Permitting Reform In Action: CEQ Updates Roadmap For Agency NEPA Compliance

Highlights

• The Council on Environmental Quality (CEQ) on Sept. 29, 2025, issued new, nonbinding guidance to assist federal agencies with implementation of the National Environmental Policy Act (NEPA), updating the prior memorandum that CEQ had issued in February 2025 in light of recent case law and executive action.
• The new guidance includes suggested procedures for agencies to adopt when establishing or revising their NEPA implementing procedures.
• This Holland & Knight alert provides a brief summary of the relevant background and breaks down the new guidance to highlight the most significant updates.

In keeping with the Trump Administration's goals of permitting reform, the Council on Environmental Quality (CEQ) on Sept. 29, 2025, issued an updated guidance memorandum to the heads of federal agencies regarding implementation of the National Environmental Policy Act (NEPA), which supersedes and replaces CEQ's prior NEPA guidance. This Holland & Knight