The new Federal Aviation Administration (FAA) Order 1050.1G introduces major changes to the Agency's policy and procedures for complying with the National Environmental Policy Act (NEPA), which applies to a broad range of infrastructure development and operations at airports, heliports, vertiports, and commercial space launch facilities. New Order 1050.1G replaced Order 1050.1F and became effective July 3, 2025 (upon publication of the Federal Register Notice announcing its availability) and will apply prospectively only. 

Affected stakeholders now have until August 4, 2025, to submit comments to the FAA, which FAA advises "will inform future revisions" of the Order.

FAA's action is part of a broader suite of "landmark revisions" to U.S. Department of Transportation (DOT) NEPA policies and procedures announced on June 30, 2025, and comes in the context of several recent developments that have greatly altered the NEPA policy and legal landscape, including;

• the Council on Environmental Quality's (CEQ) rescission of its NEPA regulations in response to Executive Order No. 14154 Unleashing American Energy and the U.S. Court of Appeals for the District of Columbia decision in Marin Audubon Soc'y v. FAA;
• the U.S. Supreme Court's decision in Seven County Infrastructure Coalition v. Eagle County, narrowing the required scope of NEPA analyses and limiting the role of courts in reviewing NEPA analyses; and
• changes to NEPA made by the Fiscal Responsibility Act of 2023 (FRA, see also NEPA.Gov Q&A) and the One Big Beautiful Bill Act of 2025 (OBBA), including time and page limits and revised standards for determining NEPA documentation required.

Key changes to FAA's NEPA procedures implemented through new Order 1050.1G include:

1. Narrows Impacts Subject to Analysis: Climate and environmental justice are no longer required subjects of analysis.

Moreover, in accordance with Seven County, Order 1050.1G adds new directives for FAA to focus analysis on the effects of the "action or project at hand" (emphasis in original) and to document "where and how [FAA] drew a reasonable and manageable line" in considering effects that are geographically or chronologically remote from the project itself or effects from other projects that are separate in time or place, fall outside of FAA’s regulatory authority, or a third party would need to initiate, if consideration of these effects would assist in decision-making.  

2. Narrows Actions Triggering NEPA Review: Implementing and exceeding changes made by the 2023 FRA, new Order 1050.1G clarifies that NEPA does not apply to a “non-exhaustive list” of action, including:

• "non-federal actions," including "actions with no or minimal Federal funding" (with a new presumption that - subject to some caveats - projects with 14% or less of total funding are exempt);
• "nondiscretionary actions," describing such actions as those where FAA "retains no residual discretion to consider environmental factors" in making a decision;
• (consistent with Seven County) simply because FAA involvement or funding could be considered a "but-for" cause of an action; or
• certain other “advisory” actions, “such that the FAA does not have substantial control or responsibility over their outcome.”

3. Speeds EA and EIS Reviews and Imposes Page Limitations. New Order 1050.1G also implements page and time limits required by the FRA: 75 pages and 1 year for Environmental Assessments (EAs) and 150 pages and 2 years for Environmental Impact Statements (EISs). The OBBA cuts these timeframes in half, where a project sponsor pays to CEQ 125 percent of the anticipated costs of preparing or overseeing a NEPA document.

4. Clarifies Applicability of CATEXs (Categorical Exclusions) and Role of "Extraordinary Circumstances": New Order 1050.1G continues to recognize that actions that are "categorically excluded" (CATEX'ed) from more in-depth analysis may nonetheless be subject to an EA or EIS in "extraordinary circumstances." The list of such "extraordinary circumstances" is largely unchanged from previous guidance. However, Order 1050.1G clarifies the actions “likely to be highly controversial on environmental grounds” may be deemed to present an extraordinary circumstance only where the controversy "relate[s] to a substantive issue pertaining to the analysis of effects" and not simply because "a substantial number of persons" oppose or may be affected by the action. Also consistent with existing NEPA practice, the Order affirms that, even if FAA finds "extraordinary circumstances" exist, the Agency can apply a CATEX where it "concludes there is no potential for significance from the project as designed."

5. Updates Significance Thresholds: Despite noting that they "remain unchanged, with one minor exception," FAA’s significance thresholds in Appendix A of New Order 1050.1G do incorporate some major changes from the previous listing (in Exhibit 41 of Order 1050.1F), including the elimination of thresholds for climate, coastal resources and environmental justice impacts.

6. Supersedes Lines of-Business (LOB)-specific NEPA orders, guidance, manuals, or "other NEPA-related instructions" to the extent they conflict with Order 1050.1G (e.g., Order 5050.4B NEPA Implementing Instructions for Airport Actions). Order 1050.1G also makes several references to the 1050.1 Desk Reference as a source of, e.g., "more detail," "further instructions," and "applicable standards." While FAA indicates on its dedicated webpage that the Desk Reference "is being updated and will be posted when a final version is complete," it is unclear whether the FAA will provide an opportunity to comment on any revision.

Potentially affected stakeholders should carefully review new Order 1050.1G and comment on any changes that may affect FAA actions taken on or after July 3, 2025. In its Notice, FAA states new Order 1050.1G "does not apply to or alter any decisions made or final environmental documents issued" before July 3, 2025. Similarly, stakeholders should be on the lookout for the promised revisions to the 1050.1 Desk Reference and prepare to engage the FAA as appropriate. 

Going forward, stakeholders should understand that NEPA policy and law will continue to evolve, both within FAA and more broadly within DOT and across the federal government.