The past few months have been characterized by ongoing threats to public lands and environmental protections. At RPL, we are doing our best to sort through the proposed changes so we can clearly understand what is at stake for our running community and act in ways that continue to support our public lands, the environment, and the health of runners for generations to come.
One of the foundational ways that runners historically have contributed to decisions around how public lands are managed is via the National Environmental Policy Act (NEPA). NEPA has been considered the cornerstone of U.S. environmental law and has provided a regulatory framework for assessing the environmental impact of proposed actions across federal agencies. It is also the framework that facilitates public participation during environmental assessments and impact statements, allow ing for runners to make their voices heard in decisions that affect public landscapes on which we run.
In a sweeping transformation of federal environmental review procedures that began earlier this year, NEPA has been substantially weakened as different federal departments overseeing public lands released interim final rules (IFR) to modify its implementation, and the Council of Environmental Quality (CEQ) has rescinded its NEPA regulations. The proposed changes would significantly curtail the ability of runners to participate in processes that affect the environmental health and protection of public lands.
It can be easy to get lost in the technical details of NEPA changes, but the bottom line is that the proposed changes will limit public engagement, remove a clear regulatory framework for NEPA’s implementation, make judicial review more challenging, and curtail transparency and oversight into NEPA processes. Here, we dive into what the proposed IFRs from different federal departments actually mean for NEPA and the implications of these changes for runners and other public lands users.
Key Developments and Implications
The changes to NEPA are widespread and can be hard to parse through. Here, we highlight several key developments and potential changes to NEPA processes across different federal agencies.
Rescission of CEQ Regulations
Historically, the Council on Environmental Quality (CEQ) has overseen the implementation of NEPA across federal agencies by implementing regulations to comply with NEPA’s procedural requirements. The recent rescission of CEQ regulations means that implementation of NEPA will now occur at the agency-level, leading to fragmented implementation that hinges more on internal agency guidance than a regulatory framework. This means that there will no longer be a unified body regulating NEPA implementation. This will likely make it harder for trail runners to make their voices heard as there will be inconsistencies between how different agencies are implementing NEPA that will hinder collaborative efforts.
Loss of transparency and weakened public participation
Through their IFRs, agencies are reducing opportunities for public participation, limiting avenues for judicial review, and generally making public comment periods shorter and less frequent. All of this would curtail the ability of the running community and other public land users to have a voice in processes and decisions that affect the public lands we collectively enjoy.
Increase the ability to bypass environmental assessment
Several proposed revisions to NEPA implementation will increase different agencies’ ability to sidestep meaningful environmental analysis. This weakens safeguards for trails we share, important cultural sites, and ecosystems contained within public lands.
Significantly reduce (and in most cases eliminate) the requirement to conduct cumulative impact and climate risk analyses
Narrowing environmental analysis to “reasonably foreseeable” impacts disregards cumulative and climate-related impacts. In the trail running community, where trails often intersect with wildfire regimes, watershed health, and species habitat—omitting considerations for longer-term impacts is particularly harmful for growing existential and long-term threats from climate change.
What Does This Mean For You?
With fewer formal opportunities for comment, stakeholders—particularly in the conservation, outdoor recreation, and local government sectors—are losing key participatory opportunities. This makes it even more critical for us to engage early and maintain relationships with agency staff to influence project design and procedural decisions. Run club leaders, race directors, and other groups of runners should make sure they are building and maintaining relationships with local land managers. With expedited NEPA processes and more limited public engagement opportunities, it will fall more to regional groups to know what’s happening and to be able to take initiative on participation and advocacy efforts.
What Has RPL Done?
RPL submitted public comments to the Department of Agriculture and the Department of the Interior strongly opposing each of these departments’ interim final rule (IFR) revising their implementation procedures under NEPA. Our comments reflected our ongoing dedication to protecting and restoring public lands and promoting sustainable trail access. They also reflected our continued interest in collaborating with the U.S. Forest Service and other agencies to support management that balances ecological health, community benefit, and equitable access now and for future generations.
What Comes Next?
Most government agencies accepted public comments on NEPA IFRs up until August 4, 2025. So, the public comment period for this has now closed. The agencies are now in the process of reviewing public comments, which can take a while. Outcomes after review include 1) confirmation of the proposed changes to NEPA with no additional changes; 2) issuing revised rules based on comments and feedback; 3) withdrawing the IFRs and issuing new IFRs. There will likely also be lawsuits challenging the IFRs that will also have to be played out.
Photo: Oscar Ponteri