by the participation of either organizations’ individual members. Friends of the Earth, 528 U.S. at 180-81, 120 S.Ct. 693. Finally, Plaintiffs’ NEPA and FLPMA claims fall within the statutes’ respective zones of interest. See Kootenai Tribe of Idaho, 313 F.3d at 1113-14. Western Watersheds Project — a non-profit conservation group engaged in advocating science-based management, land restoration, public education, and conservation of BLM’s public lands with thousands of members that study, recreate, and enjoy aesthetic pursuits on the affected grasslands — has a direct interest in seeing that the BLM adequately considers the environmental consequences of its planned action as required by NEPA and that the well-being of the affected land not be threatened. See Cantrell, 241 F.3d at 679 (<HOLDING>). Finally, Western Watersheds Project’s
holding that even though an executive order mandating agency consideration of environmental justice concerns created no private right of action for an agencys failure to comply with that mandate the court would review the agencys action as an exercise of discretion under the apa and nepa holding that the government interest in preventing crime is compelling holding court must insure that agency took hard look at environmental effects of proposed action holding that nsf must comply with procedural requirements of nepa when considering incineration of food waste in antarctica because 1 the presumption against extraterritoriality does not apply because nepa is designed to regulate conduct occurring within the territory of the united states 2 the united states exercises legislative control over antarctica 3 any concerns about nepa interference with foreign policy were overstated because when foreign policy interests outweighed benefits of nepa compliance nepas requirements must yield and 4 broad language of the statute supports broad application of nepa requirements holding that birdwatchers interest in preventing adverse environmental effects from agency action fell squarely within the zone of interests of nepa