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.

Hard cases make bad law. So do unique, serpentine factual patterns.

In June 1975, Congress finally diverted the Bureau of Reclamation's Garrison Diversion Unit, a massive irrigation project with potentially catastrophic environmental and diplomatic impacts.

On July 25, 1975,¹ the Army Corps of Engineers promulgated interim final regulations governing the granting of permits for activities in United States inland and ocean waters, including, inter alia, the discharge of dredged and fill materials. The Corps' action came in response to a court order² invalidating the agency's previous rules that restricted its regulatory jurisdiction over the latter category of activities to "navigable waters" as traditionally defined.

Man has been dumping his wastes into the oceans since time immemorial, but the quantity and toxicity of these discharges has increased steadily as our industrial society has become more complex. Though scientists have just begun to study the environmental impact of these personal and industrial wastes and though tracking the paths of discharged metals and bacteria through shifting ocean currents is a frustrating and difficult task, the results thus far obtained from such investigation are not encouraging.

"Only Nixon loves a coyote" seems to be the message of recent political developments in Washington sanctioning increased use of sodium cyanide devices to kill these and other predators. To be specific, President Ford recently relaxed stringent limits imposed by his predecessor in a 1972 Executive Order¹ on the field use of toxic chemicals in federal programs against coyotes and other predators on federal lands, which form a large part of the habitat of the coyote in five southwestern states.

The Environmental Law Institute recently concluded an eight-month study of enforcement under the Federal Water Pollution Control Act Amendments of 1972 for the National Commission on Water Quality. The Institute's report was part of the Commission's effort under §315 of the Act to review issues related to the Act's implementation;¹ a draft Commission report to Congress is expected this fall.

The Environmental Law Institute has recently initiated a year-long National Science Foundation-funded project to investigate impediments to and incentives for solar energy development.

The question of whether and how to control growth has come to the fore in the last several years as one of the broadest and most serious environmental issues facing the United States.¹ In the area of land use, this abstract question reduces to the dilemma of managing or controlling the rapid and chaotic development at the perimeters of metropolitan centers that has drastically reshaped the face of our nation since 1945.

A pair of amendments to the National Environmental Policy Act has recently been signed into law. One of the acts, Public Law No. 94-83, seeks to clarify federal and state roles in preparing environmental impact statements, and will have a significant bearing on future litigation directed at NEPA statements on federal aid highway projects and other federal actions. The second act authorizes 1976 appropriations and several minor administrative changes for the Council on Environmental Quality, of interest primarily to the Council itself.