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Mintz, Monica.  "National Parks and Conservation Association v. Babbitt: Titanic Mess, Restricting Cruise Ships in Order to Protect Glacier Bay," Villanova Environmental Law Journal, 2003, 14:2, 325-247

The National Parks and Conservation Association (NPCA) brought suit against NPS in 2001, charging that the agency failed to follow guidelines pursuant to NEPA when it increased the amount of cruise ship traffic to Glacier Bay, AK. The NPCA emphasized that preservation of the diverse environment of
Glacier Bay outweighed any economic benefit from tourism. The Ninth Circuit ruled to restrict the number of cruise ships that can enter the bay. The cruise ship industry must now wait for completion of an environmental impact statement and hope that no major impact is documented before sending a larger number of ships to the bay.