Title I of the National Environmental Policy Act of 1969¹ (hereafter NEPA) imposes a broad scope of environmental responsibility upon federal agencies. Unlike other environmental protection statutes that begin with broad declarations of purpose but then limit federal agencies to specific duties, NEPA declares a comprehensive national environmental policy and imposes both procedural and substantive duties on federal agencies to implement that policy.² Thus, the responsibility of federal agencies under NEPA is as broad as the declaration of environmental policy.

Judicial enforcement of the duties imposed by NEPA will be necessary if, as is likely, the federal agencies concerned do not readily abandon entrenched attitudes and procedures that currently result in environmental degradation. The broad reach of NEPA's policy, and the necessity for judicial enforcement, will then most certainly result in environmental litigation that asks the courts to determine whether agencies have fulfilled their responsibility under NEPA to protect the environment. Environmental attorneys have an obligation to aid courts in their task by adopting a rational judicial strategy for the use of NEPA.