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During the 1999 war between NATO and the Federal Republic of Yugoslavia, NATO targeted and destroyed chemical plants and storage facilities at Pancevo, Kragujevac, and elsewhere. A United Nations inspection team found that the NATO attacks had caused measurable, but not catastrophic, environmental damage wityin the territory of Yugoslavia. This article explores the historical evolution and current status of the body of law regarding protection of the environment during wartime, as well as the legality of NATO's actions. It concludes that NATO probably did not violate international law as it currently stands. However, the postwar reactions of states, including the NATO member states, may show a growing intolerance for environmentally destructive military tactics. Chemical plants, in particular, may in the future be proscribed as ultrahazardous targets, as dams, dikes, and nuclear power plants are currently.

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