The vast majority of environmental impact statements prepared under the National Environmental Policy Act (NEPA) during the last five years have concerned the localized environmental effects of particular major federal actions such as highway segments and dams, or of specific federal loans, grants, permits, and licenses. That NEPA was intended to have such an impact at the lower levels of federal decisionmaking, where most decisions regarding environmentally harmful projects are formulated and made final, is clear from its legislative history.¹

A more recent and equally important trend regarding the "environmental quality" of federal decisionmaking, however, has been growing recognition among both agencies and courts that in certain circumstances NEPA also requires preparation of "program" environmental impact statements, that is, statements that examine the environmental effects of a broad federal policy or program decision, which will entail a number of discreet major federal actions. In an important decision² written by Judge J. Skelley Wright, the D.C. Circuit Court of Appeals has now extended this doctrine by holding that NEPA can require preparation of a program EIS on nominally independent major federal actions within the same geographical area, even where the government claims no federal program exists.