In a decision reaffirming the Interior Department's Atlantic Outer Continental Shelf (OCS) oil and gas leasing procedures, the Second Circuit Court of Appeals, in County of Suffolk v. Secretary of the Interior,¹ reversed a lower court's nullification² of Interior's first sale of Atlantic OCS exploration leases. The court concluded that the district court erred in finding that the requirements of the National Environmental Policy Act (NEPA) had been violated. Instead, the court of appeals ruled that the environmental impact statement (EIS) for the lease sale contained sufficient information on the environmental consequences of the proposed action to fulfill thestatutory requirements given the fact that the sale alone did not constitute an irrevocable commitment to ultimately allow OCS oil and gas development.