“A 1970 legislative acorn has grown over the years into a judicial oak that has hindered infrastructure development ‘under the guise’ of just a little more process.” Justice Kavanah’s words in the Supreme Court’s majority opinion in Seven County Infrastructure Coalition v. Eagle County are an apt description of what the National Environmental Policy Act (NEPA) has become. Indeed, a law that was once simple and easy has made any infrastructure development crawl at a snail’s pace.