to Federal control and responsibility.” 40 C.F.R. § 1508.18. “Effects” are defined to “include: • (a) [d]ireet effects, which are caused by the action and occur at the same time and place,” and “(b) [i]ndirect effects, which are caused by the action and are later in time or farther removed in distance, but are still reasonably foreseeable.” Id. § 1508.8. It is undisputed that HUD’s funding of the project is a major federal action. Thus, we must determine whether HUD acted reasonably and in accordance with law in deciding, based on its EA and FONSI, that its action had no direct or indirect effects that significantly affected the quality of the human environment. See Pub. Citizen, 541 U.S. at 763-64, 124 S.Ct. 2204. Plaintiff iate Credit Bank, 727 F.Supp. 1055, 1058 (S.D.Miss.1989) (<HOLDING>); see also Davis Mountains, 116 Fed.Appx. 3,
holding that the trademark manual of examining procedure tmep does not have the force and effect of law holding to the same effect holding that directive not promulgated according to apa procedure lacks force and effect of law holding force to be an element of pre1994 amendment  111 which may be satisfied by proof of force or threat of force recognizing that when an ordinance is not published according to law it is invalid and of no effect