Environmental watchdogs awaited with some concern the two National Environmental Policy Act (NEPA)¹ decisions of the Supreme Court during its 1988-1989 term. The issues were important, and the Court had not been especially kind to NEPA in the past. The Court's decisions in the two cases, Robertson v. Methow Valley Citizens Council² and Marsh v. Oregon Natural Resources Council,³ came down on May 1, 1989. The environmental plaintiffs did not win, but the Court, in unanimous decisions written by Justice Stevens, clearly endorsed the statute. Indeed, Justice Stevens wrote that "NEPA declares a broad national commitment to protecting and promoting environmental quality."⁴