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Despite the vast mountain ranges, rivers, parks, coasts and forests within the bounds of its jurisdiction, the Second Circuit has had little occasion to decide many cases in the area of environmental law. Nonetheless, sufficient decisions do exist to indicate tentative outlines of the Second Circuit's disposition to date of such cases. On balance, the Second Circuit has carefully and conservatively hewed to the mandate of Congress in its construction of statutes, has mediated the competing demands of development and environmental protection, and has cautiously supported conservationists while sharply criticizing some of their tactics in administrative proceedings. This characterization can be traced from the early cases of nearly a decade ago through the several decisions which construed the National Environmental Policy Act of 1962, including the two cases treated in this issue of the Second Circuit Review.