… The Supreme Court’s reasoning in Seven County encourages judicial restraint in NEPA cases. Thus, Seven County may prompt federal agencies to conduct NEPA reviews with less fear of judicial oversight than they may have had prior to the decision. For proponents of water infrastructure projects involving the U.S. Army Corps of Engineers (Corps), Bureau of Reclamation (Reclamation), or other federal agencies, this shift could create a less onerous permitting process. However, these project proponents remain exposed to regulatory uncertainty — especially in projects involving multiple federal agencies — because of the recent rollback of the Council on Environmental Quality’s unified NEPA framework. The proponents also face litigation risk at the state level, and under statutes that, unlike NEPA, impose substantive constraints on development decisions. In fact, approval of the project at the heart of Seven County remains vacated under some such authorities at this time. Therefore, all stakeholders — project proponents and opposers alike — should proceed cautiously as this area of law continues to evolve.