April 21, 1992



_________________________

No. 91-1895

UNITED STATES OF AMERICA, ET AL.,
Plaintiffs, Appellees,

v.

AVX CORPORATION, ET AL.,
Defendants, Appellees.
_______________

NATIONAL WILDLIFE FEDERATION,
Intervenor, Appellant.
_________________________

APPEAL FROM THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MASSACHUSETTS

[Hon. William G. Young, U.S. District Judge]
___________________
_________________________

Before

Selya, Circuit Judge,
_____________
Bownes, Senior Circuit Judge,
____________________
and Cyr, Circuit Judge.
_____________

Eric R. Glitzenstein, with whom Katherine A. Meyer and
______________________ ___________________
Harmon, Curran, Gallagher & Spielberg were on brief, for
__________________________________________
appellant.
John A. Bryson, Attorney, U.S. Dept. of Justice, with whom
______________
Barry M. Hartman, Acting Assistant Attorney General, Myles E.
_________________ ________
Flint, Deputy Assistant Attorney General, Ellen M. Mahan and Anne
_____ ______________ ____
S. Almy, Attorneys, U.S. Dept. of Justice, were on brief, for
_______
appellee United States of America.
Matthew T. Brock, Assistant Attorney General
______________________
(Massachusetts), on brief for appellee Commonwealth of
Massachusetts.
Paul B. Galvani, with whom Roscoe Trimmier, Jr. and Ropes &
________________ ____________________ _______
Gray were on brief, for appellee Aerovox, Inc.
____
David A. McLaughlin and McLaughlin & Folan, P.C. on brief
____________________ _________________________
for appellee Belleville Industries, Inc.

_________________________


_________________________














SELYA, Circuit Judge. The National Wildlife Federation
SELYA, Circuit Judge.
_____________

(NWF), an intervenor below, tries to appeal the entry of a

consent decree concerning the cleanup of New Bedford Harbor. NWF

bills the appeal as one involving critical interpretive questions

anent the Comprehensive Environmental Response, Compensation, and

Liability Act (CERCLA), 42 U.S.C. 9601-9675 (1988). There is,

however, a prevenient issue; the original parties to the

litigation contend that NWF lacks standing to maintain the

appeal. Because NWF cannot push past this threshold, we dismiss

for lack of appellate jurisdiction (without considering the

substantive questions that lie beyond the doorstep).

I. BACKGROUND
I. BACKGROUND

The litigation that undergirds this appeal is nearly a

decade old. In 1983, two governmental plaintiffs, the United

States and the Commonwealth of Massachusetts, acting as natural

resources trustees, brought suit for damages under CERCLA 107,

42 U.S.C. 9607, in the United States District Court for the

District of Massachusetts. The complaint alleged that Aerovox,

Inc., Belleville Industries, Inc., and four other defendants bore

responsibility for the release of polychlorinated biphenyls into

the Acushnet River and New Bedford Harbor, causing injury to

natural resources. An amended complaint, filed in March 1984,

added claims for recovery of costs to be incurred in remediating

the river and harbor.






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The subsequent course of the litigation has been much

chronicled.1 We need not retrace the district court's steps.

For the purpose at hand, it suffices to say that, in 1987, NWF

moved to intervene as a party plaintiff, premising its motion on

the divergence between its views and the views of the plaintiffs

as to the appropriate measure of damages for environmental harm.

NWF professed concern that, due to this divergence in views, the

plaintiffs might settle the pending action too cheaply. On April

27, 1989, the district court granted permissive intervention for

the limited purpose of allowing NWF to brief and argue the

following issues: (1) the legal requirements applicable to any

proposed consent decree; (2) the appropriate measure of natural

resource damages under CERCLA; and (3) the legal requirements for

cleanup under CERCLA. In Re Acushnet River & New Bedford Harbor:
__________________________________________

Proceedings Re Alleged PCB Pollution, 712 F. Supp. 1019, 1023 (D.
____________________________________

Mass. 1989). The order permitting intervention also granted NWF

the right to appeal "from a judgment it views as adverse" in

respect to these issues. Id.
___

On December 18, 1990, the plaintiffs proposed a consent

decree memorializing the anticipated settlement of their claims


____________________

1The district court has written no less than eight published
opinions on various aspects of the litigation. See In re
___ ______
Acushnet River & New Bedford Harbor: Proceedings Re Alleged PCB
_________________________________________________________________
Pollution, 725 F. Supp. 1264 (D. Mass. 1989); S.C., 722 F. Supp.
_________ ____
893 (D. Mass 1989); S.C., 722 F. Supp. 888 (D. Mass. 1989); S.C.,
____ ____
716 F. Supp. 676 (D. Mass. 1989); S.C., 712 F. Supp. 1019 (D.
____
Mass. 1989); S.C., 712 F. Supp. 1010 (D. Mass. 1989); S.C. 712 F.
____ ____
Supp. 994 (D. Mass. 1989); S.C., 675 F. Supp. 22 (D. Mass. 1987).
____
We refer the reader who hungers for more intimate details about
the underlying litigation to those rescripts.

3














against Aerovox and Belleville. The decree provided that the

settling defendants would pay $9,450,000 in response costs and

$3,150,000 as compensation for injuries to natural resources in

the harbor area. In exchange for this $12,600,000 cash

settlement, the plaintiffs would covenant "not to sue or to take

any other civil or administrative action" against Aerovox or

Belleville.

On January 7, 1991, the federal government solicited

public comment on the proposed decree, 56 Fed. Reg. 535 (1991),

as required by CERCLA 122(d)(2), 42 U.S.C. 9622(d)(2), and 28

C.F.R. 50.7 (1990). NWF submitted comments contending that the

suggested cash-out settlement would violate CERCLA in two

respects. First, NWF argued that "the proposed decree

contravened [CERCLA 122(f)] because EPA has not approved a

final response action at the site."2 Second, NWF argued that

____________________

2The statute provides that the federal government may grant
covenants not to sue to CERCLA defendants

. . . if each of the following conditions is met:

(A) The covenant not to sue is in the
public interest.
(B) The covenant not to sue would
expedite response action consistent with the
National Contingency Plan . . . .
(C) The [covenantee] is in full
compliance with a consent decree under
[CERCLA] section 9606 . . . (including a
consent decree entered into in accordance
with this section) for response to the
release or threatened release concerned.
(D) The response action has been
approved by the [Administrator of the EPA, as
the President's designee].

42 U.S.C. 9622(f)(1).

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the proposed decree ran afoul of CERCLA 122(j) because it

contemplated that the defendants would obtain covenants not to

sue without any assurance that they would "take appropriate

actions necessary to protect and restore the natural resources

damaged by such release . . . of hazardous substances." 42

U.S.C. 9622(j)(2). Unimpressed by NWF's comments, the

plaintiffs pressed the district court to approve the consent

decree. On July 16, 1991, the district court, ore tenus,
___ _____

overruled NWF's objections and entered the decree. This appeal

followed.

Because the dispositive issue in this proceeding

implicates NWF's standing to pursue its appeal, we turn

immediately in that direction. NWF, an intervenor, is the lone

appellant. The plaintiffs (the federal and state governments)

and the settling defendants (Aerovox and Belleville) all appear

as appellees, the district court having entered final judgment,

Fed. R. Civ. P. 54(b), as to all claims against Aerovox and

Belleville. The suit remains pending in the court below against

other defendants.

II. THE NECESSITY FOR STANDING
II. THE NECESSITY FOR STANDING

Our odyssey through the often Byzantine world of

standing is greatly assisted in this instance by the Supreme

Court's opinion in Diamond v. Charles, 476 U.S. 54 (1986).
_______ _______

There, Dr. Diamond, a pediatrician, intervened as a defendant in

a class action brought by a group of gynecologists seeking to

invalidate an Illinois abortion law. Later, disappointed by an


5














opinion of the Seventh Circuit, Dr. Diamond took an appeal to the

Supreme Court in which he sought to challenge an injunction

barring enforcement of certain

sections of the statute. Id. at 61. He prosecuted the appeal
___

notwithstanding that the state (on whose side he had originally

intervened) chose not to pursue a further appeal. Id. at 56, 61.
___

The Court ruled that, since the intervenor was the sole

appellant, he could no longer ride the state's coattails, but

must himself bear the burden of showing that he met the

requirements for standing.3 Id. at 63-64. In language of
___

unmistakable clarity, Justice Blackmun wrote that "an

intervenor's right to continue a suit in the absence of the party

on whose side intervention was permitted is contingent upon a

showing by the intervenor that he fulfills the requirements of

Art. III." Id. at 68. Accord Boston Tow Boat Co. v. United
___ ______ _____________________ ______

States, 321 U.S. 632, 633-34 (1944). Because he had not made the
______

requisite showing, Dr. Diamond's appeal was dismissed for want of

appellate jurisdiction. See Diamond, 476 U.S. at 71.
___ _______

NWF suggests that Diamond is not controlling because
_______

the original parties here the federal and state sovereigns, on

the one hand, and the settling defendants, on the other hand

remain parties to the appeal. This suggestion is a prime example

of a litigant allowing hope to triumph over reason. In Diamond,
_______

the intervenor also argued that the party on whose side he

____________________

3The Court expressly left open the question of whether a
party seeking to intervene in the district court must satisfy
Article III's standing requirements. Diamond, 476 U.S. at 68-69.
_______

6














intervened the state remained a party to the litigation, thus

keeping the original controversy alive and allowing him to derive

the benefit of the state's standing. Id. at 63-64. The Court
___

squarely rejected the argument, noting that while the state's

interests may theoretically have remained adverse to those of the

other appellees, the state's failure to appeal the issue removed

the underlying controversy upon which the intervenor had

"piggyback[ed]" in the lower courts. Id.
___

So here. In the district court, the plaintiffs were

seeking to maximize cleanup efforts; the defendants were hoping

to minimize their financial liability. This provided the

"adversariness" that rendered the question of NWF's standing

academic. See id. at 68-69. The entry of the consent decree,
___ ___

with the full support of all the settling parties, changed the

calculus. While the parties to the decree are still parties to

the action and to the appeal, they are now opponents in name

only; in practical effect, the plaintiffs and the settling

defendants no longer represent opposing interests. The

underlying controversy between them has been resolved. Hence,

given the case's current posture, there is no longer any

extraneous support to which NWF may cling.

In point of fact, this case presents a stronger

argument against continued piggybacking than the Diamond case.
_______

In Diamond, the state, while not itself appealing, had filed a
_______

letter of interest making clear that it favored the position that

the appellant was endeavoring to advance. Id. at 61. Here,
___


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however, there is no such enduring confluence of interests. The

parties on whose side NWF originally intervened the federal and

state sovereigns want to preserve the very decree that NWF

wants to defenestrate. They are adamantly opposed to the

position that the intervenor seeks to espouse on appeal.

Therefore, NWF finds itself in an even weaker position than that

occupied by Dr. Diamond: in Thomas Wolfe's phrase, "a stranger

and alone."4

Nor does the clause in the intervention order

purporting to grant NWF the right to appeal have any significance

on the threshold issue with which we must grapple. Standing is a

constitutional precondition to the jurisdiction of a federal

court and may not be conferred by judicial fiat upon a party who

does not meet the requirements of Article III. See Diamond, 476
___ _______

U.S. at 68 (while intervenors are entitled to seek review, their

ability to maintain an appeal in the absence of the party on

whose side they originally intervened is contingent upon meeting

the requirements of Article III). Thus, an intervenor who does

not actually meet the constitutional requirements for standing to

appeal cannot premise standing solely upon a court order

purporting to grant a right of appeal. See United States v.
___ ______________

Western Elec. Co., 900 F.2d 283, 309-10 (D.C. Cir.) (per curiam),
_________________

cert. denied, 111 S. Ct. 283 (1990).
_____ ______

We have said enough. This case is a Diamond in the
_______

rough. Consonant with the Court's teachings, we rule that an

____________________

4Thomas Wolfe, Look Homeward, Angel, foreword (1929).
____________________

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association which has intervened in the trial court and which

seeks to prosecute an appeal notwithstanding that the parties on

whose side it intervened have eschewed further appeals, must

independently pass the test of Article III standing. Applying

this precept, NWF can no longer piggyback on the plaintiffs'

interests in this litigation, but must satisfy the requirements

for standing if it is to maintain the instant appeal.

III. THE REQUIREMENTS FOR STANDING
III. THE REQUIREMENTS FOR STANDING

Standing poses the potential for a domino effect. If a

party lacks standing to bring a matter before the court, the

court lacks jurisdiction to decide the merits of the underlying

case. See FW/PBS v. City of Dallas, 493 U.S. 215, 231 (1990);
___ ______ _______________

Bender v. Williamsport Area School Dist., 475 U.S. 534, 541
______ ________________________________

(1986); Valley Forge Christian College v. Americans United for
________________________________ _____________________

Separation of Church & State, 454 U.S. 464, 475-76 (1982). Ergo,
____________________________

standing is a "threshold question in every federal case,

determining the power of the court to entertain the suit." Warth
_____

v. Seldin, 422 U.S. 490, 498 (1975). The inquiry into standing
______

seeks to determine "whether the litigant is entitled to have the

court decide the merits of the dispute or of particular issues."

Id.; accord Conservation Law Found. of N.E. v. Reilly, 950 F.2d
___ ______ _______________________________ ______

38, 40 (1st Cir. 1991) (CLF/NE). The ingredients of standing are
______

imprecise and not easily susceptible to concrete definitions or

mechanical application. See Allen v. Wright, 468 U.S. 737, 751
___ _____ ______

(1984); Valley Forge, 454 U.S. at 475.
____________

The constitutional limitations on standing derive from


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the requirement that federal courts can act only upon a

justiciable case or controversy. U.S. Const. art. III. To

satisfy the constitutional imperative, "[a] plaintiff must allege

personal injury fairly traceable to the defendant's allegedly

unlawful conduct and likely to be redressed by the requested

relief." Allen, 468 U.S. at 751. Because the constitutional
_____

imperative seeks to ensure the existence of a case or controversy

by focusing on the harm to the complainant, it is unsurprising

that the "personal injury" prong of the standing inquiry has

received the bulk of the Court's attention. While the requisite

injury may be common to many, see United States v. Students
___ _____________ ________

Challenging Regulatory Agency Procedures (SCRAP), 412 U.S. 669,
_________________________________________________

687-88 (1973), it may not be shared by all. See Warth, 422 U.S.
___ _____

at 499; Schlesinger v. Reservists Comm. to Stop the War, 418 U.S.
___________ ________________________________

208, 220 (1974). The injury must be real, see Warth, 422 U.S. at
___ _____

501 (requiring injury to be "distinct and palpable"), but not

necessarily economic; environmental or aesthetic injury can

suffice in certain circumstances. See, e.g., SCRAP, 412 U.S. at
___ ____ _____

686; Sierra Club v. Morton, 405 U.S. 727, 734 (1972). A mere
___________ ______

interest in an event no matter how passionate or sincere the

interest and no matter how charged with public import the event

will not substitute for an actual injury. See Diamond, 476 U.S.
___ _______

at 62 ("The presence of a disagreement, however sharp and

acrimonious it may be, is insufficient by itself to meet Art.

III's requirements."); SCRAP, 412 U.S. at 687 (insisting upon a
_____

showing of personal injury "prevents the judicial process from


10














becoming no more than a vehicle for the vindication of the value

interests of concerned bystanders").

In addition to its constitutional dimensions, the

doctrine of standing also embraces prudential concerns regarding

the proper exercise of federal jurisdiction. To this end, the

Court has required "that a plaintiff's complaint fall within the

zone of interests protected by the law invoked." Allen, 468 U.S.
_____

at 751. The Court has also demanded that, as a general rule, a

plaintiff "must assert his own legal rights and interests, and

cannot rest his claim to relief on the legal rights or interests

of third parties." Warth, 422 U.S. at 499.5 Finally, "the
_____

Court has refrained from adjudicating 'abstract questions of wide

public significance' which amount to 'generalized grievances,'

pervasively shared and most appropriately addressed in the

representative branches." Valley Forge, 454 U.S. at 475 (quoting
____________

Warth, 422 U.S. at 499-500).
_____

IV. THE METHODOLOGY OF REVIEW
IV. THE METHODOLOGY OF REVIEW

Before shining the light of these teachings on the case

at hand, we pause to discuss questions of methodology.

The burden of adducing facts necessary to support

standing rests squarely with the party seeking to avail itself of

federal jurisdiction. The Court has stated the proposition

unequivocally: "It is the responsibility of the complainant


____________________

5One exception to this general rule is that associations may
assert the claims of their members, provided that the members
have suffered some distinct and palpable injury. We discuss this
exception in greater detail infra.
_____

11














clearly to allege facts demonstrating that he is a proper party

to invoke judicial resolution of the dispute and the exercise of

the court's remedial powers." Warth, 422 U.S. at 518; accord
_____ ______

FW/PBS, 493 U.S. at 231; Munoz-Mendoza v. Pierce, 711 F.2d 421,
______ _____________ ______

425 (1st Cir. 1983). This burden pertains in full measure to an

intervenor who proposes to prosecute an appeal singlehandedly.

See Diamond, 476 U.S. at 68.
___ _______

In this instance, the intervenor's standing was

immaterial in the lower court. Once NWF filed a notice of

appeal, however, its standing (or lack thereof) took on critical

importance. The appellees promptly moved to dismiss the appeal

under 1st Cir. R. 27.1 (which empowers the court of appeals to

dismiss an appeal for either lack of jurisdiction or lack of a

substantial question). It is necessary, therefore, that we

explicate the method and mode of our consideration of such a

motion.

In addressing the appellees' motions to dismiss, we

steer by the Court's beacon. "For purposes of ruling on a motion

to dismiss for want of standing, both the trial and reviewing

courts must accept as true all material allegations of the

complaint, and must construe the complaint in favor of the

complaining party." Warth, 422 U.S. at 501; accord Lujan v.
_____ ______ _____

National Wildlife Fed'n, 110 S. Ct. 3177, 3189 (1990); NAACP,
________________________ ______

Boston Chapter v. Harris, 607 F.2d 514, 525 (1st Cir. 1979). In
______________ ______

practical effect, then, the standard is much the same as that

traditionally applied to motions to dismiss made under Fed. R.


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Civ. P. 12(b)(6).6



This formulation does not mean, however, that a court

must (or should) accept every allegation made by the complainant,

no matter how conclusory or generalized. In connection with run-

of-the-mine motions brought under Rule 12(b)(6), a reviewing

court is obliged neither to "credit bald assertions, periphrastic

circum-locutions, unsubstantiated conclusions, or outright

vituperation," Correa-Martinez v. Arrillaga-Belendez, 903 F.2d
_______________ __________________

49, 52 (1st Cir. 1990), nor to honor subjective

characterizations, optimistic predictions, or problematic

suppositions. Dartmouth Review v. Dartmouth College, 889 F.2d
________________ _________________

13, 16 (1st Cir. 1989). "[E]mpirically unverifiable"


____________________

6Because the pending motions seek dismissal on the basis of
the pleadings, they are highly analogous to motions brought under
Fed. R. Civ. P. 12(b). Courts have often treated motions to
dismiss for want of standing as motions to dismiss for failure to
state a claim, thus bringing them under the rubric of Rule
12(b)(6). See, e.g., Rental Housing Assoc. of Greater Lynn v.
___ ____ _______________________________________
Hills, 548 F.2d 388, 391 (1st Cir. 1977); see also 5A Charles A.
_____ ___ ____
Wright & Arthur R. Miller, Federal Practice and Procedure 1360
______________________________
(2d ed. 1990). We recognize, of course, as the District of
Columbia Circuit has concluded, that Rule 12(b)(1) arguably
provides a closer analogy. See Hasse v. Sessions, 835 F.2d 902,
___ _____ ________
905-07 (D.C. Cir. 1987); see also Bordell v. General Elec. Co.,
___ ____ _______ __________________
922 F.2d 1057, 1058 (2d Cir. 1991); Cone Corp. v. Florida Dep't
__________ ______________
of Transp., 921 F.2d 1190, 1203 n.42 (11th Cir.), cert. denied,
__________ _____ ______
111 S. Ct. 2238 (1991); Xerox Corp. v. Genmoora Corp., 888 F.2d
___________ ______________
345, 350 (5th Cir. 1989). Nevertheless, we leave the ultimate
choice between Rules 12(b)(6) and 12(b)(1) for another day. In
the case at hand, none of the parties have asked us to apply the
jurisprudence of Rule 12(b)(1). Moreover, considering the
posture in which this case comes before us, and the fact that we
have gone beyond NWF's complaint in intervention in a record-wide
search for facts supporting its stance, the Rule 12(b)(6)
criterion is as favorable to NWF as any other criterion that
might conceivably be applied.

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conclusions, not "logically compelled, or at least supported, by

the stated facts," deserve no deference. Id.
___

Although the legal standard for reviewing a motion

under Rule 12(b)(6) remains constant, the degree of specificity

with which the operative facts must be stated in the pleadings

varies depending on the case's context. Thus, there are various

classes of cases in which we have required a heightened degree of

specificity to withstand a motion to dismiss. See Garita Hotel
___ ____________

Ltd. Partnership v. Ponce Fed. Bank, ___ F.2d __, ___ & n.1 (1st
________________ _______________

Cir. 1992) [No. 91-1685, slip op. at 4 & n.1]; see also Miranda
___ ____ _______

v. Ponce Fed. Bank, 948 F.2d 41, 44 (1st Cir. 1991) ("a civil
_______________

RICO complaint must, at a bare minimum, state facts sufficient to

portray (i) specific instances of racketeering activity within

the reach of the RICO statute and (ii) a causal nexus between

that activity and the harm alleged"); Dewey v. University of New
_____ _________________

Hampshire, 694 F.2d 1, 3 (1st Cir. 1982) (a civil rights
_________

complaint must present more than "a general scenario which could

be dominated by unpleaded facts"), cert. denied, 461 U.S. 944
_____ ______

(1983). In such contexts, the burden of articulation is not a

mere formality.

This case, too, is elevated above the mine-run.

Because standing is fundamental to the ability to maintain a

suit, and because the Court has saddled the complainant with the

burden of clearly alleging facts sufficient to ground standing,

we are of the opinion that, where standing is at issue,

heightened specificity is obligatory at the pleading stage. The


14














resultant burden cannot be satisfied by purely conclusory

allegations or by a Micawberish reading of a party's generalized

averments. To the contrary, the proponent's pleadings "must be

something more than an ingenious academic exercise in the

conceivable." SCRAP, 412 U.S. at 688. The complainant must set
_____

forth reasonably definite factual allegations, either direct or

inferential, regarding each material element needed to sustain

standing. See Munoz-Mendoza, 711 F.2d at 425 ("Where 'injury'
___ _____________

and 'cause' are not obvious, the plaintiff must plead their

existence in his complaint with a fair degree of specificity.");

see generally Gooley v. Mobil Oil Corp., 851 F.2d 513, 514 (1st
___ _________ ______ _______________

Cir. 1988) (describing minimal allegations needed, in an ordinary

case, to survive Rule 12(b)(6) motion to dismiss). To borrow the

Court's phrase, the facts necessary to support standing must

clearly appear in the record and "cannot be 'inferred

argumentatively from averments in the pleadings.'" FW/PBS, 493
______

U.S. at 231 (quoting Grace v. American Cent. Ins., 109 U.S. 278,
_____ ___________________

284 (1883)).

It is with this rubric in mind that we inquire into

NWF's standing to maintain this appeal.7

____________________

7We categorically reject the idea that appellees waived the
right to question NWF's standing by not moving for summary
judgment in the district court. Standing implicates a court's
ability, consistent with the requirements of Article III, to hear
a case. Thus, a defect in standing cannot be waived; it must be
raised, either by the parties or by the court, whenever it
becomes apparent. See FW/PBS, 493 U.S. at 230-31. Moreover,
___ ______
inasmuch as permission to intervene and standing to appeal are
horses of two different hues, see Diamond, 476 U.S. at 68-69; see
___ _______ ___
also supra note 3 and accompanying text, there was no reason for
____ _____
the appellees to challenge the intervenor's standing until the

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V. NWF'S STANDING TO APPEAL
V. NWF'S STANDING TO APPEAL

On appeal, NWF identifies two distinct injuries which,

it says, are sufficient to sustain standing. First, quoting from

its motion to intervene, it alleges that its members "have been

and continue to be harmed by the threats and damage to the

environment and to natural resources caused by PCBs and other

toxics and hazardous substances released into the New Bedford

Harbor area." Second, it alleges harm to its members and other

citizens attributable to the government's failure to comply with

certain procedural requirements imposed by CERCLA. We consider

these claims separately, after recounting some basic principles.

A. General Principles of Associational Standing.
A. General Principles of Associational Standing.
____________________________________________

It is well settled that, under certain circumstances,

an unincorporated association may premise standing upon injuries

suffered by some or all of its members. See UAW v. Brock, 477
___ ___ _____

U.S. 274, 281-82 (1986); Hunt v. Washington State Apple
____ ________________________

Advertising Comm'n, 432 U.S. 333, 342-43 (1977); Warth, 422 U.S.
___________________ _____

at 511. An association has standing to sue on behalf of its

members when three requisites have been fulfilled: (1) at least

one of the members possesses standing to sue in his or her own

right; (2) the interests that the suit seeks to vindicate are

pertinent to the objectives for which the organization was

formed; and (3) neither the claim asserted nor the relief

demanded necessitates the personal participation of affected

individuals. See Brock, 477 U.S. at 282; Hunt, 432 U.S. at 343;
___ _____ ____

____________________

appeal eventuated in its present posture.

16














CLF/NE, 950 F.2d at 41. These prerequisites for associational
______

standing ensure that Article III's case or controversy

requirement is satisfied in a given situation.

In the matter before us, affinity and personal

participation are not of particular concern. There is no

question that the interests which NWF seeks to safeguard are

"germane to the organization's purpose." Hunt, 432 U.S. at 343.
____

Likewise, nothing about the claims asserted or the relief

requested seems to require the involvement of particular

individuals as named plaintiffs. Thus, NWF's standing vel non
___ ___

rests on the first tine of the furcula: has NWF alleged an

injury to a member sufficient to meet the requirements of Article

III? Put another way, has the association shown "that its

members, or any one of them, are suffering immediate or

threatened injury as a result of the challenged action of the

sort that would make out a justiciable case had the members

themselves brought suit [?]" Warth, 422 U.S. at 511. We believe
_____

this question, in either phrasing, must be answered in the

negative.

B. Environmental Harm.
B. Environmental Harm.
__________________

NWF stated in its motion to intervene that it has

"79,000 members and supporters in Massachusetts." NWF further

claimed that its members "use and enjoy, through fishing,

swimming, recreational and other uses, the environment and

natural resources in the New Bedford Harbor [area]," and that its

"members have been and will continue to be harmed by the releases


17














that are the subject of [the] litigation." NWF has not

particularized these conclusory averments in any way. To the

contrary, in a manner hauntingly reminiscent of the unsuccessful

attempt of another environmental interest group to establish

standing in an earlier case, see Sierra Club v. Morton, 405 U.S.
___ ___________ ______

727, NWF makes only the most nebulous allegations regarding its

members' identities and their connection to the relevant

geographic area. Compare id. at 735 & n.8. Gauzy generalities
_______ ___

of this sort, unsubstantiated by any sort of factual foundation,

cannot survive a motion to dismiss. See Dartmouth Review, 889
___ ________________

F.2d at 16.

To be sure, unlike the plaintiff in Morton, NWF does
______

make a general allegation of actual injury to members. NWF

asserts that this generalized allegation of individual harm is

sufficient to withstand appellees' motions to dismiss. We

disagree. The averment has no substance: the members are

unidentified; their places of abode are not stated; the extent

and frequency of any individual use of the affected resources is

left open to surmise. In short, the asserted injury is not

anchored in any relevant particulars. The intervenor's papers do

not contain an averment, much less a particularized showing, of

the type of "concrete injury" that we have said is needed to

confer standing in an environmental suit. CLF/NE, 950 F.2d at
______

43. A barebones allegation, bereft of any vestige of a factual

fleshing-out, is precisely the sort of speculative argumentation

that cannot pass muster where standing is contested. See FW/PBS,
___ ______


18














493 U.S. at 231.

NWF urges that SCRAP, 412 U.S. 669, adumbrates a
_____

different result. But, although it is true that the SCRAP Court
_____

applied a liberal standard in reviewing claims of associational

standing, see id. at 687-90, NWF has failed to achieve even that
___ ___

minimal benchmark. In SCRAP, the complainant, an environmental
_____

organization, sued under the Administrative Procedure Act to

enjoin a rate surcharge approved by the Interstate Commerce

Commission.8 Id. at 685. The association consisted of five
___

members, all clearly identified, who lived in metropolitan

Washington. It was alleged that each member had suffered

specific economic, recreational, and aesthetic harm as a result

of illegal agency action, e.g., they were each forced to pay more
____

for finished products and to suffer decreased enjoyment in their

use of natural resources in the immediate area of their homes due

to the permitted modification in the rate structure. Id. at 678.
___

The Court found these allegations adequate to underbrace

standing. Id. at 689-90.
___

The contrast between SCRAP and the case before us could
_____

scarcely be more stark. In SCRAP, unlike here, the association
_____

consisted of a discrete number of identified individuals. In

SCRAP, unlike here, there was a geographic nexus; all the
_____

association's members resided in a single, defined metropolitan



____________________

8The Administrative Procedure Act takes a very permissive
view of standing, see 5 U.S.C. 702 (1988), imposing no
___
additional requirements beyond those inherent in Article III.

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area, directly affected by the challenged action.9 In SCRAP,
_____

unlike here, economic damage to individual members was manifest.

In SCRAP, unlike here, the claimed environmental injury was tied
_____

to the particular pursuits of particular persons. We believe

these distinctions are of decretory significance. Even under

SCRAP's rather relaxed regime, we cannot find standing in the
_____

instant case.

We note, moreover, that the Court has lately limited

SCRAP to its particular facts, observing that SCRAP's "expansive
_____ _____

expression of what would suffice for [5 U.S.C.] 702 review . .

. has never since been emulated by this Court." Lujan, 110 S.
_____

Ct. at 3189. In light of Lujan, the continued vitality of SCRAP
_____ _____

as a divining rod for locating associational standing is highly

questionable. When, as here, an alleged injury involves the use

and enjoyment of natural resources, it is not enough, at least in

the post-Lujan era, that a plaintiff possesses some generalized,
_____

undifferentiated interest in preserving those resources. Rather,

as Professor Chemerinsky has concluded, a plaintiff, to secure

standing, "must show that he or she uses the specific property in

question." Erwin Chemerinsky, Federal Jurisdiction 2.3.2
_____________________


____________________

9To be sure, in moving to intervene, NWF alleged that it had
79,000 "members and supporters" in Massachusetts. But, it did
not name even one of them. It did not attempt to distinguish
between members and non-members. It did not restrict its claims
of harm to its local members. It did not mention whether any
members lived in close proximity to the harbor area. When one
contrasts a state the size of Massachusetts with the confined
geographic area of New Bedford Harbor, it is apparent that
residing in Massachusetts, without more, furnishes an inadequate
basis for a claim of particularized injury.

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(Supp. 1990). No such showing has been made in the instant case.

For these reasons we find NWF's allegations of

environmental injury to be insufficiently specific to sustain a

claim of associational standing.

C. Procedural Harm.
C. Procedural Harm.
_______________

The second part of NWF's quest for standing involves a

claim that NWF's members were deprived of their full right to

comment on the consent decree because the plaintiffs failed to

comply with certain provisions of CERCLA. NWF argues that, since

the consent decree caps the defendants' payments, it effectively

determines the extent and scope of the "plan for remedial

action," thereby nullifying the public's statutorily guaranteed

"opportunity for submission of written and oral comments" prior

to "adoption" of such a plan. 42 U.S.C. 9617(a). As an

adjunct to this theme, NWF also argues that by failing to

promulgate a final cleanup plan before soliciting public comment

on the proposed consent decree, the federal government has

undermined the public's statutory right to provide meaningful

comment on the decree prior to "its entry by the court as a final

judgment." 42 U.S.C. 9622(d)(2)(B).

These somewhat convoluted contentions amount to an

overall claim of procedural harm. The claim comprises more cry

than wool. While harm resulting from an agency's refusal to

follow statutorily required procedures may in some instances

constitute an actual injury sufficient to confer Article III

standing, see Defenders of Wildlife v. Lujan, 911 F.2d 117, 121
___ ______________________ _____


21














(8th Cir. 1990), cert. granted, 111 S. Ct. 2008 (1991); Munoz-
_____ _______ ______

Mendoza, 711 F.2d at 428; cf. Sierra Club v. Marsh, 872 F.2d 497,
_______ ___ ___________ _____

504 (1st Cir. 1989), this is not such a case.

1. Previously Addressable Harm. In the first place,
1. Previously Addressable Harm.
___________________________

NWF appears to have waited too long to premise standing on a

theory of procedural harm. Contrary to appellant's bald-faced

assertions before us, its motion to intervene alleged only a

claim of environmental harm. The closest it came to an
_____________

allegation of procedural harm was to say in its motion that:
__________

There also exists, as already has been
demonstrated in the proposed decree, the
potential for the parties to "bargain away"
the interests of NWF and its members, which
is to assure that the remedy agreed to is
appropriate, protective of NWF and its
members, and in compliance with CERCLA.

We do not think that this general statement can be construed to

assert a claim of procedural harm to NWF's members bottomed upon

the denial of their right fully and effectively to comment under

42 U.S.C. 9617(a), 9622(d)(2)(B). Rather, the quoted

sentence, read in context, is an amplification of one of NWF's

substantive arguments nothing more.10

By the same token, NWF's conduct of the litigation

focused exclusively on its claims of environmental harm. Its

complaint in intervention sought relief only against the

____________________

10Indeed, we doubt whether this type of procedural harm is
consistent with, or falls within, the scope of the permitted
intervention which was limited, at NWF's own suggestion, to
legal issues concerning the measure of damages, the requirements
for cleanup, and the requirements for entering a consent decree.
See Acushnet, 712 F. Supp. at 1022-23. NWF's claim of procedural
___ ________
harm does not appear to fit within this taxonomy.

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corporate defendants. Its response to the plaintiffs' motion for

entry of the consent decree neither mentioned nor alleged

abridgement of members' rights to comment. At the "decree

confirmation" hearing held in the district court, NWF's counsel

made only substantive arguments, eschewing any reference to the

incidence of a procedural injury. Because NWF failed in any way

to raise the issue of procedural harm in the court below,

notwithstanding that court's capability to redress such harm (if

any existed), NWF cannot now be allowed to predicate appellate

standing on that foundation.

2. Absence of Actual Injury. Even if appellant's
2. Absence of Actual Injury.
__________________________

claim of procedural harm were properly before us, it would not

salvage the day.

There is nothing talismanic about the phrase

"procedural harm." A party claiming under that rubric is not

relieved from compliance with the actual injury requirement for

standing. See, e.g., Munoz-Mendoza, 711 F.2d at 425-26
___ ____ _____________

(requiring, as a precondition to standing, that plaintiffs who

allege procedural harm also show "injury in fact"). Thus, one

who asserts procedural harm as the basis for standing must set

forth particulars that serve to indicate a distinct and palpable

injury. Warth, 422 U.S. at 501. Put bluntly, a party must set
_____

forth a sufficient panoply of facts to show that his injury is

real as opposed to being theoretical or abstract. See Capital
___ _______

Legal Found. v. Commodity Credit Corp., 711 F.2d 253, 258 (D.C.
____________ _______________________

Cir. 1983) (holding that a plaintiff's claim of injury stemming


23














from alleged procedural harm is insufficient to ground standing

where the harm is "uncoupled from any injury in fact, or tied

only to an undifferentiated injury common to all members of the

public"). In the case of an association, this translates to a

requirement that at least one of the organization's members is

"suffering immediate or threatened injury as a result of the

challenged action." Warth, 422 U.S. at 511.
_____

In this instance, NWF wholly failed to show, or even

supportably to allege, that any member suffered a cognizable

injury stemming from the supposedly inadequate opportunity to

comment. A mere inability to comment effectively or fully, in

and of itself, does not establish an actual injury.11 Here,

the actual injury, if there is any, can only stem from the

potential for an inadequate cleanup of the New Bedford Harbor

area rather than from an alleged impairment of the citizenry's

right to comment. It follows ineluctably that, in order for

standing to arise out of procedural harm, NWF must show that its

members have suffered, or are imminently in danger of, some

distinct and palpable injury flowing from the possibility of an

inadequate cleanup. Cf., e.g., Defenders of Wildlife, 911 F.2d
___ ____ ______________________

at 120-21 (refusal of Secretary of Interior to follow statutory

consultation procedures prior to issuing new regulations

____________________

11We assume, for argument's sake, but without deciding, that
appellant could show some curtailment in this respect. We note,
however, that appellant was afforded, and vociferously exercised,
a right to comment both administratively (before the federal
government moved for entry of the consent decree) and judicially
(when the district court held a hearing to consider placing its
imprimatur on the decree).

24














regarding Endangered Species Act constituted sufficient injury

for standing where plaintiff organization had established that it

had members who "had visited, and planned to visit again, the

endangered species or their habitat in the areas that may be

affected"); Munoz-Mendoza, 711 F.2d at 427-28 (failure of
_____________

Department of Housing and Urban Development to follow proper

procedure in approving a grant constituted sufficient injury for

standing only as to those plaintiffs who alleged that they lived

in the affected area, that their neighborhood was currently

integrated, that they had an interest in living in an integrated

neighborhood, and that the grant would skew the racial mix

through increased gentrification). As we have already

demonstrated, see supra Part V(B), NWF failed to make this
___ _____

showing.

In short, appellant cannot make an end run around the

requirement of actual injury. NWF bore a burden, to the extent

its standing was dependent on a claim of procedural harm, to limn

with fair specificity some concrete nexus between its members and

the harbor area. Without such a nexus, any procedural harm its

members suffered was common to all members of the public and,

therefore, did not rise to the level of stating an individualized

claim of harm. See Warth, 422 U.S. at 499; Schlesinger, 418 U.S.
___ _____ ___________

at 220; see also Erwin Chemerinsky, Federal Jurisdiction 2.3.5
___ ____ _____________________

(1989); 13 Charles A. Wright, Arthur R. Miller & Edward H.

Cooper, Federal Practice & Procedure 2d 3531.10 (1984).
___________________________________

Inasmuch as NWF failed to allege with the requisite particularity


25














that any of its members risked a distinct and palpable injury if

the cleanup of the harbor fared poorly, the allegation of

procedural harm portrayed an injury that was both hypothetical

and undifferentiated. Consequently, we find NWF's embryonic

allegations of procedural harm impuissant to sustain a claim of

associational standing. See Wilderness Society v. Griles, 824
___ __________________ ______

F.2d 4, 19 (D.C. Cir. 1987) (where plaintiffs lack standing to

challenge an agency's substantive actions, they similarly "lack

standing to challenge the procedural defects in the process that

produced those actions").

VI. CONCLUSION
VI. CONCLUSION

To recapitulate, NWF premised its intervention into

this remedial action on the divergence between its views and the

views of the named plaintiffs concerning the appropriate measure

of damages. NWF knew from the start that the district court

action might well end in the entry of a decree with which NWF

and NWF alone disagreed.12 NWF was on notice that, under the

clear mandate of Diamond v. Charles, 476 U.S. 54, it would be
_______ _______

unable to appeal such a decree without meeting the requirements

of federal standing. Despite its knowledge of these realities,

NWF chose to file a motion for intervention that contained only

the vaguest and most conclusory allegations in connection with

standing. And, although the appellees raised questions regarding

____________________

12NWF, it must be recalled, took pains to seek and obtain a
right of appeal from the district court. See Acushnet, 712 F.
___ ________
Supp. at 1023. This fact is significant because it indicates an
awareness, early on, that the district court proceedings might
well culminate in a decree satisfactory to everyone except NWF.

26














NWF's standing in their respective responses to the motion to

intervene, NWF elected not to supplement the record or otherwise

address these questions at any time during the long hiatus

between the filing of its motion to intervene and the district

court's approval of the consent decree. Against this backdrop of

inaction, NWF can scarcely be heard to complain when an easily

anticipated application of Article III results in the dismissal

of its appeal.

We need go no further. Because NWF has failed, despite

ample opportunity, to place in the record specific facts

sufficient to support standing, its appeal must be dismissed.



The appeal is dismissed for want of appellate
The appeal is dismissed for want of appellate
_______________________________________________________

jurisdiction. Costs to appellees.
jurisdiction. Costs to appellees.
____________ __________________


























27