DC Circuit: Sierra Club, et al v. FERC

Standing, Environment

Member living under a mile away gives associational standing to challenge increased constuction and output at natural gas port, given construction plans.

Environmental analysis was a substantial part of the export strategy, so not moot.

Intervening causation defeats challenge to export strategy by challenging port expansion.

Foreseeable and proximte effects on national markets required for cumulative analysis.

Shift in metrics not raised in agency proceedings


Sierra Club, et al v. FERC