The United States Supreme Court has undercut recent judicial¹ and scholarly² attempts to expand the use of programmatic impact statements under the National Environmental Policy Act (NEPA) in order to inject environmental factors more deeply into agency policymaking. In Kleppe v. Sierra Club,³ Justice Powell, writing for a seven-member majority, specifically disapproved the D.C. Circuit's attempt to quicken program impact statement timing by requiring commencement of statement preparation where programmatic major federal action is shown to be imminent, even though the agency denies that it is contemplating a program. The Court also concluded that, except in rare cases, agencies determinations of the proper geographical scope of such impact statements in situations involving multiple private proposals for action are entitled to judicial deference. And it rejected the suggestion, discussed with favor by the court of appeals, that NEPA imposes substantial comprehensive planning duties on federal agencies.