The court of appeals affirmed a judgment of the district court. The court held that an environmental assessment by the federal Bureau of Reclamation regarding a proposed draw-down of water from a lake properly accounted for the cumulative effects of past projects in satisfaction of the National Environmental Policy Act.

The Bureau of Reclamation and other federal agencies operated Lake Roosevelt, that portion of the Columbia River between the Grand Coulee Dam in the State of Washington and the Canadian border, in cooperation with state agencies and in accord with numerous treaties, statutes, and contracts.