The inclusion of fish kills at Indian Point caused the Second Circuit Court of Appeals to order the FPC to revive the fish mortality issue at Storm King. With the environmentalists' new constitutional standing, Con Ed envisioned costly litigation ahead. In 1980, Con Ed sought a settlement accord, resulting in the Hudson River Peace Treaty. This agreement cancelled the hydropower plant, mandated the land become a park and forced Con Ed to donate $12 million to endow a Hudson River Foundation to study the river. Con Ed was spared costs of constructing infrastructure at Indian Point to solve the fish intake problem, but had to research alternative solutions to reduce fish kills. The Storm King Doctrine set precedents for environmental law including citizens' claims to bring an environmental dispute before a court. This right was included in the National Environmental Policy Act and expanded citizen participation in the environmental movement.