On July 3, 2025, numerous federal agencies initiated an effort to revise the manner in which they comply with the National Environmental Policy Act (NEPA).  NEPA, a cornerstone of environmental governance and project development in the U.S., has historically been implemented through regulations from the Council on Environmental Quality (CEQ).  The DC Circuit questioned the legality of those regulations, as well as CEQ’s authority to implement them.  And at the direction of President Trump’s February 25, 2025 Executive Order 14154 — “Unleashing American Energy” — CEQ rescinded its NEPA implementing regulations.  In place, CEQ provided guidance for agencies that instructed them to update their NEPA procedures by February 2026 in a manner consistent with recent statutory amendments that prioritizes “efficiency and certainty over any other policy objectives.”  Today, we are getting our first glimpse into what that process will look like.

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