistake would not necessarily require a court
to vacate the agency's approval of the railroad project. Cf.
Vermont Yankee, 435 U. S., at 558.
4
In other words, as this Court has said before, NEPA does
not authorize a court to “ `interject itself within the area of
discretion . . . as to the choice of the action to be taken' ” by
the agency. Strycker's Bay Nei ghborhood Council, 444
U. S., at 227–228 (quoting Kleppe, 427 U. S., at 410, n. 21).
NEPA's procedural mandate helps “to insure a fully in-
formed and well-considered decision, not necessarily a deci-
sion the judges of the Court of Appeals or of this Court would
have reached had they been members of the decisionmaking
unit of the agency.” Vermont Yankee, 435 U. S., at 558.
The “role of a court in reviewing the suffciency of an
agency's consideration of environmental factors is a limited
one.” Id., at 555. The bedrock principle of judicial review
in NEPA cases can be stated in a word: Deference.
4
When, unlike this case, an agency denies approval of a project, the
denied applicant may ordinarily challenge the denial under the APA or
the relevant agency's governing statute. The denied applicant may argue,
among other things, that the agency acted unreasonably in denying ap-
proval by weighing environmental consequences too heavily in light of the
agency's governing statute and other relevant factors, or perhaps that the
agency erred because the governing statute did not allow the agency to
weigh environmental consequences at all. NEPA does not alter those
judicial inquiries.
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B
E
ven apart from failing to afford suffcient deference to
the Surface Transportation Board, the D. C. Circuit's deci-
sion was mistaken on the merits under NEPA. The D. C.
Circuit erroneously required the Board to address environ-
mental effects from projects that are separate in time or
place from the 88-mile railroad project at hand—that is, ef-
fects from potential future projects or from geographically
separate projects. Moreover, those separate projects fall
outside the Board's authority and would be initiated, if at all,
by third parties.
In its EIS, the Board determined that upstream oil drilling
in the Uinta Basin and downstream oil refning along the
Gulf Coast were separate from the construction and opera-
tion of the 88-mile railroad line. The Board's EIS explained
that the “proposed rail line and any future oil and gas devel-
opment projects are not two phases of a single action,” but
“separate, independent projects.” App. 523. Those other
projects, the Board reasoned, should not be considered “part
of the proposed action assessed in the EIS.” Ibid. The
Board concluded that its EIS need not evaluate the possible
environmental effects from separate upstream or down-
stream projects.
5
The Board's approach complied with NEPA and this
Court's longstanding NEPA precedents. Importantly, the
textually mandated focus of NEPA is the “proposed ac-
5
Even though not mandated by NEPA to do so, the Board did identify
some of the potential effects and marginal risks from projects separate
from the 88 miles of additional railroad track in rural Utah. See, e. g.,
App. 354–358 (forecasting the number of oil wells that could be added in
the Uinta Basin as a result of increased production spurred by the new
railway); id., at 420–423, 539–542 (evaluating effects from increased oil
refning along the Gulf Coast). The Board should not necessarily earn
bonus points for studying more than NEPA demanded. But it should
defnitely not receive a failing grade just because its 3,600-page EIS was
less thorough in analyzing the effects from other projects than the Court
of Appeals might have preferred.
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tion”—that is, the project at hand—not other future or geo-
graph
ically separate projects that may be built (or expanded)
as a result of or in the wake of the immediate project under
consideration. 42 U. S. C. § 4332(2)(C) (2018); see Aber-
deen & Rockfsh R. Co. v. Students Challenging Regulatory
Agency Procedures (SCRAP), 422 U. S. 289, 322–324 (1975);
Kleppe, 427 U. S., at 398–402. Therefore, when the effects
of an agency action arise from a separate project—for exam-
ple, a possible future project or one that is geographically
distinct from the project at hand—NEPA does not require
the agency to evaluate the effects of that separate project.
To be clear, the environmental effects of the project at
issue may fall within NEPA even if those effects might
extend outside the geographical territory of the project or
might materialize later in time—for example, run-off into a
river that fows many miles from the project and affects fsh
populations elsewhere, or emissions that travel downwind
and predictably pollute other areas. Those so-called indi-
rect effects can sometimes fall within NEPA, as the Govern-
ment explained at oral argument. See Tr. of Oral Arg.
59–63.
But if the project at issue might lead to the construction or
increased use of a separate project—for example, a housing
development that might someday be built near a highway—
the agency need not consider the environmental effects of
that separate project. To put it in legal terms, the separate
project breaks the chain of proximate causation between the
project at hand and the environmental effects of the separate
project. See Public Citizen, 541 U. S., at 767 (citing Metro-
politan Edison, 460 U. S., at 774, and n. 7). The effects from
a separate project may be factually foreseeable, but that
does not mean that those effects are relevant to the agency's
decisionmaking process or that it is reasonable to hold the
agency responsible for those effects. Cf. Public Citizen, 541
U. S., at 766–767. In those circumstances, “the causal chain
is too attenuated.” Metropolitan Edison, 460 U. S., at 774.

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In other words, there is no “ `reasonably close causal relation-
sh
ip' ” between the project at hand and the environmental
effects of those other projects. Public Citizen, 541 U. S., at
767 (quoting Metropolitan Edison, 460 U. S., at 774).
Moreover, and importantly, the Board here possesses no
regulatory authority over those separate projects. The
Board does not regulate oil drilling, oil wells, oil and gas
leases, or oil refneries. The Board approves railroad lines.
See 49 U. S. C. §§ 10101, 10901. Other agencies possess au-
thority to regulate those separate projects and their environ-
mental effects. As this Court stated in one of the more im-
portant sentences in the NEPA canon, “where an agency has
no ability to prevent a certain effect due to its limited statu-
tory authority over the relevant actions, the agency cannot
be considered a legally relevant `cause' of the effect.” Pub-
lic Citizen, 541 U. S., at 770. In other words, agencies are
not required to analyze the effects of projects over which
they do not exercise regulatory authority. For that reason
as well, there is no “ `reasonably close causal relationship' ”
between the 88-mile railroad project at hand and the envi-
ronmental effects of the separate oil drilling and oil refning
projects. Id., at 767 (quoting Metropolitan Edison, 460
U. S., at 774); see also Robertson, 490 U. S., at 350–353; Ver-
mont Yankee, 435 U. S., at 550–551, 558.
To be sure, NEPA mandates that an agency “consult with”
other agencies as appropriate. 42 U. S. C. § 4332(2)(C). But
there is a vast difference between, for example, an agency's
consulting with the Forest Service to determine the effects
of a railroad line that would pass through a national forest
and an agency's asking another agency to assess how 88
miles of additional track in rural Utah would contribute to
emissions or climate change along the Gulf Coast. Indeed,
“no rule of reason worthy of that title would require an
agency to prepare an EIS” addressing effects from another
project that is separate in time or place from the project
at hand—particularly when it would require the agency to
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speculate about the effects of a separate project that is out-
side
its regulatory jurisdiction. Public Citizen, 541 U. S., at
767–768 (citing Aberdeen & Rockfsh R. Co., 422 U. S., at 325).
In this case, the Uinta Basin Railway was the relevant
project. NEPA therefore required the Board to consider
the environmental effects of that 88-mile railroad line's con-
struction and operation. To the extent that the new 88-mile
railroad line could disrupt the habitat of protected species,
or the new rail embankments could cause soil erosion into
local bodies of water, or trains on the new line could pollute
the air, NEPA dictated that the Board evaluate those effects.
And consistent with NEPA, the Board here did comprehen-
sively evaluate those effects, including via consultation with
other agencies. As the D. C. Circuit itself recognized, the
Board explained that “construction and operation of the Rail-
way” would affect “water resources, air quality, [and] special
status species like the greater sage-grouse.” 82 F. 4th, at
1168. But nothing in NEPA required the Board to go fur-
ther and study environmental impacts from upstream or
downstream projects separate in time or place from the 88-
mile railroad line's construction and operation.
Under NEPA, it also bears emphasis, a mere “ `but for'
causal relationship is insuffcient to make an agency responsi-
ble for a particular effect.” Public Citizen, 541 U. S., at 767.
Likewise, the fact that other projects might foreseeably be
built or expanded in the wake of the current project does
not, by itself, make the agency responsible for addressing the
environmental effects of those other projects. The agency
may draw what it reasonably concludes is a “ `manageable
line' ”—one that encompasses the effects of the project at
hand, but not the effects of projects separate in time or place.
Ibid. (quoting Metropolitan Edison, 460 U. S., at 774, n. 7).
True, a new airport may someday lead to a new stretch of
highway; a new pipeline to a new power plant; a new housing
development to a new subway stop. But the environmental
effects of the project at hand constitute NEPA's textual
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focus. An agency need not assess the environmental effects
of
other separate projects simply because those projects (and
effects) might not materialize but for the project at hand, or
are in some sense foreseeable.
Simply stated, a court may not invoke but-for causation or
mere foreseeability to order agency analysis of the effects of
every project that might somehow or someday follow from
the current project. See Public Citizen, 541 U. S., at 767–
768; Metropolitan Edison, 460 U. S., at 774–775. NEPA
calls for the agency to focus on the environmental effects of
the project itself, not on the potential environmental effects
of future or geographically separate projects. A relatively
modest infrastructure project should not be turned into a
scapegoat for everything that ensues from upstream oil drill-
ing to downstream refnery emissions. As Justice Rehn-
quist underscored in Vermont Yankee, NEPA is not a “game”
where project objectors can engage in “unjustifed obstruc-
tionism”—here, for example, by raising a slew of remote ef-
fects that they think “ `ought to be' considered.” 435 U. S.,
at 553–554.
To be sure, in certain circumstances, other projects may
be interrelated and close in time and place to the project at
hand—a residential development next door to and built at
the same time as a ski resort, for example. See, e. g., Rob-
ertson, 490 U. S., at 338–340. The question then is whether
that is a single project within the authority of the agency in
question. There may be a gray area in defning the project
at hand. Even in those circumstances, however, a court's
review still must remain deferential, as we explained in Part
II–A above. In other words, even if the reviewing court in
such a case might think that NEPA would support drawing
a different line, a court should defer to an agency so long
as the agency drew a reasonable and “ `manageable line.' ”
Public Citizen, 541 U. S., at 767 (quoting Metropolitan Edi-
son, 460 U. S., at 774, n. 7). All of that is to again underscore
that a difference may exist between what an agency should
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do as a matter of good policy and best practices under
NEP
A, and what a reviewing court may subsequently order
an agency to do under NEPA.
In this case, in any event, the NEPA question is not close.
The Board did not need to evaluate potential environmental
impacts of the separate upstream and downstream projects.
As to other projects upstream, the EIS rightly explained
that the environmental consequences of future oil drilling in
the Basin are distinct from construction and operation of the
railroad line. App. 525–527. As for other projects down-
stream, the Board likewise correctly explained that any envi-
ronmental effects from highly regulated oil refneries along
the Gulf Coast are well outside the scope of the 88-mile rail-
road project in rural Utah. Id., at 420–423, 539–542.
6
An agency may decline to evaluate environmental effects
from separate projects upstream or downstream from the
project at issue. Public Citizen, 541 U. S., at 770. Here,
the Board's EIS concluded that the “proposed rail line and
any future oil and gas development projects are not two
phases of a single action,” but “separate, independent proj-
ects.” App. 523. So the Board concluded that they need
not be considered “part of the proposed action assessed in
the EIS.” Ibid. Absolutely correct.
6
In addition, inherent in Board approval of railroad lines is the under-
standing that any new freight railroad may transport different kinds of
cargo over an approved line—from corn to cars to coal and the like. See
Brief for Association of American Railroads as Amicus Curiae 2, 8–9. As
common carriers, railroads subject to the Board's jurisdiction are required
to provide “transportation or service on reasonable request” to any person
or commodity. 49 U. S. C. §§ 11101(a), 10102(9). Railroad lines approved
by the Board cannot decline to provide “common carrier” transport based
on the product or commodity to be carried. § 11101(a). For that addi-
tional reason, the EIS here correctly explained that the Board was “not
required to analyze impacts related to the destinations or end uses of any
such products or commodities” transported by the 88-mile railroad line,
including Uinta Basin crude oil. App. 422; see Department of Transpor-
tation v. Public Citizen, 541 U. S. 752, 766–770 (2004).

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Sotomayor, J., concurring in judgment
***
In
deciding cases involving the American economy, courts
should strive, where possible, for clarity and predictability.
Some courts' NEPA decisions have fallen short of that objec-
tive. The proper judicial approach for NEPA cases is
straightforward: Courts should review an agency's EIS to
check that it addresses the environmental effects of the proj-
ect at hand. The EIS need not address the effects of sepa-
rate projects. In conducting that review, courts should af-
ford substantial deference to the agency as to the scope and
contents of the EIS.
Plaintiffs' policy objections to this 88-mile Utah railroad
may or may not be persuasive. But neither “the language
nor the history of NEPA suggests that it was intended to
give citizens a general opportunity to air their policy objec-
tions to proposed federal actions. The political process, and
not NEPA, provides the appropriate forum in which to air
policy disagreements.” Metropolitan Edison, 460 U. S., at
777. Citizens may not enlist the federal courts, “under the
guise of judicial review” of agency compliance with NEPA,
to delay or block agency projects based on the environmental
effects of other projects separate from the project at hand.
Vermont Yankee, 435 U. S., at 558.
We reverse the judgment of the Court of Appeals and re-
mand the case for further proceedings consistent with this
opinion.
It is so ordered.
Justice Gorsuch took no part in the consideration or de-
cision of this case.
Justice Sotomayor, with whom Justice Kagan and
Justice Jackson join, concurring in the judgment.
The National Environmental Policy Act improves agency
decisionmaking by requiring agencies to consider environ-
mental impacts for which their decisions would be responsi-
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ble. I agree with the Court that the Surface Transportation
Board
would not be responsible for the harms caused by the
oil industry, even though the railway it approved would de-
liver oil to refneries and spur drilling in the Uinta Basin. I
reach that conclusion because, under its organic statute, the
Board had no authority to reject petitioners' application on
account of the harms third parties would cause with products
transported on the proposed railway. The majority takes a
different path, unnecessarily grounding its analysis largely
in matters of policy. Accordingly, I write separately to ex-
plain why the result in this case follows inexorably from
our precedent.
I
A
The Uinta Basin spans thousands of square miles across
northwestern Utah and Colorado. Bookended by the Uinta
Mountains in the north and the Roan Cliffs in the south, the
Basin is hard to access and has few residents. The Basin,
however, contains “ `extensive deposits of valuable miner-
als,' ” including large reserves of “waxy crude,” a form of
petroleum known for its thick consistency at ambient tem-
peratures. 82 F. 4th 1152, 1165–1166 (CADC 2023). For
over a decade, oil producers have transported this oil out of
the Basin in heated tanker trucks, to be sold to refneries in
Utah and beyond.
Petitioners, the Seven County Infrastructure Coalition
and the Uinta Basin Railway, LLC, plan to build a railway
connecting the Uinta Basin with the Union Pacifc Railroad
Company station in Kyune, Utah, and from there to the na-
tional rail network. As the Coalition recognizes, “the Rail-
way's predominant and expected primary purpose would be”
to enable Basin oil producers to transport, with greater ease
and in greater quantities, waxy crude to refneries in the
Gulf Coast. Ibid. Nearly all the waxy crude transported
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194 SE
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Sotomayor, J., concurring in judgment
over the Union Pacifc track from Kyune to Denver, which
r
uns through Eagle County, Colorado, and closely abuts the
Colorado River.
B
No person may “construct an additional railroad line” or
“provide transportation over . . . an extended or additional
railroad line” without a certifcate of approval from the Sur-
face Transportation Board. 49 U. S. C. § 10901(a). Appli-
cants can fle a formal application for such a certifcate,
§ 10901(c), or they can seek approval through an abbreviated
exemption process, § 10502(a). In either case, the Act ex-
presses a clear presumption in favor of approving railways.
See ibid. (exemptions must be granted “to the maximum ex-
tent” consistent with law); § 10901(c) (the Board “shall” issue
a certifcate “unless” inconsistent with public convenience
and necessity).
In May 2020, petitioners requested permission to build the
Railway by way of the exemption procedure. Because the
proposed railway constitutes a “major Federal actio[n] sig-
nifcantly affecting ” the environment, the National Environ-
mental Policy Act (NEPA) required the Board to prepare a
“detailed” statement addressing its environmental impacts.
42 U. S. C. § 4332(C). The Board conditionally approved
petitioners' request based on the Railway's “transportation
merits,” but it deferred a fnal decision pending the results
of its environmental review. Surface Transportation Board,
Offce of Environmental Analysis, Uinta Basin Railway Final
Environmental Impact Statement S–2, n. 2 (Aug. 2021)
(Final EIS).
After soliciting public comment, the Board completed its
environmental impact statement on August 6, 2021.
1
App.
1
The fnal statement consisted of a 600-page report accompanied by
supporting appendixes and responses to the public comments. See www.
uintabasinrailwayeis.com (Board-created website containing the complete
EIS and all related documentation); cf. ante, at 173, 175, 186, n. 5 (assert-
ing that the EIS spanned more than 3,600 pages of analysis).
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195
Sotomayor, J., concurring in judgment
to Pet. for Cert. 76a. The statement recognized that “be-
tween
3.68 and 10.52 trains” would travel daily on the pro-
posed new railway, which would be used “primarily to trans-
port crude oil from the Basin to markets across the United
States.” Final EIS 1–4. Consistent with its obligations
under NEPA, the Board discussed the comparative environ-
mental merits of alternative railway routes as well as the
environmental consequences common to all alternatives.
Among other things, the Board analyzed the Railway's likely
impact on the Basin's natural environment and the impacts
increased freight traffc from the Railway would have on the
existing Union Pacifc line running through Eagle County.
Of particular relevance here, the Board recognized that
“[r]efners would refne the crude oil transported by the pro-
posed rail line into various fuels,” which in turn would be
combusted, causing an increase in greenhouse-gas emissions.
Id., at 3.15–35. Depending on market conditions, the Board
estimated that increased oil production made possible by the
Railway would cause greenhouse-gas emissions equivalent to
between 0.04 and 0.1 percent of the global total. Id., at
3.15–36. (By way of comparison, Sweden and Ireland are
each responsible for about 0.1 percent of global emissions.
2
)
Although the Board recognized the “massive deleterious im-
pacts” of climate change, it explained that it was “not re-
quired to analyze impacts related to the destinations or end
uses of ” products transported on proposed rail lines. Ibid.
After all, the Board explained, “railroads have a common car-
rier obligation to carry all commodities, including hazardous
materials, upon reasonable request,” meaning the Board can-
not control the products “transported on the proposed rail
line.” Ibid. (citing 49 U. S. C. § 11101 and Riffn v. STB, 733
F. 3d 340, 345–347 (CADC 2013)). For that reason, the
Board did not consider in further detail the effects of in-
2
See European Commission, Emissions Database for Global Atmo-
spheric Research Report 2024 (last accessed May 7, 2025), https://edgar.
jrc.ec.europa.eu/report_2024#emissions_table.
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creased drilling for oil in the Basin, or increased refning of
oi
l in the Gulf Coast.
After completing this analysis, the Board issued a decision
approving the railway. With respect to the anticipated in-
crease in oil production, the Board again concluded that it
had “no authority or jurisdiction over development of oil and
gas in the Basin nor any authority to control or mitigate the
impacts of any such development.” App. to Pet. for Cert.
108a. Board member Oberman dissented. In his view, the
Board did have “the power to deny construction approval
based on weighing all of the environmental impacts that will
arise from oil and gas development in the Basin,” particu-
larly because the Railway's “ `entire purpose' ” would be to
stimulate such production. Id., at 124a.
C
Several environmental groups fled a petition for review of
the Board's decision to approve the railway, arguing princi-
pally that the Board should have further considered the con-
sequences of increased oil drilling and refning that the Rail-
way's construction would enable. Eagle County separately
petitioned for review of the Board's decision, alleging that
the Board's environmental analysis was defcient because it
ignored or underestimated the Railway's impacts, through
increased rail traffc, on the County and the nearby Colorado
River. Petitioners intervened in support of the Board's
decision.
The D. C. Circuit rejected several claims no longer at issue
here, but it sided with the challengers on others. With re-
gard to the environmental respondents' challenge, the court
held that the Board should have more carefully considered
the deleterious environmental effects of increased oil produc-
tion made possible by the Railway's construction. 82 F. 4th,
at 1180. Among other things, the court explained, the
Board should have “estimate[d] the emissions or other envi-
ronmental impacts” of oil refning as localized for the “spe-
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cifc regions that will receive the oil based on expected train
traffc.
” Id., at 1179. The court rejected the Board's argu-
ment “that it lacks authority to prevent, control, or mitigate
those developments.” Id., at 1180. Instead, in the D. C.
Circuit's view, the Board's statutory obligation to consider
whether the Railway would serve the “ `public convenience
and necessity' ” encompassed “reasonably foreseeable envi-
ronmental harms,” including those resulting from the in-
crease in oil production on the Gulf Coast. Ibid.
Moving to the County's claims, the D. C. Circuit agreed
the Board's analysis of the Railway's effect on the Union Pa-
cifc track and the Colorado River contained serious, unex-
plained errors and omissions. The court further concluded
that the Board had failed to comply with several other statu-
tory requirements unrelated to NEPA. Accordingly, the
D. C. Circuit vacated the Board's decision and remanded it
to the agency for further proceedings.
Petitioners asked this Court to review only one part of the
D. C. Circuit's decision: whether NEPA required the Board
to study the environmental impacts of oil wells and refneries
that lie outside the Board's regulatory authority. Pet. for
Cert. i. This Court granted review to decide that question.
II
A
NEPA requires agencies to prepare and publish a “de-
tailed statement” reviewing the environmental impact of
any major federal action. 42 U. S. C. § 4332. That “action-
forcing ” requirement serves dual purposes, ensuring both
that an agency considers a project's environmental conse-
quences before deciding whether to approve it, and render-
ing the agency publicly accountable for environmental harms
it decides to tolerate. See Robertson v. Methow Valley Citi-
zens Council, 490 U. S. 332, 349–350 (1989). The point, as
this Court has recognized, is not merely that an agency
produce a report but “that environmental concerns be inte-
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grated into the very process of agency decision-making.”
Andr
us v. Sierra Club, 442 U. S. 347, 350 (1979); see also
Kleppe v. Sierra Club, 427 U. S. 390, 409–410 (1976); Robert-
son, 490 U. S., at 350. In that way, NEPA's procedural re-
quirements advance Congress's aim that the Federal Govern-
ment “use all practicable means [to ensure] that the Nation
may . . . fulfll the responsibilities of each generation as trustee
of the environment for succeeding generations.” § 4331(b)(1).
Because NEPA's central aim is to improve agency deci-
sionmaking, an agency need not consider every conceivable
environmental consequence of a proposed federal action.
Rather, agencies need only analyze environmental impacts
for which their decision would be (at least in part) “responsi-
ble,” a requirement akin to “the familiar doctrine of proxi-
mate cause from tort law.” Metropolitan Edison Co. v. Peo-
ple Against Nuclear Energy, 460 U. S. 766, 774, and n. 7
(1983). An agency is not responsible for environmental im-
pacts it could not lawfully have acted to avoid, either through
mitigation or by disapproving the federal action. See De-
partment of Transportation v. Public Citizen, 541 U. S. 752,
770 (2004). Nor is an agency responsible for impacts that,
though technically avoidable, are so causally attenuated from
or ancillary to the agency's statutorily assigned tasks that it
could not reasonably have been expected to consider them
as part of its decisionmaking process. Metropolitan Edi-
son, 460 U. S., at 774. Together these limitations serve to
keep the scope of the agency's review targeted to environ-
mental impacts it is well positioned to address.
Precedent makes these abstract principles concrete. In
Public Citizen, this Court evaluated the Federal Motor Car-
rier Safety Administration's environmental analysis of regu-
lations establishing an application process for Mexican motor
carriers who wanted to operate in the United States. 541
U. S., at 758–763. The application system itself had only
minimal environmental impacts (related to anticipated road-
side inspections of the Mexican trucks and buses). Yet the
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agency developed it at the direction of the President, who
had
decided to lift a long-running moratorium on Mexican
carriers' operation in the United States following the sys-
tem's completion. Id., at 760. Thus, promulgation of the
agency's regulations would enable a substantial infux of new
trucking, which in turn would have major environmental
implications.
This Court concluded that, though the agency's regulations
would be a “but-for” cause of the new trucking, it did not
need to consider the related environmental impacts because
it had “no authority to prevent” them. Id., at 766–767.
After all, the decision to lift the moratorium had been the
President's, not the agency's, and the agency could not law-
fully refuse to issue its regulations in order to block the
President's decision. Id., at 761. The agency had no means
to prevent, and thus was not responsible for, the conse-
quences of lifting the moratorium. Hence NEPA did not re-
quire it to analyze those consequences.
The Court's decision in Metropolitan Edison illustrates
the companion principle: Some environmental impacts are
connected to an agency action by way of so “attenuated” a
causal chain that the agency may reasonably dismiss them as
ancillary to its decision. 460 U. S., at 774. In Metropolitan
Edison, the Court considered whether the Nuclear Regula-
tory Commission had to analyze not only the risk that a pro-
posed nuclear plant would cause an accident, but also the
psychological concern nearby residents might experience
when they learned about that risk. Ibid. Although the
psychological concern would be “caused by” the nuclear
plant, the Court held that NEPA did not require the agency
to consider it. Id., at 774–775. That makes sense: Prevent-
ing nuclear accidents is a core element of the Commission's
statutory task; preventing psychological distress is not. See
id., at 776 (noting that “psychiatric expertise” is “not other-
wise relevant to [the agency's] congressionally assigned func-
tions”). Because the agency could reasonably disregard
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psychological distress in deciding whether to approve a
power
plant, it could disregard that risk in its environmental
analysis as well.
As these cases show, the dual limitations on an agency's
duty to consider information under NEPA yield a “ `rule of
reason,' which ensures that agencies determine whether and
to what extent to prepare an EIS based on the usefulness of
any new potential information to the decisionmaking proc-
ess.” Public Citizen, 541 U. S., at 767 (quoting Marsh v.
Oregon Natural Resources Council, 490 U. S. 360, 373–374
(1989)). NEPA requires consideration of environmental im-
pacts only if such consideration would result in information
on which the agency could act.
B
Consistent with these principles, judicial review of an
agency's environmental impact statement involves a two-
step analysis. First, courts must consider the grounds on
which an agency may rely under its organic statute to modify
(by mitigation) or reject a proposed federal action. If the
organic statute precludes consideration of a particular issue,
the agency may set it aside for purposes of its NEPA review
as well. That is the rule of Public Citizen.
3
Second, if an agency decided not to review an environmen-
tal impact because (in its judgment) the impact was too caus-
ally attenuated from the question at hand, courts must ask
whether the agency “acted arbitrarily” in doing so. Kleppe,
427 U. S., at 412. That deferential standard of review is ap-
propriate here, as it is across substantive areas of adminis-
trative law, because “[a]gencies . . . have `unique expertise,'
often of a scientifc or technical nature, relevant to applying
3
It follows from this rule that the proper scope of an agency's NEPA
review depends in part on the nature of the agency's statutory authority.
The greater an agency's authority to consider and prevent environmental
impacts in its decisionmaking process, the greater its duty under NEPA
to consider those impacts, and vice versa.

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Sotomayor, J., concurring in judgment
a regulation `to complex or changing circumstances.' ”
Kiso
r v. Wilkie, 588 U. S. 558, 571 (2019) (plurality opinion).
Thus, as the majority points out, agencies often are “better
equipped to assess what facts are relevant to the[ir] . . . own
decision than a court is.” Ante, at 181; cf. Loper Bright En-
terprises v. Raimondo, 603 U. S. 369, 456 (2024) (Kagan, J.,
dissenting) (“[A]gencies often know things about a statute's
subject matter that courts could not hope to”).
4
This case provides no occasion to consider the second step
because the question presented is resolved at the frst. The
Board twice decided it lacked authority to reject railway ap-
plications on account of the ways in which third parties
would use the products “transported on the proposed rail
line.” Final EIS 3.15–36; App. to Pet. for Cert. 108a (“Here,
the Board has no authority or jurisdiction over development
of oil and gas in the Basin nor any authority to control or
mitigate the impacts of any such development”). Each time,
the agency cited Public Citizen to justify its decision not to
analyze further the environmental effects of oil drilling and
refning made possible by the Railway. See Final EIS 3.15–
36; App. to Pet. for Cert. 108a.
Review of the Board's organic statute, the Interstate Com-
merce Commission Termination Act of 1995, confrms the
Board's understanding of the scope of its review. “As com-
mon carriers, railroads subject to the Board's jurisdiction are
required to provide `transportation or service on reasonable
request' to any person or commodity.” Ante, at 191, n. 6
(quoting 49 U. S. C. § 11101(a)). In addition, the Act contains
a clear presumption in favor of approving new railways. See
supra, at 194. And of the 15 statutory policies the Board
must consider in the exemption process, not one concerns the
anticipated use of commodities that will be transported on the
proposed railway. See §§ 10101(1)–(15). Unlike the Board,
meanwhile, other entities do have authority “to approve oil
4
Of course, that point applies equally when an agency decides that an
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and gas development projects” and to regulate the effects of
ref
ning. See Brief for Federal Respondents 19. All this
suggests, as the Board concluded, that the Board could not
have rejected petitioners' application in order to prevent the
harmful effects of oil drilling and refning.
5
Short of reject-
ing the Railway entirely, moreover, the common carrier man-
date prevented the Board from mitigating, by limiting the
transport of crude oil, the Railway's spurring of the oil indus-
try. See § 11101(a).
The environmental respondents concede that the Board
correctly understood the scope of its decisionmaking author-
ity. See Tr. of Oral Arg. 84–85. Instead, they argue that
the Board should have analyzed even environmental impacts
it could not lawfully prevent. Yet Public Citizen squarely
forecloses that position. See supra, at 201. Even a fore-
seeable environmental effect is outside of NEPA's scope if
the agency could not lawfully decide to modify or reject the
proposed action on account of it. NEPA thus did not re-
quire the Board to consider the effects of oil drilling and
refning.
***
Under NEPA, agencies must consider the environmental
impacts for which their decisions would be responsible.
Here, the Board correctly determined it would not be re-
sponsible for the consequences of oil production upstream or
downstream from the Railway because it could not lawfully
5
The D. C. Circuit came to the opposite conclusion because it viewed
the Board's authority to license railroad construction based on the “ `public
convenience and necessity' ” as encompassing the effects of oil drilling and
refning enabled by the Railway. 82 F. 4th 1152, 1180 (2023). That
phrase, however, must be read “with a view to [its] place in the overall
statutory scheme.” Davis v. Michigan Dept. of Treasury, 489 U. S. 803,
809 (1989). Here, the Board's organic statute contains clear indicators,
most signifcantly the common carrier mandate, that the Board's authority
does not extend so far.

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consider those consequences as part of the approval process.
F
or that reason, I concur in the Court's judgment reversing
the D. C. Circuit's holding requiring the Board to consider in
further detail harms caused by the oil industry.
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Reporter’s Note
The attached opinion has been revised to refect the usual publication
and citation style of the United States Reports. The revised pagination
makes available the offcial United States Reports citation in advance of
publication. The syllabus has been prepared by the Reporter of Decisions
for the convenience of the reader and constitutes no part of the opinion of
the Court. A list of counsel who argued or fled briefs in this case, and
who were members of the bar of this Court at the time this case was
argued, has been inserted following the syllabus. Other revisions may
include adjustments to formatting, captions, citation form, and any errant
punctuation. The following additional edits were made:
p. 185, line 7 from bottom: “of ” is inserted before “this”
p. 198, line 1: “agency” is inserted before “decision-making ”