In a far-reaching decision announced June 6, 1975,¹ District Court Judge John H. Pratt has ordered the Department of Interior to prepare, consider, and disseminate environmental impact statements on annual budget requests for financing the National Wildlife Refuge System. Judge Pratt found that such requests are "proposals for legislation" within the meaning of §102(2)(C) of the National Environmental Policy Act of 1969 (NEPA), and are also "major federal actions" that clearly have a significant effect on the environment. Furthermore, the decision orders the Director of the Office of Management and Budget (OMB), also a defendant in the action, to develop formal methods and procedures that will, with respect to OMB's own administrative actions and proposals, "identify those agency actions requiring environmental impact statements to be prepared, considered and disseminated."

The suit, brought by the Sierra Club and other environmental organizations in July 1974, challenged threatened cutbacks in federal ownership, management, and financing of the Refuge System. The System consists of more than 350 refuge units, totaling over 30 million acres of land and water, and is administered by the Fish and Wildlife Service, an arm of the Department of the Interior.