Environmental Defense Fund v. Tennessee Valley Authority

In Environmental Defense Fund v. Tennessee Valley Authority, plaintiffs began this action to enjoin the Tennessee Valley Authority (TVA) from completing construction of the Tellico Dam Project, which would affect Fort Loudoun, a historic fort, and some archeological sites. The court had granted a preliminary injunction directing the agency to comply with the National Environmental Policy Act (NEPA). TVA then prepared an environmental impact statement (EIS) under NEPA that plaintiffs alleged was inadequate.

The court dissolved the preliminary injunction, finding that the environmental impact statement was adequate. TVA had conducted archeological surveys of the project area and included in the EIS a sufficiently detailed discussion of the effects of the project on historic properties. Without further explanation, the court concluded that both the EIS and the evidence showed that TVA had complied with the National Historic Preservation Act.