Congress intended for the National Environmental Policy Act to have a major impact on the manner in which the federal government formulates national policy affecting the environment. To achieve this result, NEPA declares a separate national environmental policy and sets out the obligations of federal agencies toward full implementation of that policy. No part of the NEPA process is more important to sound federal policymaking than the requirement of §102(2)(C)(iii) and §102(2)(D) that agencies fully consider alternative courses of action before setting federal policy. NRDC v. Morton reaches deeply into the meaning of this requirement and puts agencies on notice that if the actions that they propose to carry out have not been sufficiently examined in the light of the national environmental policy, the proposed actions may be held up until a full review of alternatives, basic underlying policies, and resource commitments takes place.

The decision, however, does not fully discuss the available techniques for making NEPA serve in the evaluation of federal policies affecting the environment. This Comment explores two promising avenues open to government: full implementation of the already-existing NEPA requirement that agency legislative proposals be accompanied by impact statements, and impact statement preparation by the Executive Office of the president or ad hoc interagency task forces. Several "tiers" of impact statements that overlap essentially the same programs may occur when NEPA is fully implemented in federal policymaking. The Comment closes with a discussion of why redundancy and excessive paperwork need not overload the federal process as NEPA is fully implemented.