This Comment was originally presented at the 2014 Lloyd K. Garrison Lecture on Environmental Law on March 26, 2014, at the Pace University School of Law. For more about the lecture series, see

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In 1995, Professor of Law David Sive and Pace’s Law Faculty established this lectureship, in honor of Lloyd K. Garrison, to commemorate Scenic Hudson Preservation Conference v. Federal Power Commission.1 Known as the Storm King case, this ruling inaugurated what we today call environmental law. Two individuals above all others guided and framed the jurisprudential foundations for environmental law. We honor these founders today. Their lives were intertwined.