One aspect of the National Environmental Policy Act (NEPA) which has attracted surprisingly little judicial attention is the requirement for preparation of an environmental impact statement (EIS) on "every recommendation or report on proposals for legislation."¹ Commentators have suggested that the difficulty of formulating appropriate relief in a suit to compel preparation of such a statement is the principal reason for the dearth of litigation on this point.² Three recent court decisions in suits by private parties seeking to enforce this NEPA requirement illuminate some of the unresolved problems and suggest possible avenues for fuller implementation of this aspect of the Act.