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Marrin, Samantha S.  "Rough Seas Ahead for Alaska Cruises? The Judicial and Legislative Battle Over Glacier Bay," Fordham Environmental Law Journal, 2002, 13:2 (2nd qtr), 323-342

Cruise ships bringing tourists to view the natural beauty of
Glacier Bay provide an economic boon for Alaska. However, such tourism must be weighed against the protection of the very natural resource the ships seek to exploit. Relevant litigation is surveyed, highlighting the February 2001 decision handed down by the Ninth Circuit of the U.S. Court of Appeals which found that the federal government violated the law when it allowed the number of cruise ships sailing in Glacier Bay to increase from 107 to 138 during the height of the summer cruise season.