A suit brought by the Sierra Club against the Department of the Interior and the Office of Management and Budget (OMB)¹ raises for the first time the question where NEPA's requirement for environmental impact statements applies to the annual general appropriations process of the federal government. Specifically, the suit seeks a finding that the Department must prepare an environmental impact statement (EIS) on appropriations proposals to Congress for the National Wildlife Refuge System, and a further finding that OMB must establish NEPA compliance procedures with respect to these appropriations proposals.

The suit grew out of the strong concern of members of the Sierra Club and a number of other conservation organizations over threatened cutbacks in federal ownership, management and financing of the Refuge System. The System consists of more than 350 individual refuge units totaling over 30 million acres of land and water, selected primarily on the basis of their value as habitat for wildlife populations, particularly migratory birds and rare animals. Administrative responsibility over the system is exercised by the U.S. Fish and Wildlife Service.