What legal challenge are environmental groups most likely to bring against the NEPA skip?

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Environmental groups will argue NEPA mandates environmental review for major federal actions, and a five-year program opening 1.27 billion acres to drilling is undeniably "major." They'll cite 45 years of practice (every program since 1980 underwent NEPA review) as evidence the statute requires it. Courts must decide if Interior can claim discretion to skip review that's been standard practice for decades, or if NEPA's mandate is absolute.

What legal challenge are environmental groups most likely to bring against the NEPA skip?

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