There continues to be sUbstantial disagreement as to whether or not the National Environmental Policy Act [hereinafter NEPAl, applies to federal activities abroad. The federal court cases on this matter are less than clear and have come short of saying NEPA does not apply overseas. Further, there has been a growing awareness of the effects of a nation's activities, programs and policies on the environment. International environmental law is evolving. The number and severity of environmental problems with global implications have increased. As a result of the increasing recognition by nation states of the interdependence of activities on the human environment, national legislation has been enacted to regulate activities within and outside a country's borders. Additionally courts are reconsidering prior judicial decisions in light of this new legislation and international environmental regime.