Abstract : On September 17, 2002, the latest skirmish in an ongoing battle over the extra-territorial application of the National Environmental Policy Act (NEPA) was fought in the U.S. District Court for the Central District of California, pitting the Natural Resources Defense Council and other environmental groups against the United States Navy. On a day that found both environmentalists and the Department of Justice claiming victory, Judge Christina A. Snyder held that the U.S. Navy's Littoral Warfare Advanced Development (LWAD) Program as a whole was not subject to NEPA, but that individual sea tests under the program are. More important, however, was her holding that NEPA applies to federal actions that may affect the environment within the 200 nautical mile Exclusive Economic Zone (EEZ). In this paper I will examine Judge Snyder's holding in light of the legislative intent behind NEPA, the executive interpretation expressed in Executive Order 12,114, and case law regarding the extra-territorial application of NEPA. Additionally, I will discuss the precedential weight that NRDC v. United States Department of the Navy should be given in future cases and whether the uncertainty surrounding the extraterritorial application of NEPA is now any clearer. Finally, I will conclude with recommendations designed to bring clarity and uniformity to the application of NEPA worldwide.