dissenting:
The novel issue in this case is whether the Federal Communications Commission’s (FCC or Commission) order disqualifying attorney Chase is a reviewable action. Because along with both parties to the case, *525Chase and the FCC, I conclude that the Supreme Court’s rationale in Richardson-Merrell, Inc. v. Koller, 472 U.S. 424, 105 S.Ct. 2757, 86 L.Ed.2d 340 (1985), does not apply to deny judicial review of a disqualification order under an agency regulation that grants a cause of action to attorneys in their own right to challenge such disqualifications, I would hold that review is proper under 47 U.S.C. § 402(a) and 28 U.S.C. § 2342.
Section 2342 of 28 U.S.C. vests this court with jurisdiction over “all final orders of the Federal Communications Commission made reviewable by section 402(a) of title 47.” In turn, § 402(a) of the Communications Act of 1934, as amended, reads: “Any proceeding to enjoin, set aside, annul, or suspend any order of the Commission under this chapter ... shall be brought as provided by and in the manner prescribed in chapter 158 of Title 28.” 47 U.S.C. § 402(a).1 There can be no question that the FCC’s disqualification order involved in this case is a final order under Administrative Procedure Act standards.
As Judge Ginsburg’s opinion notes, attorney Chase adhered to clear FCC procedure2 and exhausted every channel of internal agency appeal of his disqualification order. The chronology of Chase’s internal FCC appeals is brief. On May 19,1986, the presiding Administrative Law Judge (AU) disqualified him for the alleged representation of two opposing interests in the Bakersfield licensing proceeding. Chase’s client Liberty appealed the disqualification to the Review Board, which affirmed the AU order. In re Owens, 104 F.C.C.2d 848 (Rev.Bd.1986), reprinted in Joint Appendix (J.A.) at 2.3 Then, on August 27, 1986, Chase invoked his Rule 1.301(a)(5) right, supra, to appeal the removal order. Meanwhile, Liberty retained other counsel, and its dispute — proceeding independently from Chase’s disqualification case — was settled by agreement on October 10, 1986. The full Commission did not deny Chase’s disqualification appeal until January, 1987. In re Owens, 2 F.C.C.Rcd 38 (1987). Chase filed the present appeal against the Commission action as a final order reviewable under 47 U.S.C. § 402(a).
Any suggestion that the Commission’s January, 1987 ruling denying Chase’s challenge to his disqualification is not “final agency action” is difficult to fathom. Not only had Chase exhausted every stage of agency appeal, but, decisive for an APA “finality” inquiry, the Commission’s pronouncement conclusively fixed a legal status on Chase. The Commission made its final determination that Chase had been properly disqualified. Precisely such a fixing of a legal relationship is all that is necessary to demonstrate the finality of an agency order for APA purposes. Reuters Ltd. v. FCC, 781 F.2d 946, 947 n. 1 (D.C.Cir.1986); Natural Resources Defense Council, Inc. v. Nuclear Regulatory Commission, 680 F.2d 810 (D.C.Cir.1982).4
*526These relevant facts distinguish our case from Richardson-Merrell,5 The Supreme Court’s avowed purpose in Richardson-Merrell was to arrest further erosion of the final judgment rule through over-extension of the “collateral order” exception. 472 U.S. at 440, 105 S.Ct. at 2766. The Court found that granting immediate review of an interlocutory appeal from a disqualification order rendered by the district court in a civil case would not only promote “piecemeal” litigation, but also elevate attorneys’ desires for vindication above their clients’ interests in proceeding to final judgments in their main cases. Id. at 434-35, 105 S.Ct. at 2763. Both concerns vanish, however, when an agency regulation provides for a separate cause of action between the disqualified attorney and the agency — a cause of action independent of an underlying dispute that may be settled prior to final decision on the attorney's petition. Cf. In re Schmidt, 775 F.2d 822, 823 (7th Cir.1985) (order that is “both independent of the merits and irremediable on appeal” would be immediately appealable under Richardson-Merrell). In Richardson-Merrell, the Court viewed the only “case or controversy” as that between the main parties to the civil case; the attorney was in effect treated as an agent or extension of the client. In this case, however, the FCC has created a cause of action against the agency for attorneys who are disqualified in proceedings before the FCC. A subsequent appeal to the courts clearly involves a genuine justiciable controversy between the attorney and the agency.
Chase’s aggrievement by a final FCC order adjudicating his separate complaint against the agency thus places him outside the contours of Richardson-Merrell.6 It does not end the reviewability inquiry, however. Judicial determination may be foreclosed where “statutes preclude judicial review....” 5 U.S.C. § 701(a)(1). If the withholding of judicial review is not express, however, there must be clear and convincing evidence of Congress’ intent to deny judicial review. See H.R.Rep. No. 1980, 79th Cong., 2d Sess. 41 (1946) (“To preclude judicial review under this bill [APA] a statute, if not specific in withholding such review, must upon its face give clear and convincing evidence of an intent to withold it. The mere failure to provide specially by statute for judicial review is certainly no evidence of intent to withhold review.”); see also Morris v. Gressette, 432 U.S. 491, 501, 97 S.Ct. 2411, 2418, 53 L.Ed.2d 506 (1977); Abbott Laboratories v. Gardner, 387 U.S. 136, 140, 87 S.Ct. 1507, 1510-11, 18 L.Ed.2d 681 (1967). None of the parties, nor my colleagues, has proffered any language from the legislative history of the Communications Act of 1934, 47 U.S.C. §§ 151 et seq. (Communications Act), committing FCC decisions that affect attorneys entirely to the agency’s discretion.
Another requisite to a judicial appeal is standing. Chase’s standing under 5 U.S.C. § 702 as a person aggrieved by agency action seems quite clear. Moreover, the guidelines specified by the Supreme Court in Association of Data Processing Service Organizations, Inc. v. Camp, 397 U.S. 150, 90 S.Ct. 827, 25 L.Ed.2d 184 (1970), that the party meet the “case or controversy” test of Article III of the Constitution by demonstrating that the agency action caused the petitioner an “inquiry in fact,” are satisfied. See also Allen v. Wright, 468 U.S. 737, 751, 104 S.Ct. 3315, 3324, 82 L.Ed.2d 556 (1984) (Article III standing requirement *527incorporates three elements of (a) personal injury, (b) fairly traceable to defendant’s allegedly unlawful conduct, and (c) likely to be redressed by requested relief). Also relevant to the standing inquiry is the fact that the interest Chase seeks to protect in this case is within the zone of interests that Congress intended to benefit or regulate through the legislation in question, namely, the Communications Act.
The likelihood of reputational and economic injury to Chase from the disqualification order settles the first concern. Chase has a “cognizable interest” in his professional reputation, see Meese v. Keene, — U.S. -, 107 S.Ct. 1862, 1867, 95 L.Ed.2d 415 (1987); see also Southern Mutual Help Association, Inc. v. Califano, 574 F.2d 518, 524 (D.C.Cir.1977), which has been marred by the FCC’s multiple charges of misconduct.7 Reversal of the disqualification order by this court not only would lift this stigma, see id., but also would be likely to redress, at least in part, Chase’s economic injury from the disqualification inasmuch as his future earnings, indeed all attorneys’ fees, turn on professional reputation. See Model Rules of Professional Conduct Rule 1.5(a)(7), cited and annotated in G. Hazard, The Law of Law-yering (1987) (reputation is factor in determining fees to clients),8
With respect to the second aspect of standing, whether a particular plaintiff is “arguably within the zone of interests” Congress intended to benefit or regulate, the Supreme Court has recently reminded this court that this “zone of interests” test was “not meant to be especially demand-ing_” Clarke v. Securities Industry Association, 479 U.S. 388, 107 S.Ct. 750, 757, 93 L.Ed.2d 757 (1987). The Court wrote that “there need be no indication of congressional purpose to benefit the would-be plaintiff,” but rather there must simply be a “plausible relationship” between the litigants’ interests and the policies embodied in “the overall context” of the statute in question. Id. 107 S.Ct. at 758-59. The relevant statutory context in this case is the broad delegation by Congress to the FCC of adjudication of disputes in the broadcasting industry. Specifically, the promulgation of Rule 1.301, which establishes agency adjudicatory procedures, falls under Congress’ charge in the Communications Act that “[t]he Commission may conduct its proceedings in such manner as will best conduce to the proper dispatch of business and to the ends of justice.” 47 U.S.C. § 154(j).9 The plain language of the statute implies broad agency discretion; moreover, the Supreme Court has fully endorsed this wide authority. See FCC v. Schreiber, 381 U.S. 279, 85 S.Ct. 1459, 14 L.Ed.2d 383 (1965). In allowing the FCC wide latitude to organize its internal proceedings, Congress clearly intended that the FCC could regulate attorneys who would appear before the agency.10 Cf. United States v. *528Erika, Inc., 456 U.S. 201, 207 n. 7, 102 S.Ct. 1650, 1653 n. 7, 72 L.Ed.2d 12 (1981) (Secretary of Health and Human Services’ regulations “extends” right of agency review to persons not expressly assured right in statute); Ezell v. Bowen, 669 F.Supp. 141, 143 (S.D.W.Va.1987) (court impliedly recognizes that agency regulation may give rise to legitimate judicial review, though statute does not extend right of review to nonattorney representative). The FCC has quite reasonably decided that the fairness and efficiency of its proceedings are enhanced when the members of the specialized bar who appear before the agency have the opportunity to challenge disqualification orders. See Removal of Counsel From Hearing Proceeding, 59 F.C.C.2d 1384 (1976). The disqualified attorneys therefore fall within the zone of interests of the Communications Act.
In sum, I fear that Judge Ginsburg overlooks the difference between the FCC administrative proceedings involved in this case and Article III district court proceedings when she expands the Richardson-Merrell reviewability bar to a disqualification decision that is a final agency order, which arose from an underlying dispute that has been settled, yet was properly pursued as a separate cause of action under an agency rule that allows disqualified attorneys an independent route to vindication. I would apply traditional rules of reviewability of agency action and reach the merits of the attorney’s appeal.
It strains credulity that a lawyer appearing before an agency may be disqualified in a case on the basis of alleged unethical practices, even misconduct, and, because the client settles the case or refuses to appeal the order, the lawyer forfeits recourse in the courts for the palpable injury to her reputation and future livelihood. Along with both parties to this appeal, I simply do not think that Richardson-Mer-rell meant to take us so far from notions of fundamental fairness.
I respectfully dissent.
. The corresponding provision in the Administrative Procedure Act (APA or "the Act"), which establishes a presumption of reviewability of agency actions, authorizes review of "final agency action” for which there is no other adequate remedy in a court, 5 U.S.C. § 704, and where the party petitioning for review is "adversely affected or aggrieved by [the] agency action within the meaning of the relevant statute.” Id. § 702. I agree with both the FCC and petitioner Chase that these two provisions, which embody the doctrines of finality and standing, have been fulfilled in this case.
. Rule 1.301(a), section 5, reads:
A ruling removing counsel from the hearing is appealable as a matter of right, by counsel on his own behalf or by his client.
47 C.F.R. § 1.301(a)(5) (1986) (emphasis added).
. An agency’s characterization of action as interim is not decisive; courts have authority to consider what is in form an interlocutory administrative order but is in substance a final determination of a person's rights. See, e.g., Carter/Mondale Presidential Committee, Inc. v. Federal Election Commission, 711 F.2d 279, 288 n. 17 (D.C.Cir.1983) (quoting Fidelity Television, Inc. v. FCC, 502 F.2d 443, 448 (D.C.Cir.1974) (per curiam) ("principle of finality in administrative law is not ... governed by the administrative agency’s characterization of its action, but rather by a realistic assessment of the nature and effect of the order”)).
. The two cases cited in Judge Ginsburg’s opinion for the requirement of finality, Illinois Citizens Comm. for Broadcasting v. FCC, 515 F.2d 397, 402 (D.C.Cir.1975), and Bethesda-Chevy Chase Broadcasters, Inc. v. FCC, 385 F.2d 967, 968 (D.C.Cir.1967), dealt respectively with a speaker’s unofficial remarks (not agency action at all) and an agency request that a party amend *526an application. Neither case is analogous to the facts before us, where the disqualification order is undisputed FCC action, indeed the last agency decision on this matter, and where the aggrieved party has exhausted all possible agency relief.
. Thus, I agree with Judge Williams that Richardson-Merrell, which was decided on finality doctrine, does not control this case. See Concurring Opinion at 522.
. Judge Ginsburg's opinion cites this court's pre-Richardson-Merrell decision, Community Broadcasting of Boston, Inc. v. FCC, 546 F.2d 1022 (D.C.Cir.1976), as additional support for the nonreviewability of an agency disqualification order. But Community Broadcasting involved a denial, not a grant, of a disqualification motion, so that the express cause of action created by Rule 1.301 could not have been relevant.
. The FCC Review Board, as well as the AU whose order the Board affirmed, relied on attorney disciplinary rules to disqualify Chase. See In re Owens, 104 F.C.C.2d 848, 851-52 n. 3, 856 (Rev.Bd.1986), Joint Appendix (J.A.) at 5-6, 10. Both also commented negatively about Chase’s past professional behavior, see id. at 859 n. 8, J.A. at 13, and the Board expressly invited the Committee on Professional Responsibility of the Federal Communications Bar Association to examine the entire matter. See id. at 858 n. 7 (Rev.Bd.1986), J.A. at 12.
. Case law emphasizes that certainty of redressing injury is unnecessary; "mere likelihood [of redress] will do.” National Wildlife Federation v. Hodel, 839 F.2d 694, 705 (1988) (citing cases).
. The effect of Rule 1.301(a)(5), of course, is to make the disqualified attorney not merely a "person aggrieved" by agency action, but a "partly” adversely affected, one who actually participates in the agency proceeding. Cf. Water Transport Ass’n v. ICC, 819 F.2d 1189, 1192 n. 27 (D.C.Cir.1987) (noting that “party aggrieved” appealability standard is more stringent than APA “person aggrieved” standard). Rules, like 1.301, which create a separate cause of action altogether, do not open a floodgate for litigants seeking court review, if only because agencies surely will be reluctant to proliferate opportunities for others to mount judicial challenges to their orders.
. The asserted distinction between persons regulated and persons ”affect[ed]” by legislation, see Concurring Opinion at 523, drawn from Tax Analysts & Advocates v. Blumenthal, 566 F.2d 130 (D.C.Cir.1977), through Haitian Refugee Center v. Gracey, 809 F.2d 794 (D.C.Cir.1987), is unpersuasive. Most important, these cases antedate the recent, deliberate Supreme Court relaxation of the zone of interest test. See *528Clarke v. Securities Industry Association, 107 S.Ct. 750 (1987); see also National Cottonseed Products Ass'n v. Brock, 825 F.2d 482, 490-91 (D.C.Cir.1987) (noting Clarke liberalization; criticizing Haitian Refugee Center; and reasserting this court’s position that "vendors” meet prudential standing requirement even if they are outside the "zone” as long as their customers would pass zone test); Investment Co. Instit. v. FDIC, 815 F.2d 1540, 1544 (D.C.Cir.1987) (noting Clarke liberalization that absent congressional intent to preclude review, mere “ ‘plausible relationship”’ to protected interests satisfies zone test). The Court in Clarke, we have noted, not only minimized the rigor of the test, but also enlarged it to extend to persons whose interests are within "the overall [policy] context” of the legislation. This context is especially broad with the Communications Act, and clearly encompasses attorneys practicing before the FCC. Indeed, the Court has assumed so(in FCC v. Schreiber, 381 U.S. 279, 85 S.Ct. 1459, 14 L.Ed.2d 383 (1965), and its progeny. Additionally, both Tax Analysts and Haitian Refugee Center, indeed most prudential standing case law, concerned courts’ efforts to narrow third parties’ ability to assert the rights of others. This concern about dilution of immediate effect is certainly not involved in the present case. We emphasize again that attorney Chase seeks review of an agency action against himself; he seeks to vindicate his legal rights, and to do so pursuant to an express agency process created for just that purpose.