Sections of the Federal Power Commission's procedural compliance guidelines for the implementation of the National Environmental Policy Act have recently been struck down by the Court of Appeals for the Second Circuit in Greene County Planning Board v. Federal Power Commission, 2 ELR 20017 (2d Cir. Jan. 17, 1972). Although the FPC has continued to resist complying with the court's order in other proceedings, and although a number of other federal agencies have procedural compliance guidelines that echo the deficiencies struck down in Greene County, there can be little doubt that the Second Circuit was correct in interpreting NEPA as forbidding the delegation of drafting impact statements to persons other than the "responsible federal official" Other creative devices are available to agencies wishing to use the resources of private applicants in gathering the information necessary to conduct a thorough, intelligent NEPA analysis.