The large number of federal facilities throughout the nation—military bases, nuclear fuel plants, the TVA, the Bonneville Power Administration—contribute significantly to ambient environmental pollution. Various efforts have been made at the federal level to bring federal facilities into conformity with federal and state pollution standards, but the problem still persists. Congress clearly indicated its dissatisfaction with this state of affairs by including identical language in the Clean Air Act Amendments of 1970 (§118),¹ the Federal Water Pollution Control Act Amendments of 1972 (§313),² and the Noise Control Act of 1972 (§4)³ mandating federal compliance with "Federal, State, interstate, and local requirements respecting control and abatement of pollution to the same extent that any person is subject to such requirements." Unfortunately, however, the precise meaning of this congressional command as it regards the extent of state jurisdiction over federal facilities in order to ensure such compliance is not so clear. On February 10, 1975, the Ninth Circuit became the latest court to step into these murky waters when it held in California v. Environmental Protection Agency⁴ that federal agencies and enclaves that discharge water pollutants within California and Washington are required by this language in the FWPCA to seek NPDES permits from the appropriate state regulatory bodies.