One key example of this phenomenon was the Rio Conference on Environment and Development. 313 314 TFLR-ENVIRONMENTAL LAW rvoL 8:313 Moreover, in an attempt to address the problem of protecting the earth from environmental; degradation, govenunents around the world have enacted environmental laws and participated in international treaties and multilateral agreements dealing \Vith environmental issucs.j In keeping with that trends, in 1970, Congress enacted the National Environmental Policy Act (NEPA) 6 to "declare a national policy \vhich will encourage productive and enjoyable harmony between man and his environment. " 7 NEPA requires federal agencies to complete an environmental impact statement (EIS) before participating in "major Federal actions significantly affecting the quality of the human environment." 8 In preparing an EIS, the agency is required to consider the possible adverse effects of the project, methods of mitigating potential damage, and less destructive alternatives. 9 Although NEPA is often referred to as the Magna Carta of environ mental la\v, federal agencies have tended not to comply with its mandates when their actions extend beyond the United States borders. For example, according to Worldv.•atch Institute, the United States Air Force and Navy have dumped large quantities of trichloroethylene, a carcinogenic solvent, in Guam. Those actions led to the contamination of the aquifer that supplies drinking water to three-quarters of the island's population. 10 Else\vhere overseas, various federal agencies support projects such as hydroelectric development, mining, and pesticide spraying without preparing an environmental impact statement to consider the environmental consequences of such actions. 11 In an attempt to justify their noncompliance Groy, supra at 7.
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