concurring and dissenting:
The majority today upholds a district judge’s self-appointment as de facto Secretary of the Interior over 180 million acres— nearly one-fourth of all federal lands and more than half of the public lands managed by the Bureau of Land Management (“BLM”). It does so without a showing that the BLM breached any legal requirement as to a single parcel of land. Even assuming such a breach, the record is barren of any hint that it was material or likely to harm plaintiffs’ interests — much less irreparably. Unable to sanction such a judicial usurpation of power, I dissent.
Part I addresses various procedural problems, Part II the merits of the preliminary injunction.
I. Procedural Matters
A. Standing
At this point in the proceeding the issue of standing is largely academic. The district court found that Congressman Sieber-ling had standing and did not consider that of the National Wildlife Federation (“NWF”). It marched on with the injunction proceedings that resulted in this appeal. During this process, a record developed that supplemented the vague allegations appearing in NWF’s complaint. By the time the case was submitted to this court, the defendants appear to have conceded the bare minimum necessary for standing.
I write separately on this issue in the hopes of clarifying what a plaintiff must show to meet the injury-in-fact component of standing when it seeks a preliminary injunction. The gaps that lingered for some time in this record appear to have been quite unnecessary.
NWF challenges the legality of two programs — classification terminations and withdrawal revocations — that together affect over 180 million acres of public lands. To bring this challenge NWF must show that each program has impaired, or seriously threatened to impair, its members’ use and enjoyment of either the subject lands or neighboring ones. This requires that NWF (1) identify lands that are affected by each program; (2) demonstrate that third parties are likely to respond to the regula*328tory changes with development activities; and (3) identify activities of members in specific areas that would suffer an adverse impact from such third-party conduct. See, e.g., Sierra Club v. Morton, 405 U.S. 727, 733, 92 S.Ct. 1361, 1365, 31 L.Ed.2d 636 (1972); United States v. Students Challenging Regulatory Agency Procedures (SCRAP), 412 U.S. 669, 688-89, 93 S.Ct. 2405, 2416, 37 L.Ed.2d 254 (1973); Wilderness Society v. Griles, 824 F.2d 4, 10-12 (D.C.Cir.1987).
The specificity required on each of these points is of course a function of the posture of the case. SCRAP, 412 U.S. at 689-90 & n. 15, 93 S.Ct. at 2417 n. 15; Wilderness Society, 824 F.2d at 16. In Wilderness Society, we explained that “while a motion to dismiss may be decided on the pleadings alone, construed liberally in favor of the plaintiff, a motion for summary judgment by definition entails an opportunity for a supplementation of the record, and accordingly a greater showing is demanded of the plaintiff.” Id. We also noted that plaintiff’s opportunity for discovery in resisting summary judgment supported insistence on greater specificity at that stage. Id. at 16 n. 10.
Both Wilderness Society factors — opportunities to supplement the record and to engage in discovery — will normally be present where plaintiff seeks a preliminary injunction.1 Moreover, plaintiff in this context must carry its affirmative burden of showing a likelihood of success on the merits; this necessarily includes a likelihood of the court’s reaching the merits, which in turn depends on a likelihood that plaintiff has standing. It follows that the specificity required for standing allegations to secure a preliminary injunction will normally be no less than that required on a motion for summary judgment.
It is true that SCRAP involved motions to dismiss and for a preliminary injunction, see 412 U.S. at 689 n. 15, 93 S.Ct. at 2417 n. 15, and that the Court’s standing analysis did not distinguish between the two, see id. at 683-90, 93 S.Ct. at 2413-17. However, as the Court concluded that the district court completely lacked jurisdiction to issue an injunction, id. at 690, 93 S.Ct. at 2417, that silence is of little moment.
The Court’s later decisions are at least congruent with the view that a preliminary injunction requires a more powerful showing. In O’Shea v. Littleton, 414 U.S. 488, 94 S.Ct. 669, 38 L.Ed.2d 674 (1974), for example, the Court first found that a complaint against certain judicial officers alleging discrimination in criminal law enforcement and seeking injunctive relief failed to allege a case or controversy because of the speculative character of the injury foreseen. Id. at 493-99, 94 S.Ct. at 675-77. It then observed that the same considerations “obviously shade into those determining whether the complaint states a sound basis for equitable relief,” id. at 499, 94 S.Ct. at 677, and analyzed the complaint under traditional equitable principles — irreparable injury and adequacy of the remedy at law. See also Allen v. Wright, 468 U.S. 737, 760-61, 104 S.Ct. 3315, 3329, 82 L.Ed.2d 556 (1984); City of Los Angeles v. Lyons, 461 U.S. 95, 103, 103 S.Ct. 1660, 1665-66, 75 L.Ed.2d 675 (1983).
The exact degree of specificity required of a plaintiff depends, to be sure, on the nature of its claim and the exigencies of the situation. Thus, where a preliminary injunction was needed simply to preserve files claimed by plaintiffs to substantiate their claims, the court imposed only a modest burden on them. Palmer v. City of Chicago, 755 F.2d 560, 573 (7th Cir.1985). See Wilderness Society, 824 F.2d at 16-17 & n. 10 (on motion for dismissal for want of jurisdiction, Fed.R.Civ.P. 12(b)(1), or motion for summary judgment, court must give plaintiff chance to discover evidence relevant to jurisdiction). And of course if facts relating to standing are put in issue, the court must address those conflicts. See SCRAP, 412 U.S. at 689, 93 S.Ct. at 2416 (“the allegations must be true and capable of proof at trial”); Warth v. Seldin, 422 U.S. 490, 501, 95 S.Ct. 2197, 2206, 45 L.Ed.2d 343 (1975) (“it is within the trial *329court’s power ... to require the plaintiff to supply ... further particularized allegations of fact deemed supportive of plaintiffs standing”). Here, NWF has direct access to the evidence necessary to flesh out its claim of standing. Thus it is appropriate for the court to insist on allegations indicating specifically that defendant’s acts are likely to lead to third-party conduct, in specific places, such as to injure plaintiff’s members in their use of specific lands.
NWF’s submissions were adequate on the identity of the lands affected by the regulatory status changes. Its complaint cites the passages in the Federal Register that affected the challenged classification terminations and withdrawal revocations; these passages identified the lands by legal descriptions. Complaint, Joint Appendix (“J.A.”) at 15-16; Exhibit A, J.A. at 30-47 (citing notice given in Federal Register of each such act). Compare Wilderness Society, 824 F.2d at 12 (plaintiffs’. claim of standing fails because affected lands not identified).
As to the other elements, NWF’s submissions were markedly defective. Its complaint alleges that “[mjembers of NWF use and enjoy the environmental resources that will be adversely affected by the challenged actions.” Complaint, J.A. at 15. This is too vague. The defect is similar to that in Wilderness Society, though not identical. There plaintiffs alleged use of federal lands throughout Alaska, and claimed impairment through transfer of federal lands to the state. We responded that the lands affected by the challenged policy might not overlap with those used by plaintiffs, 824 F.2d at 15, and said that the “absence of specificity regarding location dooms plaintiffs’ claim of threatened injury.” Id. Obviously the requirement of specificity cannot be met by plaintiffs’ simply using broadened allegations (asserting use of “the environmental resources” rather than “various” lands, as in Wilderness Society).
After the injunction issued, NWF attempted to “further particularize[ ]” its allegations by submitting the affidavits of two of its members. Cf. Warth v. Seldin, 422 U.S. at 501, 95 S.Ct. at 2206. The affidavits themselves are still too vague. They merely state that the affiant uses “the federal lands, including those in the vicinity of [the South Pass-Green Mountain area of Wyoming (for one affiant), and the Grand Canyon National Park, the Arizona Strip (Kanab Plateau), and the Kaibab National Forest (for the other affiant)] for recreational purposes and for aesthetic enjoyment.” J.A. at 372, 376. While a court conceivably could match the legal descriptions in the Federal Register with these broad stretches of land, it has neither the legal obligation nor the resources to do so.
Further, NWF’s complaint alleges, again in the most general terms, that private parties will avail themselves of the withdrawal revocations and classification terminations to develop the lands in a manner incompatible with its members’ uses. The affidavits are only slightly more specific, alleging that the lands used by the affiant (or lands in their vicinity) have been “opened to the staking of mining claims,” J.A. at 373, 377, or to oil and gas leasing, J.A. at 373. They do not trace the opening of the lands to either of the two challenged programs, do not assert (much less substantiate) that the “opening” was likely to lead to mining or oil or gas development, and do not specify how such activity would interfere with their uses.
The record, however, provides modest support for the inference that some types of the disputed regulatory status changes have a material likelihood of leading to development activity potentially injurious to the activities of plaintiff’s members on the lands named in the affidavits. BLM data show that withdrawal revocations have opened over 12 million acres to mining, and classification terminations over 800,000 acres. These resulted in the filing of about 7,000 claims and the filing of plans for operations with respect to 540 acres. See J.A. at 64-70, 94-96. 540 acres worth of activity is not much, out of 180,-000,000 acres, but, bearing in mind that threatened environmental damage is also a ground of standing, it seems minimally sufficient. Combined with the concession at oral argument that some of the acreage *330opened to mining was in the vicinity of lands used by one of plaintiffs members in Arizona,2 this seems to me to minimally meet the standing requirement.
B. Exhaustion
In a motion to reconsider the district court’s order granting a preliminary injunction, Mountain States Legal Foundation, a public interest law firm that intervened on the side of the defendants, raised the question of whether plaintiff exhausted available remedies as to the classification terminations. It raised no such claim as to the withdrawal revocations, without explanation. The government defendants make no exhaustion claim at all. The district court rejected the defense. I believe this was an abuse of discretion.
First, the silence of the government defendants might be deemed a waiver. But that appears consistent neither with the principles of exhaustion nor with circuit law. The exhaustion requirement serves not only interests of agency autonomy but also interests of the courts:
Exhaustion generally is required as a matter of preventing premature interference with agency processes, so that [1] the agency may function efficiently and [2] so that it may have an opportunity [a] to correct its own errors, [b] to afford the parties and the courts the benefits of its experience and expertise, and [c] to compile a record which is adequate for judicial review.
Weinberger v. Salfi, 422 U.S. 749, 765, 95 S.Ct. 2457, 2467, 45 L.Ed.2d 522 (1975). The considerations in the second group plainly bear on important concerns of judicial economy. Government neglect cannot force courts to disregard those concerns.
Indeed, this court has not regarded an agency’s failure to invoke the exhaustion defense as a binding waiver. In Asarco, Inc. v. EPA, 578 F.2d 319, 320-21 n. 1 (D.C.Cir.1978), one petitioner raised an argument that another claim had not been made in the administrative proceedings. The court said that indeed the argument had been made, but set out alternative grounds for treating the merits. First, it read the EPA’s silence on the issue as evidence that EPA saw no harm to its institutional interests:
First, EPA itself did not move for dismissal on grounds of exhaustion or join in intervenors’ motion. The agency’s failure to insist upon exhaustion in this particular case suggests that, in EPA’s view, the costs — in terms of interfering with agency proceedings, creating an incentive to ignore agency processes in the future, and depriving the agency of a greater opportunity to apply its expertise or of a chance to “correct its own errors” —do not outweigh the benefits of this court’s immediate consideration of Sierra’s petition. See K. Davis, Administrative Law of the Seventies § 20.00 (1977 Supp.); cf. Weinberger v. Salfi, 422 U.S. 749, 764-67, 95 S.Ct. 2457, 45 L.Ed.2d 522 (1975).
Id. The court then invoked two additional factors in support of dispensing with the requirement: first, the issues were purely ones of law, not requiring “a record of fact-finding developed by an agency with special expertise”; second, as other parties had raised “essentially the same question,” it was appropriate to consider both at the same time. Id. Obviously the court regarded agency silence as something to be considered, but not a dispositive factor. Cf. Granberry v. Greer, — U.S. -, 107 S.Ct. 1671, 95 L.Ed.2d 119 (1987) (in habeas action by state prisoner, state’s failure to raise exhaustion defense in federal district court does not bar court of appeals from dismissing for want of exhaustion; but failure to exhaust is not jurisdictional).
Given the discretionary character of the exhaustion defense, this court may only reverse if it finds that the district court’s disposition of the issue was an abuse of *331discretion. Hayes v. Secretary of Defense, 515 F.2d 668, 674-75 (D.C.Cir.1975); Industrial Workers of the World v. Clark, 385 F.2d 687, 692 (D.C.Cir.1967), cert. denied, 390 U.S. 948, 88 S.Ct. 1036, 19 L.Ed.2d 1138 (1968); Southeast Alaska Conservation Council v. Watson, 697 F.2d 1305, 1309 (9th Cir.1983).
In rejecting the exhaustion defense, the district court characterized the issues in this case as purely “legal.” J.A. at 169. As my substantive analysis should make clear, that characterization simply neglects the core issue in the case: whether the land use plans used by the BLM in terminating classifications failed in any material way to live up to the standards imposed by the Federal Land Policy and Management Act (“FLPMA”), 43 U.S.C. § 1701 et seq. (1982). Had plaintiff sought review in the Board of Land Appeals, the Board would have compared the land use plans actually relied upon by the BLM (discussed below at pp. 19-20), and evaluated them for compliance with FLPMA § 202(d), 43 U.S.C. § 1712(d), the provision here alleged to have been violated. If it found any deficiencies in the plans, it would presumably have considered whether correction of any of those deficiencies would have any prospect of affecting the planning outcome; in so doing it would have assessed the potential impact on the substantive values involved, including plaintiffs environmental interests. Thus the issues that would have been before the Board (and are now before us) seem to me as fact-rich as one can imagine. This case implicates, as strongly as possible, the values of allowing the agency to correct possible errors, to employ its expertise, and to build an intelligible record for judicial review.
The district court also found that the department regulation permitting review of BLM decisions by the Interior Board of Land Appeals did not open the door to one in plaintiffs position. It reads:
(a) Any party to a case who is adversely affected by a decision of an officer of the Bureau of Land Management or of an administrative law judge shall have a right to appeal to the Board....
43 C.F.R. § 4.410(a) (1986). See J.A. at 167.
Plaintiff had not been a “party” to a “case” before the BLM. But at least where there has been no formal adjudication before the BLM, the Board appears not to insist on any particular kind of participation before the agency. For example, in Desert Survivors, 80 IBLA 111 (1984), the Board said plainly, “As one adversely affected by a BLM decision on a protest, appellant is a party to the case.” Id. at 113. It went on to note that appellant had been an active participant in the planning of the Wilderness Study area in question and the development of the mining plan at issue; but it in no way suggested that this was a requirement of standing. While the Board might conceivably limit appeal to participants below, Desert Survivors hardly stands for the proposition that it now does so. Even if it did, plaintiff itself claims to have corresponded on these matters with high-level officials within the Department for over a year, Brief for Appel-lee at 56, and offers no reason to believe that such involvement would not meet whatever precondition might possibly be inferred from Desert Survivors.
The only other decision to which anyone has called our attention, Park County Resource Council, Inc. v. Department of Agriculture, 613 F.Supp. 1182 (D.Wyo.1985), aff'd on other grounds, 817 F.2d 609 (10th Cir.1987), appears of marginal relevance. Plaintiffs sought review of challenges to the BLM’s issuance of (1) an oil and gas lease and (2) a drilling permit. The district court applied the doctrine of exhaustion to the lease dispute, as plaintiff had never sought IBLA review. This obviously reflected the court’s assumption that IBLA review was available. As the point was evidently not argued, and we have no information about plaintiffs’ participation before the BLM, the court’s assumption sheds no light on the proper construction of § 4.410(a). On appeal, the Court of Appeals for the 10th Circuit rejected the district court’s application of exhaustion to the lease dispute, on a variety of grounds. Insofar as it found IBLA unavailable as an administrative avenue of redress, it did so *332only on the grounds that the time limit had run. 817 F.2d at 619. I do not take the majority here to be adopting the view that exhaustion is excused whenever parties let the time for administrative review expire, a proposition as novel as it would be destructive.
Finally, the district court believed that exhaustion would be futile, that the record showed the department irreversibly committed to its view of the law. J.A. at 169. But departmental commitment to a particular view of the law would not show futility at all: administrative proceedings focused on the actual decisions and tracts would undoubtedly have clarified the relation between facts and law, the critical element in this case.
Accordingly, I believe the district court abused its discretion in rejecting the exhaustion defense.
C. Indispensable parties
Federal Rule of Civil Procedure 19 orders the joinder of certain parties where it is feasible to do so, and it appears to be assumed on all hands that this standard is met by the holders of certain types of property interests on the public lands affected by this litigation: those whose titles (perfected or inchoate) depend upon terminations or revocations made since January 1,1981. Such parties’ interests are directly affected by the district court’s preliminary injunction (in its ultimate form), for it bars the defendants from taking any administrative action dependent on such terminations or revocations, “including, but not limited to” granting of rights-of-way or approval of plans of operations. Thus, for example, the holder of a mineral lease will not be able to secure approval of any application for a permit to drill; without the permit, of course, he cannot make his lease productive. Similarly, a holder of mining claims will not be able to secure approval of plans of operations, which is required for operations involving five or more acres, see 43 C.F.R. § 3809.1-4 (1986); this disability condemns such claims at least temporarily to barrenness.
When such parties are identified under Rule 19(a) and cannot be joined, Rule 19(b) requires the court to consider four factors in choosing whether the litigation should proceed or be dismissed:
The factors to be considered by the court include: first, to what extent a judgment rendered in the person’s absence might be prejudicial to the person or those already parties; second, the extent to which, by protective provisions in the judgment, by the shaping of relief, or other measures, the prejudice can be lessened or avoided; third, whether a judgment rendered in the person’s absence will be adequate; fourth, whether the plaintiff will have an adequate remedy if the action is dismissed for non-join-der.
The district court proceeded through the required analysis, finding the balance to tilt in favor of permitting the suit to continue. Courts of appeals typically review such findings under an “abuse of discretion” standard. See Northern Alaska Environmental Center v. Hodel, 803 F.2d 466, 468 (9th Cir.1986); Pulitzer-Polster v. Pulitzer, 784 F.2d 1305, 1309 (5th Cir.1986); Envirotech Corp. v. Bethlehem Steel Corp., 729 F.2d 70, 75 (2d Cir.1984). Here I believe there has been no abuse.
The district court understandably stressed item four — the difficulties that plaintiff would encounter if unable to proceed here. J.A. at 147-48. If application of Rule 19 to this situation generated the principle that the administrative challenge could not proceed in the absence of such property owners, then plaintiff could secure adjudication only by bringing separate suits in each of the 17 states where federal land has been affected by the asserted administrative delinquencies. Normally 17 suits would not seem a hopelessly large number for litigation affecting 180 million acres of land. Each lawsuit would apply on average to more than 10 million acres, which for most of us is quite a lot. Nonetheless, it would entail a multiplication of the litigation, perhaps for little advantage.
On the other hand, the district court squarely confronted the difficulties that *333non-participation could inflict on the absentees. By forcing the defendants automatically to deny approval of plans of operations, the injunction denies mining claimants exclusive possessory rights to which they are otherwise entitled by law, 30 U.S. C. § 26 (1982). It erects similar barriers to mineral lessees. (The majority’s suggestion that the “right [of holders of such property interests] to use and enjoyment of that property is not affected by the court’s order,” Maj. at 315, is simply incorrect. And see Sierra Club v. Peterson, 717 F.2d 1409, 1414 (D.C.Cir.1983) (under usual mineral lease Interior has no absolute right to preclude development).) Further, the court noted that as only the absent parties could measure the value of their interests and the effect of the prospective impairments, the presence of defendants and intervenor Mountain States Legal Foundation was not a complete substitute for their own direct involvement. J.A. at 146-47.
Nevertheless, seeing little impact from the other two Rule 19 factors — the risk that a judgment rendered in the absence of the omitted parties might not afford plaintiff adequate relief and the court’s ability to reduce the prejudice to absentees by the shaping of relief — the court found dismissal unsuitable.
Of course under the Due Process clause of the Fifth Amendment persons normally cannot be bound by litigation to which they were not parties or privies. Parklane Hosiery Co. v. Shore, 439 U.S. 322, 327 n. 7, 99 S.Ct. 645, 649 n. 7, 58 L.Ed.2d 552 (1979) (“It is a violation of due process for a judgment to be binding on a litigant who was not a party nor a privy and therefore has never had an opportunity to be heard”); Hansberry v. Lee, 311 U.S. 32, 40, 61 S.Ct. 115, 117, 85 L.Ed. 22 (1940). We may assume, then, that the absentees are not legally bound by this adjudication. Yet their interests are severely affected, in the ways acknowledged by the trial court.
In considering whether this outcome is acceptable under Rule 19 and the Due Process clause, the remedies available to the absentees are surely relevant. Assuming that they are not legally bound, I take it that, for example, a mineral lessee that was denied a drilling permit to which it would otherwise be entitled could seek judicial relief against the BLM. A federal court outside this district would not be bound by the decision in the trial court or here, and, if it viewed the law differently, might order relief. In addition, such parties could protect their interests — at some expense — by intervening in the litigation here. (Their interest in the stare decisis effect of this litigation would likely entitle them to intervention as of right under Fed. R.Civ.P. 24(a)(2); see Nuesse v. Camp, 385 F.2d 694, 701-02 (D.C.Cir.1967); Atlantis Development Corp. v. United States, 379 F.2d 818 (5th Cir.1967).)
Moreover, administrative litigation commonly inflicts drastic effects on absent third parties. Perhaps the most radical example is that culminating in Phillips Petroleum Co. v. Wisconsin, 347 U.S. 672, 74 S.Ct. 794, 98 L.Ed. 1035 (1954), imposing federal price controls on independent gas producers’ wellhead sales of gas into the interstate market. Legal interpretations emerging from such proceedings are legitimized (we hope) by the crucible of litigation —the presence of parties motivated to present a neutral court with the most persuasive arguments. Though the parties here are not complete substitutes for the absent ones, as the district court acknowledged, the potential unfairness seems in accord with what we often tolerate.
II. The Preliminary Injunction
As relevant here, NWF has challenged (1) the Secretary’s termination of classifications — covering 160.8 million acres of federal land — without legally sufficient “land use plans” and (2) the Secretary’s revocation of withdrawals — affecting 20 million acres — without adequate public participation. In order to prevent these actions from leading to shifts in the character of the lands until its claims are adjudicated, NWF sought and obtained a preliminary injunction staying the effects of the Secretary’s actions.
“It goes without saying that an injunction is an equitable remedy. It ‘is not a *334remedy which issues as of course.’” Weinberger v. Romero-Barcelo, 456 U.S. 305, 311, 102 S.Ct. 1798, 1802, 72 L.Ed.2d 91 (1982) (citation omitted). A party seeking a preliminary injunction must prove that the balance of four elements favors such relief:
(1) the plaintiff's likelihood of success on the merits; (2) the threat of irreparable injury to the plaintiff absent the injunction; (3) the possibility of substantial harm to other parties caused by issuance of the injunction; and (4) the public interest.
Maj. at 318 (citing Weinberger v. Romero-Barcelo, 456 U.S. 305, 312-13, 102 S.Ct. 1798, 1803, 72 L.Ed.2d 91 (1982); Washington Metropolitan Area Transit Commission v. Holiday Tours, Inc., 559 F.2d 841, 842-43 (D.C.Cir.1977)). I believe that NWF fails this test.
A. Classification Terminations
NWF maintains that the Secretary has violated § 202 of FLPMA, 43 U.S.C. § 1712 (1982), by terminating land classifications on 160.8 million acres of federal lands without adequate land use planning. The Secretary has terminated a classification order only if it fell within one of four categories:
a. The order does not include any segregative language, e.g., merely “classified for retention,” since the retention-disposition issue was resolved by Section 102 of FLPMA.
b. The order segregates against applications under laws which were repealed by FLPMA.
c. The order segregates against discretionary land laws ... and a Management Framework Plan (MFP), Resources Management Plan (RMP), or special area plan ... is in place and provides an adequate basis for acting on applications which may be filed under those laws.
d. The order segregates against operation of the mining laws, but the lands involved do not contain minerals of more than nominal value, ... and there has been no serious interest expressed in mineral development.
Organic Act Directive No. 81-11, at 2 (June 18, 1981), J.A. at 97-B.
It seems highly unlikely that the reclassi-fications falling in categories (a), (b) or (d) would result in any new entry, development or disposal. Indeed, NWF makes no such claim. Rather, it focuses its attack on a subset of category (c) reclassifications— those based on MFPs, a designation used by the BLM for plans prepared before the adoption of FLPMA. (There is no revelation by the district court why the injunction should address reclassifications under (a), (b) or (d).)
Section 202(d) provides that “[t]he Secretary may modify or terminate any [land] classification consistent with ... land use plans” that have been “developed pursuant to this section.” 43 U.S.C. § 1712(d) (1982) (emphasis added). Section 202(c) enumerates nine criteria for the development of plans3 and § 202(f) requires the Secretary *335to provide an opportunity for public involvement. 43 U.S.C. §§ 1712(c), (f). Since MFPs by definition antedate FLPMA, NWF argues that they have necessarily not been “developed pursuant to this section [§ 202],” and accordingly do not provide a legal basis for reclassification. See Brief for Appellee at 27-30.
NWF’s theory builds, of course, entirely on a negative pregnant: from the authorization of classification decisions based on § 202 plans, it infers an absence of authority to make such decisions without them. In fact the full context of § 202 militates against drawing such an inference in the rigid form required for NWF to prevail.
In enacting FLPMA, Congress made clear not only its familiarity with the BLM’s land use planning procedures, but its approval. It seems fair to infer that Congress contemplated reliance on pre-FLPMA plans when they substantially conformed to the process specified in § 202, at least for some time.
FLPMA arose in large part out of the Report of the Public Land Law Review Commission, One Third of the Nation’s Land (1970), which specifically appraised the quality of land-use planning by the BLM. Far from finding the existing practices defective, it appeared to regard them as deserving codification. First the authors described the process:
BLM’s recent [land use planning] efforts appear to require consideration of the following general categories of factors in varying degrees: physical and locational suitability of the lands or resources for obvious purposes; supply of resources and demand for resource products; communities and users dependent on the public lands and resources; environmental factors; impact on state and local governments; efficiency of resource use and sustained yield of renewable resources; and regional economic growth.
Id. at 46. Then it commended them and proposed their use by Congress as at least the foundation of a codified scheme for land-use- planning:
We have profited by this implementation of the Classification and Multiple Use Act and endorse the general planning approach embodied in that system. It is now time for Congress to rely on this experience by establishing legislatively those factors that should be considered in all Federal land use planning. The factors identified in the preceding paragraph provide an adequate starting point.
Id.
The elements identified in the first paragraph clearly correspond to a large degree with those specified in § 202. Congress apparently accepted the Commission’s favorable judgment. The House Committee Report observed:
The Committee is well acquainted with the land use planning systems of the Bureau of Land Management and the Forest Service and has found them to be consistent in general principles and practices with the objectives of H.R. 13777.
H.R.Rep. No. 94-1163, 94th Cong., 2d Sess. 5 (1976), reprinted in 1976 U.S.Code Cong. 6 Admin.News 6175, 6179.
The legislative history thus suggests two points: First, as the statutory mandate for *336§ 202 plans was derived from BLM practice, there is every reason to suppose that pre-FLPMA plans, or at least many of them, would substantially correspond to the statutory requirement. Second, in view of that congruence, Congress is likely to have expected that the BLM would employ MFPs rather than, in every case, re-invent the wheel. The district court in fact acknowledged that the “MFP’s [sic] may confirm [sic] to the general principles of the FLPMA,” but then asserted that “they are not identical substitutes to RMP’s [sic] [post-FLPMA plans developed in explicit effort to comply therewith]. The land use plans Congress envisioned would modify existing plans in several aspects, including public participation.” J.A. at 153. Though obscure, the record here suggests that the MFPs used to effect reclassifications did conform to the requirements of § 202, most particularly including public participation.
The Department of Interior has promulgated regulations allowing the BLM to rely on an MFP to terminate a classification only if the MFP meets criteria closely paralleling those of § 202. Under 43 C.F.R. § 1610.8(a)(1) (1986), MFPs can support re-classifications only where they [1] “shall have been developed with public participation and governmental coordination....” and [2] “shall be in compliance with the principle of multiple use and sustained yield.” Assuming that Interior has adhered to this regulation (and there are no claims of non-adherence), the first criterion assures that none of the terminations here at issue can have violated § 202 in the single aspect specified by the district court as a potential discrepancy (and the feature most stressed by plaintiff). Moreover, the second criterion — planning in accordance with multiple use, sustained yield principles —is not only the first requirement of § 202(c), but is likely to entail compliance with the other features of its list, e.g., protecting critical environmental areas, inventorying potential resources, considering present and potential uses, considering relative scarcity of the different values involved, and weighing long-term against short-term benefits. Thus the likelihood is very great that the relevant MFPs substantially comply with § 202.
Apart from the implications from 43 C.F. R. § 1610.8(a)(1), the record is a complete blank. We do not know whether any of the plans fell short of other criteria in any significant respect — or in any insignificant one, for that matter. Not a single MFP was before the court. Not one is before us now. This is a novelty: adjudication in a vacuum. None of the judges in this proceeding — neither the district court, the majority, nor I — has any basis for concluding that the MFPs relied on do not mirror RMPs in all substantive respects.
FLPMA and its context support the view that substantial compliance with § 202 should suffice for some time after enactment. Congress explicitly recognized that § 202 land use plans would not come into existence overnight; in a general provision on supervision of the public lands, it directed the Secretary to manage them pursuant to such plans “when they are available.” 43 U.S.C. § 1732(a). Of course this general clause could co-exist with congressional insistence on 100% pure § 202 plans for classification decisions, but it surely counsels against finding a highly restrictive negative pregnant in § 202(d). A comparison of FLPMA with Congress’s 1976 amendments to the Forest and Rangeland Renewable Resources Act of 1974, adopted the day after FLPMA, also militates against such an absolutist view. There Congress directed the Secretary of Agriculture to “attempt to complete” the upgrading of national forest planning by September 30, 1985. See 16 U.S.C. § 1604(c) (1982). Congress not only “knew how” to impose a deadline, as the saying goes, but when it did so in a parallel instance on almost the same day, it allowed nearly a decade and even at that required only an “attempt.”
The district court recognized that the statute contemplated “temporary” reliance on MFPs, but concluded that the BLM had exceeded the limits of this tolerance. J.A. at 153.4 Therefore it concluded that NWF was substantially likely to prevail on the *337merits of its claim. The district court did not explain its apparent belief that reliance on MFPs should become unlawful at some specific date — regardless of how closely the MFPs conformed to the substance of § 202.
These considerations carry still worse implications for plaintiff when we turn to the issue of irreparable harm. Harm for such purposes is of course defined in terms of the evil that the particular statute was designed to prevent. Thus, in Amoco Production Co. v. Village of Gambell, — U.S. -, 107 S.Ct. 1396, 1403, 94 L.Ed.2d 542 (1987), the defendants had neglected to hold certain hearings and to make certain findings. The Court (assuming the applicability of the requirements and their violation) held that an injunction was improper, in light of district court findings that the conduct enjoined would not adversely affect “subsistence uses” of land, the statutorily protected value. Id. at 1403-04. The court below, it observed, “erroneously focused on the statutory procedure rather than on the underlying substantive policy.” Id. at 1403. See also Weinberger v. Romero-Barcelo, 456 U.S. at 314, 102 S.Ct. at 1804.
Here, even if we assume illegality under § 202, the district court had no basis for finding that such illegality would likely generate an adverse effect on the values implemented by § 202. That section manifests an intent that the public lands be managed in accordance with a planning approach that balances the many potential values to which they may be put and that allows public participation in that process. See note 3, supra. As the district court did not review a single MFP, plainly it was in no position to find that any fell materially short of fulfilling those purposes. What little we know suggests that there was no such shortfall. Cf. Natural Resources Defense Council, Inc. v. Hodel, 624 F.Supp. 1045 (D.Nev.1985) (reviewing and upholding MFP relied on by BLM after December 1982 for livestock grazing decision), aff'd, 819 F.2d 927 (9th Cir.1987). Moreover, it may well be that the bulk of the developmental activities restricted by the preliminary injunction would occur (if not blocked) on lands so barren and so distant from areas of potential recreation that they could not jeopardize plaintiffs recreational interests.
Offsetting this doubtful threat to plaintiffs interests is the obvious effect on the absent holders of interests dependent upon the challenged terminations. For commercial interest holders, an investment is tied up for an indefinite period, all chance of any return denied. Cf. First English Evangelical Lutheran Church v. County of Los Angeles, — U.S. -, 107 S.Ct. 2378, 96 L.Ed.2d 250 (1987). Further, and bizarrely, the preliminary injunction is now preventing land exchanges of such an obviously benign character that even plaintiff favors them. NWF sought to voluntarily dismiss its claim as to a tract slated for exchange by the Forest Service, under which it would give up interests already developed for vacation resort purposes and would secure the one remaining private inholding in an area proposed for Wild and Scenic River study status. See Excerpt of Record for a Writ of Prohibition (“E.R.”) 180-84. The district court, however, hewed to its absolutist view of the law and denied relief. See E.R. 260. The preliminary injunction has also blocked a similar exchange between the Forest Service and the Trust for Public Land. See E.R. 175-79. At no point has the district court made any inquiry into the intersection of plaintiffs and the absentees’ claims — i.e., what areas of potential recreation are potentially threatened by the absentees’ efforts to exercise their entitlements or to proceed with planned transactions.
Finally, the public interest does nothing to tilt the balance in favor of the injunction issued. Congress has manifested a deep interest in environmental concerns, but it has also shown an intention to allow reasonable development of mineral resources on the public lands. See 30 U.S.C. § 21(a) (1982) (it is the “continuing policy of the Federal Government ... to foster and encourage private enterprise in ... the development of economically sound and stable domestic mining ... [and] mineral reclamation industries, [and in] the orderly and *338economic development of domestic mineral resources ... to help assure satisfaction of industrial, security and environmental needs”); 43 U.S.C. § 1701(a)(12) (1982) (announcing policy that “public lands be managed in a manner which recognizes the Nation’s need for domestic sources of minerals”); National Coal Association v. Hodel, 825 F.2d 523, 529-30 & n. 8 (D.C.Cir.1987). Both interests are of great value; but in issuing the preliminary injunction the district court has made no effort to make marginal adjustments: to identify those areas where environmental interests are in real jeopardy from substantive administrative lapses from congressional mandated duties. The denial of relief even for exchanges favored by all parties appears to manifest a legalistic zeal quite inconsistent with the balancing that is required for preliminary injunctions.
Accordingly, there is no basis for the sweeping injunction here issued, halting all steps that the Secretary might take that depend on the challenged terminations.
B. Withdrawal Revocations
Since the passage of FLPMA, the Secretary has issued 671 public land orders revoking withdrawals affecting nearly 20 million acres. J.A. at 61. NWF contends that these actions are illegal because the Secretary failed to provide the public an opportunity to participate in each withdrawal revocation, in violation of FLPMA § 309(e), 43 U.S.C. § 1739(e). That section provides:
In exercising his authorities under this Act, the Secretary, by regulation, shall establish procedures, including public hearings where appropriate, to give the Federal, State, and local governments and the public adequate notice and an opportunity to comment upon the formulation of standards and criteria for, and to participate in, the preparation and execution of plans and programs for, and the management of, the public lands.
The district court found it likely that these limitations applied to the withdrawal revocations. J.A. at 155.
The Secretary argues that § 309(e) is intended to be precatory only, and in the alternative that it covers planning only.
The relation of § 309(e) to FLPMA as a whole lends some support to the Secretary’s view of it as precatory. Section 309(e) is the last subsection of a section providing for the creation and use of citizen advisory councils. That section is in turn the last provision in subchapter III, governing “Administration.” At various points along the way, FLPMA provides explicitly for public participation. Thus, § 204(h) requires a public hearing for new withdrawals. § 204(i) requires, for a special class of revocations, an elaborate, multi-stage review by the President and Congress; beside the requirements of § 204(i), the references in § 309(e) to giving “the Federal government” notice and opportunity to comment appear rather pale. Finally, as noted above, § 202(f) requires public participation in the land-use planning process. The location in a general administrative provision, the generality of language, and the presence of specific mandates elsewhere make it at least plausible to suppose that Congress intended § 309(e) only as an exhortation.
It seems fair to regard § 309(e)’s character as at best ambiguous. Thus under Chevron U.S.A. Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837, 104 S.Ct. 2778, 81 L.Ed.2d 694 (1984), the Secretary’s reading of it as precatory is entitled to deference so long as it is a reasonable one. I believe it passes that test.
The defendants' alternative argument, limiting § 309(e) to planning activities, has some support in the legislative history,5 but seems less plausible. Congress had, after all, explicitly required public participation in the planning process in § 202(f), so that *339renewal of the mandate in § 309(e) would be oddly duplicatory. In asserting the planning-only theory, however, the Secretary points to various mechanisms by which the public is brought into decisions executing the plans. Although the Secretary does not frame the argument as one of substantial compliance, his contentions inevitably suggest such a finding. If there is an opportunity for public participation in the BLM’s exercises of material discretion down the line from planning, it is hard to classify its failure to provide automatically for public participation in withdrawal revocations as a material breach of § 309(e), even assuming it to be mandatory and to encompass individual “management” decisions.
Indeed, key decisions by which the government may shift title to private parties, or otherwise permit development activities, appear to be governed by regulations giving the public a role. The Secretary notes, for example, department regulations requiring the BLM to give public notice before making a land exchange, 43 C.F.R. § 2201.1(a) (1986) (notice to be provided through the Federal Register and local newspapers, and to be sent directly to state and local officials, with a 45-day period for comment). See also id. § 2711.1-2 (1986) (similar, for sales); id. § 2802.4(d) & (e) (similar, for issuance of rights of way); id. § 2741.5(h) (similar, for grants under Recreation and Public Purposes Act, 43 U.S.C. § 869 et seq. (1982)).
The mining laws, however, particularly the Mining Act of 1872, 30 U.S.C. § 21 et seq. (1982), allow entry without BLM issuance of title. This might appear to create a gap. But regulations governing the environmental review process under the National Environmental Policy Act, 42 U.S. C. § 4321 et seq. (1982), appear to close it up. § 5.4B(8), Appendix 5 to Chapter 6, Part 516 of Departmental Manual, appears by implication to require an environmental assessment (“EA”) or environmental impact statement (“EIS”) where termination or revocation would open lands to mining laws and the lands contain minerals of more than nominal value. 47 Fed.Reg. 50371 (Nov. 5, 1982); see also BLM Reply Brief at 17 (so construing § 5.4B(8)). Cf. National Forest Preservation Group v. Butz, 485 F.2d 408 (9th Cir.1973) (requiring a NEPA statement when the government enters an exchange under which private parties will acquire land on which they will engage in activities materially affecting the environment). Other regulations provide for public participation in the preparation of an EA or EIS. See 40 C.F.R. § 1501.4(b) (requiring involvement of the public “to the extent practicable” in preparing EAs); id. § 1503.1(a)(4) (providing for solicitation of public comment in preparation of an EIS). If the BLM follows these regulations as it construes them here, they assure public participation for precisely the withdrawal revocations that might jeopardize plaintiffs interests.
Moreover, even a nominal opening to entry under the mining laws preserves the department’s opportunity to exercise discretion, together with a chance for the public to be heard. Departmental regulations require BLM approval for any mining operations disturbing more than five acres, 43 C.F.R. § 3809.1-4, and the approval process requires an EA, id. § 3809.2-1. If the EA indicates that there is “substantial public interest” in the proposed plan, the officer in charge must arrange for public notice and consideration of public comments. M § 3809.2-l(c).
Again the record on these matters is completely deficient. Although it appears to be conceded that the revocations expose some lands in the vicinity of areas used by plaintiff’s members to the risk of development, see pp. 329-330 supra, there is no evidence suggesting that want of public participation in withdrawal revocation procedures played any material role in creating this risk. If, for example, these revocations followed EAs or EISs under § 5.4B(8) of the Departmental Manual, public notice and opportunity to comment presumably occurred — unless the expected environmental effects were modest.6
*340As in the case of classification terminations, the leap to irreparable injury is an athletic one. If the withdrawal revocations that might lead to actual mining activity were made after public notice and opportunity to comment under § 5.4B(8) of the Departmental Manual, then want of public participation formally linked to § 309(e) would be irrelevant. Similarly, if (1) a revocation occurred without public opportunity for participation, but (2) later discretionary decisions triggered public notice and opportunity to comment, and (3) in those proceedings the fact of revocation did not materially reduce the range of real-world considerations that members of the public could invoke (i.e., considerations other than the technical existence of the withdrawal itself), there would be no harm from the omission. See Amoco Production Co. v. Village of Gambell, 107 S.Ct. at 1403. But none of this is explored. Plaintiff has chosen to paint with a very broad brush, and the district court has accommodated its program. I would remand for examination of these issues.7
Finally, the interests of third parties and the public interest work against the preliminary injunction as they did in the classification context. The injunction bars absentees from exercise of their rights, for an indefinite period; it makes no effort to minimize the aggregate harm to the public interests in both environmental preservation and alternative activities: the district court has allowed environmental interests, however weak and however trivially they may be at risk as to particular tracts, to sweep the other interests off the board.
Though concurring on the finding of standing and satisfaction of Rule 19, I dissent.
. But see infra, for discussion of Palmer v. City of Chicago, 755 F.2d 560 (7th Cir.1985), and the problem of special exigencies limiting those opportunities.
. Counsel for Mountain States acknowledged status changes relating to lands described by the Wyoming NWF member, but stated that these merely opened to mining claims areas not containing minerals of more than nominal value. See p. 334 infra for discussion of classification terminations based on lack of mineral interest. For such areas, the likelihood of private development activity seems too remote to meet the Wilderness Society standard.
. Section 202(c) provides as follows:
(1) use and observe the principles of multiple use and sustained yield set forth in this and other applicable law;
(2) use a systematic interdisciplinary approach to achieve integrated consideration of physical, biological, economic, and other sciences;
(3) give priority to the designation and protection of areas of critical environmental concern;
(4) rely, to the extent it is available, on the inventory of the public lands, their resources, and other values;
(5) consider present and potential uses of the public lands;
(6) consider the relative scarcity of the values involved and the availability of alternative means (including recycling) and sites for realization of those values;
(7) weigh long-term benefits to the public against short-term benefits;
(8) provide for compliance with applicable pollution control laws, including State and Federal air, water, noise, or other pollution standards or implementation plans; and
(9) to the extent consistent with the laws governing the administration of the public lands, coordinate the land use inventory, planning, and management activities of or for such lands with the land use planning and management programs of other Federal departments and agencies and of the States and local governments within which the lands are located, including, but not limited to, the statewide outdoor recreation plans developed under the Act of September 3, 1964 (78 Stat. 897), as amended [16 U.S.C.A. § 4601-4 et seq.], and of or for Indian tribes by, among other things, considering the policies of ap*335proved State and tribal land resource management programs. In implementing this directive, the Secretary shall, to the extent he finds practical, keep apprised of State, local, and tribal land use plans; assure that consideration is given to those State, local, and tribal plans that are germane in the development of land use plans for public lands; assist in resolving, to the extent practical, inconsistencies between Federal and non-Federal Government plans, and shall provide for meaningful public involvement of State and local government officials, both elected and appointed, in the development of land use programs, land use regulations, and land use decisions for public lands, including early public notice of proposed decisions which may have a significant impact on non-Federal lands. Such officials in each State are authorized to furnish advice to the Secretary with respect to the development and revision of land use plans, land use guidelines, land use rules, and land use regulations for the public lands within such State and with respect to such other land use matters as may be referred to them by him. Land use plans of the Secretary under this section shall be consistent with State and local plans to the maximum extent he finds consistent with Federal law and the purposes of this Act.
. The majority appears to repudiate that concession of the district court. Maj. at 321.
. Such history focuses generally on the value of public participation in planning, see, e.g., One Third of the Nation's Land 57 (Recommendation 11); H.R.Rep. No. 94-1163, 94th Cong., 2d Sess. 7 (1976), U.S.Code Cong. & Admin.News 1976, p. 6181 (commentary on draft section that emerged as § 202(f)); but see S.Rep. No. 94-583, 94th Cong., 1st Sess. 106-07 (1975) (correspondence arguably supporting application of § 309(e) to "management" decisions other than planning).
. It seems inescapable that § 309(e), even if mandatory, does not require public partic*340ipation in every management decision. For example, the Secretary’s regulations permit persons to engage in mining activities disturbing an aggregate of five acres or less (including access) per year merely on notice to the Secretary and without his approval. 43 C.F.R. § 3809.1-3 (1986). This excludes the public, but is surely permissible if public participation is not to be insisted upon simply as a fetish.
. In addition, certain of the revocations were subject to § 204(/), which requires the Secretary to review specified withdrawals within 15 years of FLPMA’s enactment and to submit to the President a report giving his recommendations as to whether they should be continued. The President is to forward the report to Congress, along with his recommendations. The Secretary is free to terminate withdrawals only when 90 days have passed without Congress having exercised a legislative veto. The procedure is now obviously questionable under INS v. Chadha, 462 U.S. 919, 103 S.Ct. 2764, 77 L.Ed.2d 317 (1983), as is the status of the Secretary’s authority assuming invalidation of the legislative veto. See Alaska Airlines, Inc. v. Brock, — U.S. -, 107 S.Ct. 1476, 94 L.Ed.2d 661 (1987) (discussing the severability of statutes from their legislative veto provisions). I would remand for consideration of NWF’s claim that the Secretary disregarded the § 204(/) process. Of course, my opinion on the claims under §§ 202(d) and 309(e) is only a dissent. Nonetheless, as the district court has not yet finally resolved the substantive claims, some attention to the § 204(/) claim may be in order in connection with that process if my reading of those sections has any merit.