F.3d 772, 778 (9th Cir.2003); see also Nat’l Ass’n of Clean Air Agencies v. EPA, 489 F.3d 1221, 1227-28 (D.C.Cir.2007); West Virginia v. EPA 362 F.3d 861, 868 (D.C.Cir.2004). Plaintiffs also adequately alleged that the Secretary’s action will undermine land management in the Imperial Valley. A county’s “concrete interests” in its “environment and in land management” can establish Article III standing. City of Las Vegas, 570 F.3d at 1114; see also Sausalito, 386 F.3d at 1198 (finding a concrete injury because a project would “result in a detrimental increase in traffic and crowds” and affect “municipal management and public safety functions” (quoting City of Sausalito v. O’Neill, 211 F.Supp.2d 1175, 1186 (N.D.Cal.2002))) (internal quotation marks omitted); City of Davis, 521 F.2d at 671 (<HOLDING>). C. Identification of Facts The Secretary
holding erisas accrual date for limitations period controlled despite contrary language in policy holding that declarations claiming that agency action will frustrate the citys policy of controlled growth and render its planning efforts to date obsolete established a concrete injury holding that allegations of future injury must be particular and concrete recognizing a drain on the organizations resources as a concrete and demonstrable injury recognizing a subsequent agency action as a valid ratification and indicating that the court will not substitute our judgment for that of the agency