On October 26, in D.C. Preservation League v. U.S. Department of the Interior¹, the U.S. District Court for the District of Columbia preliminarily held that federal agencies cannot avoid environmental review under the National Environmental Policy Act (NEPA) of proposed work at the East Potomac Golf Course in Washington, D.C. (Course), by segmenting that work into smaller pieces, despite the U.S. Supreme Court’s landmark NEPA ruling in Seven County Infrastructure Coalition v. Eagle County² (Seven County) concerning deference to agencies.