Editors' Summary: The Wisconsin v. Weinberger litigation over the Navy's extremely low frequency submarine communication facility has produced three views of the courts' equitable discretion to refrain from enjoining NEPA violations. The district court held it had little discretion, while the judges on the Seventh Circuit put forth two views granting the courts a freer hand in balancing public interests in granting relief. The Comment examines these opinions and the competing judicial policies behind them: the protection of the courts' traditional equitable powers versus the separation of judicial and legislative functions. The author concludes that courts must accept the legislative declarations of public policy in NEPA and deny relief from violations only when the relief would disserve those goals.