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ness under governmental agency contracts or licenses. Although the process has been criticized by many of the groups affected, most studies of NEPA’s effectiveness have concluded that it has forced greater governmental awareness and more careful planning in many agencies. Several major issues pervade an analysis of the EIS requirement, ranging from who must file the EIS, and when, to disputes over what must be included in the statement, to whether the process is effective. Threshold Considerations Every time a federal agency undertakes an activity, it must decide whether to file an EIS. Filing an unnecessary EIS is a waste of time and money. Failure to file a necessary statement can be equally or more expensive if someone challenges the lack of an EIS and seeks an injunction. However, it is not always easy to know when an EIS is required. NEPA specifies three conditions that must be met for an EIS to be required. First, the activity must be federal. A federal activity is fairly broadly defined. If, for example, a private sector construction firm wants to construct a building that requires a government license or if the project is going to be partly financed by a government loan, the licensing or lending agency is undertaking a federal activity. Whether an EIS is required for a federal activity depends on whether the other two criteria are met. The federal activity must be major. There are no dollar guidelines as to what constitutes a major activity. The courts generally say that the activity requires a substantial mitment of resources, with resources being broadly defined to include both financial and human resources. A substantial mitment of either type of resources is sufficient. The third criterion is that the proposed activity must have a significant impact on the human environment. The phrase significant impact on the human environment is so ambiguous that it initially generated substantial litigation. Then, in 1979 the CEQ 7 tried to resolve some of the controversy by adopting a series of guidelines for the imp