Editors' Summary: NEPA requires federal agencies to prepare EISs for major federal actions that significantly affect the quality of the human environment. EISs must discuss all reasonable alternatives to the proposed action. The discussion of alternatives is the heart of an EIS. In Citizens Against Burlington, Inc. v. Busey, the D.C. Circuit appears to have narrowed the scope of alternatives that a federal agency must consider when it issues a permit or other federal approval. This Article analyzes the case and proposes an interpretation that would reconcile Citizens Against Burlington with CEQ regulations and NEPA case law on the scope of alternatives.