While protection of the marine environment is a matter of important concern, the existing case law seems to pay little attention to environmental concern in the context of maritime delimitations. In the Gulf of Maine case, the United States relied on environmental factors to justify an equitable maritime boundary. However, the Chamber of the ICJ discarded the ecological criterion primarily because such a criterion was inconsistent with the ‘neutral criteria' for drawing a single maritime boundary. Usually environmental considerations have played little, if any, role in agreements concerning maritime delimitations.