The Garrison Diversion Unit (GDU), a massive $496 million irrigation project in North Dakota sponsored by the United States Bureau of Reclamation, continues to receive widespread criticism because of its alleged adverse economic and environmental impacts. The Environmental Protection Agency (EPA), Council on Environmental Quality (CEQ), and the House Government Operations Subcommittee on Conservation, Energy, and Natural Resources (Subcommittee) have requested a moratorium on project construction, of which 20 percent has been completed, pending full analysis of ecological hazards.¹ Other organizations, including the United States Fish and Wildlife Service, the South Dakota Legislature, the Minnesota Pollution Control Agency, and The Institute of Ecology have challenged the need for further work on the project. The most formidable challenge, however, may be a suit recently filed by the National Audubon Society which seeks to enjoin project-related purchases, site preparation, and construction because of alleged violations of the National Environmental Policy Act (NEPA) and other environmental statutes.²