Opinion filed by MacKINNON, Circuit Judge, concurring in part and dissenting in part.
Opinion for the Court filed by LEVENTHAL, Circuit Judge.
LEVENTHAL, Circuit Judge:
The central legal issue in this case is whether and on what occasions the National Environmental Policy Act (NEPA) requires an agency to prepare an environmental impact statement (EIS) to accompany its annual budget request for the operation of a program having significant environmental consequences.
The particular program that occasioned the lawsuit is the National Wildlife Refuge System (sometimes referred to as System, or NWRS). The System is administered by the Department of the Interior’s Fish and Wildlife Service (sometimes referred to as Service, or FWS).
Since the commencement of this suit, the FWS has prepared a programmatic environmental statement on the program which covers operation of the NWRS for the next ten years, centering on a projection of a roughly constant level of funding. No challenge has been made to the adequacy of this EIS. Rather, plaintiffs obtained, and now seek affirmance of, the district court’s declaratory ruling that an EIS adequate to then existing circumstances is required with each annual budget request. We reject this per se position and hold that the statement prepared by the Service satisfies its NEPA obligations, subject to any future decision of the agency to reevaluate the program or a drastic change of circumstances affecting the operation of the program.
We affirm the district court’s other declaratory ruling that the Office of Management and Budget (OMB) is required to develop procedures to fulfill its NEPA obligations in connection with the Budget process.
I. BACKGROUND
A. The National Wildlife Refuge System
The National Wildlife Refuge System consists of more than 350 refuges containing more than 30 million acres in 49 of the 50 states. The primary purposes of the NWRS are to preserve endangered species and to sustain populations of migratory birds, particularly waterfowl, by maintaining intact a diverse network of their natural habitats. A secondary purpose of the System is to provide for its educational and recreational use (study, observation, and hunting) by people.
The System is administered by the Service according to the provisions of several statutes.1 Much of the refuge land was acquired during the 1930’s. After a period of little growth during the 1940’s and 50’s, the System has been enlarged during the 60’s and to the present, particularly in the area of wild rivers and of wetlands. (There has recently been increasing recognition of the contribution to the preservation of important wildlife made by wetlands, which have been rapidly depleted.) During this period of territorial growth, new statutory mandates (such as the Endangered Species Act of 1973, 16 U.S.C. §§ 1531-1543), and increased public use of the NWRS, the resources devoted to staff and maintain the Refuge System have not kept up with the rate of territorial growth.2 Between 1973 and 1976, there was a 7% decrease in staffing, while the number of field stations in[898]*898creased by 10 percent.3 This has led to a substantial ($83 million) backlog of rehabilitation work, as well as unfulfilled construction work, new and replacement, e. g., water control structures, roads, and buildings.4 Given the policy decision to plan for roughly constant total expenditure (approximately $43 million in 1974 dollars), the FWS focuses on a strategy of increasing the effectiveness of the NWRS in its primary conservation task, while gradually reducing its direct use by the public. The Service’s statement (FES) analyzes the environmental consequences of this proposed strategy, alternatives, and mitigating measures.
B. Plaintiffs’ Contentions
Plaintiffs are three environmental organizations. Their standing will be discussed subsequently. They advance two arguments that section 102(2)(C) of NEPA5 obligates the Service to prepare an EIS on each annual budget request for the System: (a) that past and present proposals to cut down on NWRS operations are “proposals for legislation . significantly affecting the quality of the human environment . . . or (b) that the NWRS is so vital to protection of the environment that the annual proposal on the scope and nature of its operation per se “significantly affect[s] the quality of the human environment.”
Plaintiffs further contend that section 102(2)(B) of NEPA6 requires OMB to develop procedures to assure consideration of environmental factors in the budget process, including identification of which budget requests have significant environmental consequences and what is required of the agencies of the executive branch in submitting these requests to OMB.
C. District Court Decision
The district court granted summary judgment for the plaintiffs7 on the basis of the per se argument concerning budget proposals for operation of a major environmental program such as the NWRS. The court relied on the guidelines implementing NEPA issued by the Council on Environmental Quality (CEQ). These guidelines explicitly include “requests for appropriations” within the definition of “action” for NEPA purposes.8 The court also relied on cases requiring an EIS in connection with the request for appropriations to construct [899]*899or otherwise initiate a specific project.9 The court took note of the programmatic environmental statement being prepared by the defendants, but held that since it was directed at the long range goals of the NWRS, it would not satisfy the NEPA requirement of an analysis specifically directed to the proposed action in a “finely tuned” manner.10 Accordingly, the district court granted the plaintiffs declaratory relief that the defendants were in violation of NEPA, that an EIS was required on the annual budget proposal for the NWRS, and that OMB was required
to develop formal methods and procedures which will, with respect to the Office’s own administrative actions and proposals, identify those agency actions requiring environmental statements to be prepared, considered, and disseminated.11
II. STANDING
The defendants challenge the summary judgment granted to plaintiffs in view of their failure to adduce proof of injury in the face of defendants’ denial of plaintiffs’ standing and assertion of a disputed factual issue as to their injury.12 Plaintiffs alleged in their complaint that their members use the Refuge System and are affected by the environmental impact of the proposal concerning the operation of the System.13 Alternatively, plaintiffs assert that their organizational interests in disseminating the information which NEPA requires the proposing agency to compile and disclose provide standing under SIPI, supra note 8, 481 F.2d at 1087 n. 29. These allegations were not supported by affidavits in plaintiffs’ motion for summary judgment.
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Opinion filed by MacKINNON, Circuit Judge, concurring in part and dissenting in part.
Opinion for the Court filed by LEVENTHAL, Circuit Judge.
LEVENTHAL, Circuit Judge:
The central legal issue in this case is whether and on what occasions the National Environmental Policy Act (NEPA) requires an agency to prepare an environmental impact statement (EIS) to accompany its annual budget request for the operation of a program having significant environmental consequences.
The particular program that occasioned the lawsuit is the National Wildlife Refuge System (sometimes referred to as System, or NWRS). The System is administered by the Department of the Interior’s Fish and Wildlife Service (sometimes referred to as Service, or FWS).
Since the commencement of this suit, the FWS has prepared a programmatic environmental statement on the program which covers operation of the NWRS for the next ten years, centering on a projection of a roughly constant level of funding. No challenge has been made to the adequacy of this EIS. Rather, plaintiffs obtained, and now seek affirmance of, the district court’s declaratory ruling that an EIS adequate to then existing circumstances is required with each annual budget request. We reject this per se position and hold that the statement prepared by the Service satisfies its NEPA obligations, subject to any future decision of the agency to reevaluate the program or a drastic change of circumstances affecting the operation of the program.
We affirm the district court’s other declaratory ruling that the Office of Management and Budget (OMB) is required to develop procedures to fulfill its NEPA obligations in connection with the Budget process.
I. BACKGROUND
A. The National Wildlife Refuge System
The National Wildlife Refuge System consists of more than 350 refuges containing more than 30 million acres in 49 of the 50 states. The primary purposes of the NWRS are to preserve endangered species and to sustain populations of migratory birds, particularly waterfowl, by maintaining intact a diverse network of their natural habitats. A secondary purpose of the System is to provide for its educational and recreational use (study, observation, and hunting) by people.
The System is administered by the Service according to the provisions of several statutes.1 Much of the refuge land was acquired during the 1930’s. After a period of little growth during the 1940’s and 50’s, the System has been enlarged during the 60’s and to the present, particularly in the area of wild rivers and of wetlands. (There has recently been increasing recognition of the contribution to the preservation of important wildlife made by wetlands, which have been rapidly depleted.) During this period of territorial growth, new statutory mandates (such as the Endangered Species Act of 1973, 16 U.S.C. §§ 1531-1543), and increased public use of the NWRS, the resources devoted to staff and maintain the Refuge System have not kept up with the rate of territorial growth.2 Between 1973 and 1976, there was a 7% decrease in staffing, while the number of field stations in[898]*898creased by 10 percent.3 This has led to a substantial ($83 million) backlog of rehabilitation work, as well as unfulfilled construction work, new and replacement, e. g., water control structures, roads, and buildings.4 Given the policy decision to plan for roughly constant total expenditure (approximately $43 million in 1974 dollars), the FWS focuses on a strategy of increasing the effectiveness of the NWRS in its primary conservation task, while gradually reducing its direct use by the public. The Service’s statement (FES) analyzes the environmental consequences of this proposed strategy, alternatives, and mitigating measures.
B. Plaintiffs’ Contentions
Plaintiffs are three environmental organizations. Their standing will be discussed subsequently. They advance two arguments that section 102(2)(C) of NEPA5 obligates the Service to prepare an EIS on each annual budget request for the System: (a) that past and present proposals to cut down on NWRS operations are “proposals for legislation . significantly affecting the quality of the human environment . . . or (b) that the NWRS is so vital to protection of the environment that the annual proposal on the scope and nature of its operation per se “significantly affect[s] the quality of the human environment.”
Plaintiffs further contend that section 102(2)(B) of NEPA6 requires OMB to develop procedures to assure consideration of environmental factors in the budget process, including identification of which budget requests have significant environmental consequences and what is required of the agencies of the executive branch in submitting these requests to OMB.
C. District Court Decision
The district court granted summary judgment for the plaintiffs7 on the basis of the per se argument concerning budget proposals for operation of a major environmental program such as the NWRS. The court relied on the guidelines implementing NEPA issued by the Council on Environmental Quality (CEQ). These guidelines explicitly include “requests for appropriations” within the definition of “action” for NEPA purposes.8 The court also relied on cases requiring an EIS in connection with the request for appropriations to construct [899]*899or otherwise initiate a specific project.9 The court took note of the programmatic environmental statement being prepared by the defendants, but held that since it was directed at the long range goals of the NWRS, it would not satisfy the NEPA requirement of an analysis specifically directed to the proposed action in a “finely tuned” manner.10 Accordingly, the district court granted the plaintiffs declaratory relief that the defendants were in violation of NEPA, that an EIS was required on the annual budget proposal for the NWRS, and that OMB was required
to develop formal methods and procedures which will, with respect to the Office’s own administrative actions and proposals, identify those agency actions requiring environmental statements to be prepared, considered, and disseminated.11
II. STANDING
The defendants challenge the summary judgment granted to plaintiffs in view of their failure to adduce proof of injury in the face of defendants’ denial of plaintiffs’ standing and assertion of a disputed factual issue as to their injury.12 Plaintiffs alleged in their complaint that their members use the Refuge System and are affected by the environmental impact of the proposal concerning the operation of the System.13 Alternatively, plaintiffs assert that their organizational interests in disseminating the information which NEPA requires the proposing agency to compile and disclose provide standing under SIPI, supra note 8, 481 F.2d at 1087 n. 29. These allegations were not supported by affidavits in plaintiffs’ motion for summary judgment.
There is little doubt in our mind that some of plaintiffs’ hundreds of thousands of nature-oriented members use the Refuge System, so that at least one of them could thereby satisfy the “minimal” standing requirements of Sierra Club v. Morton [Min[900]*900eral King], 405 U.S. 727, 734, 92 S.Ct. 1361, 31 L.Ed.2d 636 (1972) and United States v. SCRAP [SCRAP I], 412 U.S. 669, 688-90, 93 S.Ct. 2405, 37 L.Ed.2d 254 (1973).14 Plaintiffs did not file specific affidavits to that effect. On the other hand, one can hardly say that the issue was sharply drawn by the defendants’ pleadings. In their statement of genuine issues opposing summary judgment, the defendants denied that plaintiffs had “been injured” by operation of the .Refuge System or budget decisions concerning the System.15 However, this point was made in the context of defendants’ denial of the allegation that there were plans to reduce the funding of the NWRS with consequent impairment of the Refuge System. Defendants’ pleadings did not specifically contest the proposition that plaintiffs’ members use and are affected by the System and how the FWS proposes to operate it, which was the underpinning of the per se argument accepted by the district court. While we do not minimize the importance of standing requirements, the issue is whether their disposition required a trial to resolve pertinent issues of fact. A trial is not automatically required by a general denial of standing. However, to avoid any possible implication of foreclosure or estoppel, we make it clear that on the remand for further proceedings, if there is a genuine issue as to use of the Refuges by plaintiffs’ members, defendants may raise it in appropriate proceedings.16
III. NEPA AND THE BUDGET PROCESS
A. Absolute Positions on NEPA Applicability
The plaintiffs’ position is simple and logical. NEPA requires “all agencies of the Federal Government” to prepare an EIS to accompany “every recommendation or report on proposals for legislation . significantly affecting the quality of the human environment.”17 The EIS guidelines of CEQ, the body established by NEPA to implement that statute, defines an “action” subject to the EIS requirement:
“Actions” include but are not limited to:
(1) Recommendations or favorable reports relating to legislation including requests for appropriations.18 [901]*901The other prerequisite of an EIS requirement, that the action significantly affect the environment, has been given a broad reading in favor of obtaining the benefits of an EIS in instances of borderline environmental significance.19 Thus, according to the plaintiffs, an EIS is required in connection with the FWS’s budget proposal for funding the upcoming fiscal year’s operation of a program with great environmental significance, the NWRS.20
The defendants counter that the FWS’s proposal to OMB is only an intermediate step in the budget process and that only the actual Budget submitted by the President could be considered a proposal for legislation, and that this presidential submission would be the earliest action possibly triggering NEPA21 Defendants deny that NEPA imposes any obligation on OMB in its preparation of the Budget; they rely on the confidentiality of the budget process, see 31 U.S.C. §§ 15, 24; and they claim that OMB and FWS are not “agencies” — either within the meaning of the Administrative Procedure Act, 5 U.S.C. § 551(1), or under NEPA- — when they are acting as advisers and staff assistants to the President in making his Budget.
A similar issue has arisen in connection with the Freedom of Information Act (FOIA), 5 U.S.C. § 552, and its applicability to entities within the Executive Office of the President. In Soucie v. David, 145 U.S. App.D.C. 144, 448 F.2d 1067 (1971), without deciding whether the APA definition of “agency” includes the President, we held the Office of Science and Technology (OST) to be an “agency” based on congressional understanding of its role assigned by the reorganization plan in which it was created and in which its position was equated to the Budget Bureau.22 Congress added a definition of “agency” in the 1974 FOIA amendments to include:
. or other establishment in the executive branch of the Government (including the Executive Office of the President) . . . 23
The legislative history makes it clear that Congress adopted the Soucie result. The Conference Report states:
With respect to the meaning of the term “Executive Office of the President” the conferees intend the result reached in Soucie v. David, 448 F.2d 1067 (C.A.D.C. 1971). The term is not to be interpreted as including the President’s immediate personal staff or units in the Executive [902]*902Office whose sole function is to advise and assist the President.24
Preparation of the Budget is an aid to Congress as well as an instrument of presidential policymaking and control over the executive bureaucracy. OMB has a statutory duty to prepare the Budget, in addition to its multitudinous other management, coordination, and administrative functions.25 Congress signified the importance of OMB’s power and function, over and above its role as presidential advisor, when it provided, also by amendment in 1974, for Senate confirmation of the Director and Deputy Director of OMB.'26 Thus, OMB is not totally exempt from the FOIA by its definition of “agency.” We are equally convinced that OMB is not exempt by definition from NEPA. Exactly what NEPA requires of OMB in the budget process in general is not presented on this appeal and awaits OMB’s response to the district court’s declaratory judgment that it is OMB’s function, at least in the first instance, to delineate the appropriate scope of a NEPA obligation that would be both feasible and meaningful.
We now turn to the question of what NEPA requires, annually or occasionally, in connection with decisions about the operation of the NWRS.
B. Review of NWRS Operations
Plaintiffs’ logic-based contention (see note 20 and accompanying text supra) leads logically to the conclusion that an EIS would have to accompany every budget request for the annual operation of an environmental-conservation program, or indeed of an agency whose activities may have significant environmental impact.27 The principle of reductio ad absurdum is part of the landscape of logic. Plaintiffs have not suggested a limiting principle to their logic.
Plaintiffs have put forward as an alternative an escape hatch that would limit the EIS requirement to instances of an alleged cutback in some aspect of NWRS activity, as in the level of NWRS staffing and maintenance, leveling of total expenditure, and lack of acquisition of new refuges.
The difficulty of limitation still obtains. Every agency has limited resources and has to establish priorities among its programs and activities within a program. Some areas and functions are given new emphasis, others are reduced. Some of these decisions, such as a decision to decline to expand the National Park System, may be of great environmental significance. In general, however, if there is no proposal to change the status quo, there is in our view no “proposal for legislation” or “other major Federal action” to trigger the duty under NEPA to prepare an EIS.
It would be absurd to require an EIS on every decision on the management of federal land, such as fluctuation in the number of forest fire spotters. We know of no case pushing NEPA to such extremes. The cases cited on this point by the plain[903]*903tiffs involve initiation or construction of a new project, or a sale of federal resources.28 The cases requiring an EIS in connection with appropriations requests involve proposals for construction or development of a project.29 There is a danger of overburdening NEPA by spreading its mandate too widely. The environmental analysis required by NEPA is governed by the rule of reason, as we have held in determining the scope of realistic alternatives to the proposed action30 and the intensity of the required analysis.31 A rule requiring preparation of an EIS on the annual budget request for virtually every ongoing program would trivialize NEPA. In our view, section 102(2)(C) contemplates a “proposal” for taking new action which significantly changes the status quo, not for a routine request for budget approval and appropriations for continuance and management of an ongoing program.
We hasten to add the qualification that NEPA may have application to those budget requests that follow or accompany an agency’s painstaking review of an ongoing program. The need is for a reading of NEPA that harmonizes its words, its purposes, and the rule of reason. Hence, a “proposal for legislation,” within § 102(2)(C), is not applicable when the budget and appropriation process is routine, but is fully applicable when the request for budget approval and appropriations is one that ushers in a considered programmatic course following a programmatic review. A review of such a nature reflects choices that should under NEPA be made in the light of a full consideration of pertinent environmental consequences and alternatives.32
[904]*904We have no occasion at this time to consider whether, or in what instances, a “new look” may be required because of vastly changed circumstances, either by NEPA or perhaps by some other provision of federal law. Nor need we now consider whether a court may mandate any such duty to take a new look.
What we do hold is that an EIS is required when such a new look is had. A new look may be generated periodically and spontaneously as a matter of good management and revitalization of the bureaucracy. It may be a response to external stimulus, as when dramatically changed circumstances cry out for review, or perhaps to accommodate existing programs to changes in the agency’s statutory mandate. It is clear that there is wide discretion in the agency to determine when such review will be conducted. That is the essence of government and administration. It is impossible to have a “new look” at everything all the time. When there is such a new look the ensuing request for appropriations is a “proposal for legislation” under NEPA.
We need not decide whether this kind of painstaking reappraisal of the NWRS was required at the time plaintiffs brought this lawsuit, because the FWS has since undertaken one. The Programmatic EIS evaluates the environmental consequences of the proposed operation of the NWRS and alternatives thereto over the next decade. The FWS has indicated that it intends to make an analysis from scratch at the end of those ten years; in the meantime it will update the environmental study in light of changed plans and circumstances.33
The Programmatic EIS sets forth the environmental consequences of the FWS’s present plan to operate the NWRS at a roughly constant real level of expenditure with priority given to its conservation mission over public use — recreational and educational. It also considers the effects of alternate program priorities and expenditures. The adequacy of the EIS for what it is (a long-term strategy and analysis) has not been challenged by plaintiffs on appeal. The controversy presented to this court concerns the district court’s ruling that an EIS is required in the future for each and every annual budget request. We hold to the contrary.
C. OMB’s Obligation
NEPA requires all agencies of the federal government to:
identify and develop methods and procedures, in consultation with [CEQ], which will insure that presently unquantified environmental amenities and values may be given appropriate consideration in decisionmaking along with economic and technical considerations.34
This requirement is applicable to OMB as the agency responsible for preparation of the budget and other executive legislative proposals, a conclusion drawn from the Act itself and supported by the legislative history and administrative regulations.35 Our [905]*905view that some but not all (and certainly not routine) requests for appropriation are “proposals for legislation” under § 102(2)(C) underscores a need, on the part of agencies, for guidance in determining when an EIS is required in connection with a budget request.
These observations clarify the obligation imposed by NEPA and OMB, as the key agency in the executive’s budget formulation process, to give appropriate guidance to the agencies. The district court granted declaratory relief that NEPA requires:
Defendant Director of the Office of Management and Budget to develop formal methods and procedures which will, with respect to the Office’s own administrative actions and proposals, identify those agency actions requiring environmental statements to be prepared, considered, and disseminated.36
The parties have not focused on this aspect of the district court’s ruling and we might treat it as not appealed. However, the government defendants might argue that it was implicitly subject to further consideration in the light of their main contention. And the rulings we have made on the type of budget and appropriation requests that require an EIS will obviously affect the obligation put on OMB. To avoid uncertainty, we have considered the matter and affirm the ruling that requires OMB to adopt procedures and appropriate regulations to comply with the obligations NEPA imposes on the budget process when it culminates in proposals for legislation under the principles previously discussed.
This is not an onerous task. Preparation of the Budget is OMB’s central function in helping the President coordinate the policy of the agencies and establish priorities for his administration. As it stands, the declaratory judgment imposes a duty on OMB to initiate the delineation of the procedures required by NEPA in connection with the budget process.37 This task will be eased and simplified, we anticipate, by our rulings identifying what types of requests to the legislature for appropriations do and do not require preparation of an EIS, as well as clarifying the bounds of an agency’s discretion in undertaking a reevaluation of an ongoing program.
OMB will give consideration to how obligations under NEPA can be discharged without violating the principle that holds an agency’s budget requests confidential prior to final review by the President. We do not expand on the problem here. For one thing, it was not developed by the government’s appeal. Furthermore, we anticipate that the OMB will wish to ponder the matter afresh in light of the rulings in this opinion. The matter may be capable of resolution in a manner that presents program proposals in terms that permit an environmental analysis, without disclosure of dollar projections or other betrayal of genuine budget confidence. Since requirement of an environmental impact statement in connection with budget proposals will arise in relatively few instances, under the [906]*906principles we have set forth, and since proposals for major program reviews and changes can probably be disclosed in general outline, sufficient for impact statement purposes, without undercutting the objectives underlying budget-type secrecy, OMB can fairly be called on to develop a proposal that serves and harmonizes both NEPA and budget processes. Certainly the fact that a proposal is subject to further review by the Executive is no bar to NEPA’s requirement for an environmental statement. On the contrary, NEPA calls for an EIS precisely so that environmental consequences may be taken into account before a final decision is reached by the executive official or agency.
IV. CONCLUSION
NEPA has been salutary in heightening agency attention to environmental values, in part by requiring disclosure of environmental consequences. However, we cannot allow NEPA to be bloated, and indeed enfeebled, by pushing the logic of Section 102(2)(C) to ridiculous extremes. NEPA does not require an annual EIS on routine operation and maintenance of every program with significant environmental ramifications. Its rule of reason does not demand rethinking of everything all the time.
The Fish and Wildlife Service has undertaken a re-evaluation of the National Wildlife Refuge System, and has done an analysis of its long term plan for operation of the System. We are not presented with a challenge to the validity of that exercise of discretion. In view of the programmatic EIS it has prepared there is no further obligation under NEPA at this time.
The judgment obligating defendants to prepare an annual EIS on NWRS operations is reversed. We affirm the judgment declaring OMB’s duty to develop methods and procedures to implement the NEPA obligation to provide environmental impact statements to accompany those proposals on budget and appropriations that are proposals for legislation. This duty, as set forth in this opinion, applies when the request for budget approval and appropriations is one that proposes a considered programmatic course following a programmatic review. OMB will have latitude to propose a method that harmonizes both NEPA and budget processes.
The case is remanded for further proceedings not inconsistent with this opinion.
So ordered.