In the first extensive judicial interpretation of the Marine Mammal Protection Act of 1972,¹ federal district court Judge Charles R. Richey has found that the National Marine Fisheries Service violated the Act by allowing continued killing of porpoises incidental to tuna fishing operations.² The court also declared void regulations promulgated by the Service and a general permit issued to the American Tunaboat Association to allow taking of porpoise during tuna fishing.³

One of the most novel enforcement mechanisms devised by the drafters of the Clean Air Act Amendments of 1970 was §304's "citizen suit" provision.¹ This section, variants of which were later incorporated in the Federal Water Pollution Control Act Amendments of 1972² and a number of other federal environmental statutes,³ authorizes any person to commence civil enforcement suits in federal district court.

The Environmental Law Institute has announced publication of A National Policy for the Environment: NEPA and Its Aftermath,¹ by Staff Political Scientist Richard A. Liroff. The book analyzes both enactment of the National Environmental Policy Act (NEPA) and the behavior of each of the key actors in its implementation.

The United States Supreme Court has undercut recent judicial¹ and scholarly² attempts to expand the use of programmatic impact statements under the National Environmental Policy Act (NEPA) in order to inject environmental factors more deeply into agency policymaking. In Kleppe v. Sierra Club,³ Justice Powell, writing for a seven-member majority, specifically disapproved the D.C.

In one of the most closely reasoned of its many end-of-term environmental law decisions, the Supreme Court held on June 1, 1976,¹ that Congress did not intend the 1972 Federal Water Pollution Control Act Amendments (FWPCA)² to transfer regulatory authority over nuclear materials in nuclear power plant effluents from the Nuclear Regulatory Commission (NRC)³ to the Environmental Protection Agency (EPA).

With its recent unanimous decision in Kleppe v. New Mexico,¹ the Supreme Court has probably written its last chapter in a half-century old controversy concerning the authority of the federal government to manage wildlife on federal lands.

In addition to its rulings in Kleppe v. Sierra Club,¹ Train v. Colorado Public Interest Research Group,² and Kleppe v. New Mexico,³ which are individually analyzed elsewhere in this issue, the Supreme Court rendered several other significant decisions in environmental cases as part of its end-of-term flurry of activity.

The Garrison Diversion Unit (GDU), a massive $496 million irrigation project in North Dakota sponsored by the United States Bureau of Reclamation, continues to receive widespread criticism because of its alleged adverse economic and environmental impacts.

Environmentalists have historically challenged only the domestic manifestations of nuclear power. The tangible fact of a nuclear power plant, together with a well-established regulatory system, lends itself to neighborhood mobilization and discrete legal fights. Recently, however, some environmentalists have ambitiously questioned a less visible aspect of the nuclear energy issue: exports of nuclear fuel destined for use in reactors operated in foreign countries.

On July 26, 1976, President Ford signed into law the Coastal Zone Management Act (CZM Act) Amendments of 1976,¹ a measure designed to improve the ability of the nation's 30 coastal states to plan for and control the impact of energy facility and resource development in their coastal areas. The Amendments, which several executive departments had vainly urged the President to veto, augment the present system of federal financial assistance for state development and implementation of coastal zone management programs.