dissenting:
I would affirm the district court’s decisions to enjoin construction of the pipeline from Lake Gaston to Virginia Beach, pending examination of its environmental impact by FERC, and to deny Virginia Beach’s motion to alter or amend the injunction. The majority states that it gives “due regard to the factual findings made by the [district] court” but that it is reviewing “the application of the holding in Gilchrist 1 to those facts” as an issue of law to be reviewed de novo, maj. at 601-02; however, I believe that the majority does more than merely review application of the Gilchrist holding. The Court today actually changes the legal standard applied by us and other courts in a way which, I believe, is inappropriate.
When a district court balances the hardships in considering whether to issue an injunction, we accept the district court’s factual findings unless they are clearly erroneous. South Carolina Dep’t of Wildlife & Marine Resources v. Marsh, 866 F.2d 97, 99 (4th Cir.1989); Capital Tool & Mfg. Co. v. Maschinenfabrik Herkules, 837 F.2d 171, 173 (4th Cir.1988). Since the district court correctly interpreted the law and properly applied the law to the facts, I would review the district court’s factual findings under the “clearly erroneous” standard and not conduct a de novo review. The district court’s balancing of the factors and decision to grant or deny an injunction is to be reversed only upon a showing of an abuse of discretion. Marsh, 866 F.2d at 99-100. The district court did not abuse its discretion; therefore, the court’s decisions to issue the injunction and to refuse to alter it should not be disturbed on appeal. See Quince Orchard Valley Citizens Ass’n v. Hodel, 872 F.2d 75, 78 (4th Cir.1989).
I.
In concluding that FERC’s examination of the impact of the pipeline project on the environment, pursuant to the National Environmental Policy Act (NEPA), 42 U.S.C. § 4332 (1988), “should have a preclusive effect” only on the portion of the pipeline within its jurisdiction, the majority states: (1) FERC only has “licensing power or veto power” over the portion of the project which would fall within Project 2009 (the Lake Gaston hydropower project), so, therefore, Virginia Beach could likely build a pipeline up to the edge of Lake Gaston without FERC approval; (2) the authority of Virginia Beach to build up to the edge of Lake Gaston without FERC approval stems in part from the lack of any FERC funding for or assistance with any portion of the pipeline outside Project 2009;2 (3) FERC is only required under NEPA to consider the environmental impact of its own actions, i.e., overseeing the portion of the pipeline project “that directly affects Project 2009.” See maj. at 604.
But to segment the problem into parts and to consider who has direct authority for each, standing alone, overlooks the spillover effect of one part on another part, i.e., their interrelationship. For the majori*607ty to emphasize the fact that FERC has no authority to prevent Virginia Beach from building over eighty miles of pipeline, with a pumping station, extending directly up to the boundary of the Lake Gaston hydro-power project operated by VEPCO under a license from FERC, is to underscore the principal reason why courts are sometimes called upon to enjoin activities of which only a portion requires a particular federal agency’s approval. In Maryland Conservation Council, Inc. v. Gilchrist, 808 F.2d 1039, 1042 (4th Cir.1986), we explained that an injunction may be necessary to prevent a non-federal actor from presenting a federal agency with a fait accompli. The highway at issue in Gilchrist had inevitably to cross a park which had been established with federal funds, and had almost certainly to cross wetlands within the park, for which federal approvals would be required. We reasoned that compliance with NEPA was mandatory before any portion of the highway, federally funded or not, could be constructed, regardless of the existence or non-existence of federal authority. Id. However, disputed issues of fact remained as to, for example, whether the roads which were under construction prior to completion of the NEPA review were necessarily to be part of the highway through the park, or were to be constructed for access to nearby subdivisions irrespective of whether the federal approvals were granted. Therefore, we remanded to the district court for further factual findings as to “whether any part of the County’s construction program is essential for access to the land, as the County claims, and whether the program in fact violates NEPA and its regulations by limiting ‘the choice of reasonable alternatives’ available to federal decision-makers. 40 C.F.R. § 1506.1(a)(2) (1985).” Gilchrist, 808 F.2d at 1043.
Even agreeing with the majority’s conclusion that FERC’s obligation under NEPA is limited to consideration of the environmental effects of the project directly within its jurisdiction, I would nevertheless conclude that the district court’s decision to issue the injunction was proper. Under Gilchrist, no part of the pipeline should be constructed which will present a federal agency with a fait accompli in considering portions within its jurisdiction, if it harms the environment or limits the reasonable alternatives. See also Arlington Coalition on Transp. v. Volpe, 458 F.2d 1323, 1333 (4th Cir.), cert. denied, 409 U.S. 1000, 93 S.Ct. 312, 34 L.Ed.2d 261 (1972) (“If investment in the proposed route were to continue prior to and during the Secretary’s consideration of the environmental report, the options open to the Secretary would diminish, and at some point his consideration would become a meaningless formality”). In the instant case, not only had FERC not yet granted approval for the construction of an intake facility and withdrawal of 60 million gallons of water per day, but Virginia Beach had intended to commence construction of the pipeline before an application was even submitted to FERC to begin the approval process.3 Moreover, North Carolina has contended both that the construction of the pipeline across federally protected wetlands will harm the environment and that *608construction prior to FERC’s approval forecloses options by locking in the design and route of the pipeline and by pressuring FERC to approve the project.
However, I am not persuaded that we are the appropriate body to determine that the effect of FERC’s review should be limited to the portion of the project under its direct jurisdiction. FERC announced in the Federal Register that it is required to consider not only that part of a project planned to be undertaken within its area of jurisdiction, but that it must examine the environmental impact of those portions of a project which are not directly within its own jurisdiction:
When [FERC] considers the environmental impact of a project subject to its jurisdiction, it also considers the environmental impact of nonjurisdictional facilities which are to be constructed with, or are an integral part of, the project involving jurisdictional facilities. [FERC] does this because [FERC] precedent, case law, and the CEQ [Council on Environmental Quality] regulations require [FERC] to consider the environmental impact of an entire project when considering whether to approve the portion of the project under the jurisdiction of [FERC].... [FERC] does not intend to exercise jurisdiction over nonjurisdictional facilities and is not using this process to exercise such jurisdiction. However, to ignore the environmental impact of these facilities when they are an integral part of an entire project that includes jurisdictional facilities would be to take too narrow a view of [FERC’s] NEPA responsibilities.
Regulations Implementing National Environmental Policy Act of 1969, 52 Fed.Reg. 47897, 47094 (Dec. 17, 1987) (footnote omitted). While the majority of the pipeline would be outside of the area in which FERC exercises jurisdiction, clearly it is “to be constructed with” or is “an integral part of” the project over which FERC would exercise jurisdiction, the intake facility at Lake Gaston and the initial portion of the pipeline. Thus, review of the entire pipeline would appear to be part of FERC’s responsibility under NEPA, absent any pri- or environmental review by the Corps of Engineers. The question, then, focuses on the extent to which FERC may or must rely on the environmental assessment conducted by the Corps in fulfillment of its own obligations.
Under the majority’s position, FERC is, in effect, absolutely bound by the environmental review conducted by the Corps, even though it dispensed with as unnecessary an environmental impact statement. While the nature of the environmental review may be left to the Corps to determine in the first instance, it will not be the last. North Carolina has contended that the environmental review which FERC is obligated to undertake differs significantly from the environmental assessment conducted by the Corps. First, under the Federal Power Act, FERC has a special duty to consider the impact of the project on the development of hydropower. See 16 U.S.C. § 803(a)(1) (1988) (FERC obliged to consider whether the proposed project is consistent with “a comprehensive plan ... for the improvement and utilization of water-power development, for the adequate protection, mitigation, and enhancement of fish and wildlife (including related spawning grounds and habitat), and for other beneficial public uses, including irrigation, flood control, water supply ... ”). Although the environmental assessment conducted by the Corps took account of various increased water uses, it did not include consideration of increased water use due to several proposed power plants in the Roanoke River Basin, one of which is already under construction. North Carolina has argued that consideration of the additional water usage due to the power plants and the pipeline’s impact on hydropower generation is incumbent upon FERC.
Second, an environmental review by FERC appears to require consideration of other developments which have occurred since the Corps conducted its review. The majority of the review undertaken by the Corps was conducted in 1983.4 Upon court *609order, the Corps in 1988 reconsidered only certain impacts of the pipeline.5 North Carolina has maintained that significant developments which have occurred since the Corps’ environmental assessment was performed, and which must be considered by FERC, include (1) changes in federal wetlands regulation, such that the area of wetlands affected by the pipeline has nearly doubled and the protections accorded to wetlands has increased; and (2) changes in population, land use, and water use which require analysis of water quality in the Roanoke River, including the river’s capacity to assimilate pollution if 60 million gallons per day are withdrawn.
Third, while the Corps concluded in its environmental assessment that preparation of the more extensive environmental impact statement was not necessary because the project would have no significant impact on the quality of the human environment, several state and federal agencies have indicated their positions that FERC is obligated to prepare an environmental impact statement before deciding whether to approve the project.6 Our review of the Corps decision not to prepare an environmental impact statement was “limited to a determination of whether the Corps’ decision was ‘arbitrary, capricious, otherwise not in accordance with law, or unsupported by substantia] evidence.’ ” Roanoke River Basin Ass’n v. Hudson, 940 F.2d 58, 61 (4th Cir.1991) (quoting 5 U.S.C. § 706(2)). Thus, the conclusion in the Corps’ environmental assessment that the project would not so significantly affect the human environment, such that a more searching study of its impact would have been necessary, would not necessarily be the conclusion of FERC when its approval is finally sought over eight years later.
The principle that a federal agency is not permitted to rely upon another agency’s examination of an action’s environmental effects to fulfill its obligations under NEPA is well-established. See The Steamboaters v. FERC, 759 F.2d 1382, 1393-94 (9th Cir.1985); Southern Oregon Citizens Against Toxic Sprays, Inc. v. Clark, 720 F.2d 1475,1480 (9th Cir.1983), cert. denied, 469 U.S. 1028, 105 S.Ct. 446, 83 L.Ed.2d 372 (1984); Oregon Environmental Council v. Kunzman, 714 F.2d 901, 905 (9th Cir.1983); Steubing v. Brinegar, 511 F.2d 489, 496 (2d Cir.1975); Calvert Cliffs’ Coordinating Comm., Inc. v. United States Atomic Energy Comm’n, 449 F.2d 1109, 1123 (D.C.Cir.1971). An agency with an obligation under NEPA “must independently assess the consequences of a project.” Steamboaters, 759 F.2d at 1394. Courts have yet to consider the extent to which one agency is permitted to rely on the judgmental decisionmaking involved in the environmental analysis undertaken by another agency when the other agency’s environmental assessment was upheld by a court as sufficient to satisfy its obligations under NEPA. However, the underlying principle enunciated by the case law suggests that a court should not determine in the first instance that an agency is bound by the environmental assessment of another agency under the circumstances presented here. An agency may not rely upon the certification by another agency that its environmental standards were met because certification of standards necessitates a different kind of judgment than the type of judgment required by NEPA; a NEPA *610judgment requires the weighing of a particular project’s environmental costs against its benefits. Calvert Cliffs’, 449 F.2d at 1123. While the Corps undertook the type of NEPA judgment which involved a weighing of the environmental costs against the pipeline’s benefits the balancing analysis which FERC is obligated to undertake is different; it may include a statutory obligation to consider the impact on hydropower, preparation of an environmental impact statement, and consideration of the changed circumstances inherent in conducting its review more than eight years after the majority of the Corps’ review was performed. Therefore, the extent to which FERC determines that it is prudent to rely on the Corps’ findings, and the extent to which FERC determines that additional studies are necessary, are matters which should be left to FERC to decide in the first instance.7
The decision of the district court to enjoin construction of the pipeline, pending FERC’s performance of its environmental review, properly preserved the opportunity for FERC to consider the environmental impact of the pipeline. The court, in its December 10, 1990 order, applied the four-part test of Blackwelder Furniture Co. v. Seilig Manufacturing Co., 550 F.2d 189, 196 (4th Cir.1977), as follows: (1) the irreparable harm to North Carolina if an injunction was not issued would be the construction of the pipeline prior to FERC’s conducting its own independent evaluation of the project’s environmental impact, and thus without FERC’s approval for the transfer of easements permitting construction of the intake facility and withdrawal of the water from Lake Gaston; (2) the harm of any delay in building the pipeline cited by Virginia Beach could not be attributed to issuance of an injunction due to other pending matters which might cause that particular harm; (3) the likelihood of success on the merits relates to the likelihood that plaintiffs would prevail in the request for a permanent injunction prohibiting construction pending FERC’s review, not to the likelihood that FERC’s decision would differ from that of the Corps; (4) the public interest in initiating construction immediately was unclear, since it could not be determined how much time would in fact be saved; however, “the public interest in a FERC decision uninfluenced by the vast expenditures of public funds and a partial completion of the project outweighs any anticipated delay. The public interest favors avoiding irreversible damage to the environment....”
In its analysis of the harm which would ensue if construction were not halted, the district court correctly interpreted our decisions in Maryland Conservation Council, Inc. v. Gilchrist, 808 F.2d 1039 (4th Cir.1986), and South Carolina Department of Wildlife & Marine Resources v. Marsh, 866 F.2d 97 (4th Cir.1989). The district court’s interpretation of the law was correct, and the findings cannot be deemed to be clearly erroneous. I would affirm the decision to enjoin construction of the pipeline pending approval by FERC. While approval is on one side ultimately quite possible, allowing construction to proceed prior to approval may as a practical matter foreclose refusal for what has become a fait accompli. The intent of Congress that FERC’s decision be fully unbiased would be frustrated.
II.
In overturning the district court’s refusal to amend the injunction, the majority sets forth a new standard for determining whether construction of those portions of a public works project which lie beyond the jurisdiction of a federal agency should be enjoined pending completion of the federal agency’s environmental review pursuant to NEPA. The majority examines the record for facts demonstrating a “direct and substantial probability” that the construction of six overhead river-crossings and part of a pump station would influence FERC's decision. See maj. at 603. In concluding that nothing in the record indicates that this construction would influence FERC’s *611decision, the majority cites the following factors: (1) Virginia Beach stated that it was willing to forego the $8.4 million it would expend on this phase of construction, and thus “knowingly accepted the risk” that FERC might refuse to approve the project;8 (2) FERC announced in the Federal Register that expenditures prior to approval of a project will not influence its decisionmaking; (3) the project involves a “relatively minor” expenditure of $8.4 million,9 yet would save significant time and expense for Virginia Beach if begun in advance. See maj. at 603-04.
After discussing the factors, the majority engages in a flawed argument. First, the majority misstates the current rule; then claims that the rule, as so misstated, logically leads to absurd results; and then issues its new standard. Specifically, the majority states: “If the rule were such that any construction that could, in even the smallest degree, bring public and political pressure on agencies is prohibited until final agency approval of all aspects of the project, the prohibition would logically extend to any de minimis construction.” Maj. at 603. Then the majority shows an absurd result of its misstatement of the current standard: “In this case, for example, it might extend even to surveying and unrelated construction which might increase the demand for water. That is not the intended reach of Gilchrist.”10 Id. Finally, the majority announces its new standard: “Thus we hold that construction which lies beyond the boundaries of FERC’s jurisdiction can be enjoined only when it has a direct and substantial probability of influencing FERC’s decision.”11 Maj. at 603. Applying such new standard, the majority concludes: “Against that standard, the reach of the injunction entered here, in prohibiting the two relatively minor phases of construction sought in Virginia Beach’s motion to alter or amend, cannot as a matter of law be justified.” Maj. at 603.
While it may be impossible to express our approach in a pithy statement, the proper “rule,” which I advocate, clearly is not that “any construction that could, in even the smallest degree, bring public and political pressure on agencies is prohibited until final agency approval of all aspects of the project_” See maj. at 603. The analysis which the Fourth Circuit has developed instead is more akin to the regulations adopted by the Council on Environmental Quality to implement NEPA; the factors we have considered focus more closely on the elements adopted by the regulation which prohibits actions prior to compliance with NEPA which would “[h]ave an adverse environmental impact” or “[ljimit the choice of reasonable alternatives.” See 40 C.F.R. § 1506.1(a) (1990); see also South Carolina Dep’t of Wildlife & Marine Resources v. Marsh, 866 F.2d 97 (4th Cir.1989); Maryland Conservation Council, Inc. v. Gilchrist, 808 F.2d 1039, 1042 (4th Cir.1986); Arlington Coalition on Transp. v. Volpe, 458 F.2d 1323 (4th Cir.), cert. denied, 409 U.S. 1000, 93 S.Ct. 312, 34 L.Ed.2d 261 (1972).
Construction, whether de minimis or not, which would demonstrably neither adversely affect the environment nor limit the available choices, even if it would bring pressure on the agency, would not necessarily be enjoined under the standard set by those precedents. See, e.g., Marsh, 866 F.2d at 100 (installation of generators permitted even though plaintiff contended that expenditures would foreclose the agency’s options, in part because plaintiffs conceded that installation would have no adverse en*612vironmental impact). And yet the majority’s new standard, involving a search for evidence that pre-approval construction would have a “direct and substantial probability” of influencing FERC’s decision, fails adequately to account for those two considerations.
Furthermore, even were I to conclude that the majority’s standard was proper, I would nonetheless remand to the district court for the requisite findings of fact in light of the new standard. I find that the majority accepted too readily the claim of factors which supposedly indicate that FERC’s decision will not be prejudiced by construction of the pipeline. For example, the majority relies on FERC’s statement in a Notice of Proposed Rulemaking that it would not be influenced by pre-approval expenditures. See maj. at 601-02 (discussing 52 Fed.Reg. 20317 (1987)). In context, however, the warning appears in a different light. The statement appears in a discussion about the intent and language of regulations proposed by the Council on Environmental Quality. FERC first noted that under the proposed regulation, appearing now at 40 C.F.R. § 1506.1(a) (1990), any steps undertaken prior to FERC’s approval of a proposal which would limit the choice of reasonable alternatives or have an adverse environmental impact would be prohibited, not merely disregarded. A commentator contended that FERC lacks authority to prohibit an otherwise lawful act occurring outside its jurisdiction. In response, FERC stated that it “can act directly or indirectly to enjoin or otherwise stop unauthorized activities directly related to a project or action within its jurisdiction.” 52 Fed.Reg. 20317 (emphasis supplied). Thus, FERC exhibited an intent to prevent a project from going forward prior to FERC’s compliance with NEPA-mandated environmental reviews, including those portions of the project falling outside its direct jurisdiction. FERC then stated that, in the process of approving a project, it would disregard any argument that a project should be approved because of pre-approval expenditures, id., an expression of attitude which has some of the aspects of whistling in the dark. Clearly, the overall goal of FERC as expressed in the statement is to prohibit actions prior to approval which would limit its reasonable alternatives or have an adverse environmental impact. Moreover, that the $8.4 million, on top of the $18.1 million already spent, would be rendered of little or no value raises a weighty political argument against the likelihood that FERC would disregard pre-ap-proval expenditures.
Similarly, the majority accords undue weight to the declaration by Virginia Beach that it is willing to forego its investment of such a large amount in the pipeline in the event that FERC does not approve the project. The notion of what it means to pressure a decision by limiting an agency’s alternatives or foreclosing its options, once so much in the way of resources has been committed by the agency itself or by another party, should be applied in a way which better takes into account the reality of bureaucratic decisionmaking. See, e.g., Sierra Club v. Marsh, 872 F.2d 497, 504 (1st Cir.1989) (taking account of “the psychology of decisionmakers,” the “difficulty of stopping a bureaucratic steam roller,” and the “deeply rooted human psychological instinct not to tear down projects once they are built”); Realty Income Trust v. Eckerd, 564 F.2d 447, 456 (D.C.Cir.1977) (injunctions prior to compliance with NEPA “preserve for the agency the widest freedom of choice.... Behind the insistence on preserving the status quo for the agency, even at the costs of an injunction, is the shared assumption by the courts that they should not prejudge the reconsiderations that agencies will make once the full environmental consequences of the action have been determined”) (emphasis in original).
I conclude, consequently, that the district court correctly denied the motion to alter or amend the initial injunction. Virginia Beach has contended that the district court misread our decision in Marsh and thus mistakenly placed undue emphasis on the amount of the expenditures and the potential to pressure FERC’s decision. The district court in its order of January 4, 1991 did state that the expenditures were a *613factor in its decision to deny the motion to alter or amend the injunction:
As this court interprets Gilchrist, federal regulatory agencies, such as FERC, should not be presented with public and political pressure brought on by partially completed projects in making important environmental decisions under the National Environmental Policy Act (NEPA), 42 U.S.C. §§ 4321 et seq. Defendant has already spent $18.1 million on this project. Although $8.4 million may be a small part of the total $218.9 million price, it at least becomes more significant when added to the $18.1 million already spent.
(Emphasis in original). However, unlike in Marsh, where we found that the pressure which may be created by expenditures on installation of generators prior to compliance with NEPA was insufficient to warrant an injunction in the absence of any detrimental impact on the environment, see Marsh, 866 F.2d at 100, the district court in the instant case had already found that construction of the initial phases of the pipeline would cause irreparable environmental harm. See Order of the District Court of December 10, 1990.
Therefore, I respectfully dissent and would affirm both decisions of the district court.
. Maryland Conservation Council, Inc. v. Gilchrist, 808 F.2d 1039 (4th Cir.1986).
. At this point in the discussion about the limited effect of the NEPA review to be conducted by FERC, the majority mentions that the only federal involvement in the pipeline outside of Project 2009 is that of the Army Corps of Engineers, and notes that the Corps already has performed an environmental review deemed by the district court and the Fourth Circuit to be sufficient under NEPA. See maj. at 605 (citing Roanoke River Basin Ass’n v. Hudson, 940 F.2d 58 (4th Cir.1991)). However, the logical relationship between the fact of the Corps’ environmental review and the limited effect of FERC's NEPA review is only drawn after the majority concludes that FERC is not required to review the impact of the pipeline beyond the limited area of its own direct jurisdiction. The majority states that such a conclusion “is consistent with” the fact that the Corps conducted an environmental review which was upheld by the courts as sufficient to satisfy the obligations of NEPA. Notably, however, the majority's conclusion that the effect of FERC's environmental review is limited to the area within its direct jurisdiction is not made dependent on the fact that a NEPA review was already performed by the Corps. See maj. at 605.
. North Carolina has argued that FERC must consider the proposed change in the Lake Ga-ston project as an amendment to VEPCO’s license under 16 U.S.C. § 803(a)(1) and 18 C.F.R. § 4.200. In contrast, Virginia Beach has argued that FERC need only approve the conveyance of easements from VEPCO to Virginia Beach. Nonetheless, both parties agree that FERC approval is required, and we have been asked by both parties to assume that such approval is a "major Federal action" requiring compliance with NEPA mandated environmental reviews.
Virginia Beach has stated that it attempted to initiate the FERC application process in 1984 after the Corps issued its permit, but that VEPCO refused to initiate the application until the district court affirmed the Corps permit. When this matter came before the district court on December 6, 1990, Virginia Beach and VEPCO were in the process of preparing an Application for the NonProject Use of Project Lands and Waters for VEPCO to complete and file. Upon FERC’s recommendation, Virginia Beach and VEPCO had prepared a draft environmental report and submitted it to various federal, state and local agencies for comments. Although the application to FERC had not been filed, Virginia Beach had awarded two of eleven construction contracts, one for six overhead river crossings and one for 6.9 miles of pipeline. The district court issued its injunction on the *608day that construction was scheduled to begin, December 10, 1990.
. The Corps report concludes that “no significant effects” on any of the following conditions *609could be anticipated: navigation, flooding, hydrology, water quality, wetlands, fish and wildlife, erosion and accretion, food and fiber production, recreation, cultural values, aesthetics, energy needs, water supply or socioeconomics.
. The Supplemental Statement of Findings prepared by the Corps addressed effects of the pipeline and diminished water flow on the striped bass downstream of Lake Gaston and the extent of Virginia Beach’s water needs.
. In their comments upon the Virginia Beach/ VEPCO draft environmental report, the following agencies stated that FERC should conduct further studies and prepare an environmental impact statement before granting approval of the pipeline project: the Fish and Wildlife Service of the United States Department of the Interior; the National Marine Fisheries Service of the United States Department of Commerce; and the Division of Marine Fisheries, the Division of Water Resources, and the Division of Environmental Management, all of the Department of Environment, Health, and Natural Resources of the State of North Carolina.
. At the very least, an application should have been made to FERC to determine the extent to which it accepts, in lieu of its own efforts, the study by the Corps, and will be bound thereby.
. For such a politically charged and expensive undertaking, complete obedience to Virginia Beach’s acceptance of the risk, without doubting the good faith of the undertaking when made, is questionable.
. But is $8.4 million, accompanied by $18.1 million already spent, truly a relatively minor expenditure?
. No such extension is here involved. Moreover, nothing in our previous decisions suggests that an injunction would extend to any activity beyond either the proposed project itself or integral parts of the overall project — a logical and easy line to draw.
. Again the question presents itself: Why has no attempt adequately to learn FERC's own position on the subject been made?