Seven County Infrastructure Coalition v. Eagle County

The STB's approval of the Uinta Basin Railway posed a threshold question: whether NEPA required analysis of downstream oil production and combustion effects that would foreseeably result from the railway's transportation capacity, even though extraction and emissions decisions belong to private producers and states outside the STB's regulatory authority. The Court held that NEPA's indirect-effects requirement does not extend to such third-party consequences, since the STB can neither require producers to limit drilling nor regulate combustion emissions once oil leaves its jurisdiction—effects it has no legal power to mitigate or prevent. This parsing of "reasonably foreseeable" to exclude foreseeable-but-uncontrollable third-party conduct narrows the causal chain agencies must trace in environmental review, constraining NEPA to effects within the permitting agency's sphere of regulatory influence rather than all downstream economic consequences of its approval.