It's interesting. Several past rail projects have needed CEQA if they involve work outside of the current right of way (which CAHSR certainly does - it doesn't own much yet), that isn't limited to federal land (again, CAHSR is certainly getting more than just federal land), and that involves activity by non-rail parties like local governments or that isn't directly rail related (like new/expanded parking lots at stations; umm...CAHSR again?). Certainly, NEPA has to be covered for STB action, but unless everything's rail-related activity in the existing railroad r/w applies CEQA also has applied.

If applied more broadly by federal agencies, the STB position could have implications well beyond rail projects. I agree that this could be a significant change in the way things are done. Will have to see how the situation (who will sue STB, and will any other agencies start taking similar positions?) develops.