join, dissenting:
The court holds that appellant Diane Jensen lacks standing to challenge under the National Environmental Policy Act of 1969 (“NEPA”) the failure of the Secretary of the Treasury and the Commissioner of the Internal Revenue Service (together “the Secretary”) to prepare an environmental impact statement (“EIS”) prior to promulgating a final rule to allow a tax credit for an alternative fuel additive known as ethyl tertiary butyl ether (“ETBE”).1 In my view, the *673court has misapplied the doctrine of standing to the assertion of a procedural right, such as the preparation of an EIS, with the consequence that it will be effectively impossible for anyone to bring a NEPA claim in the context of a rulemaking with diffuse impact. Because this result is inconsistent with the language of the congressional statute and is not required by Article III of the Constitution, I respectfully dissent.
I.
In order to have standing to sue, a plaintiff must have “such a personal stake in the outcome of the controversy as to assure that concrete adverseness which sharpens the presentation of issues upon which the court so largely depends for illumination of difficult constitutional questions.” Baker v. Carr, 369 U.S. 186, 204, 82 S.Ct. 691, 703, 7 L.Ed.2d 663 (1962). A plaintiff presents a justiciable “case or controversy” under Article III only if the plaintiff meets three constitutional standing requirements. First, the plaintiffs “injury in fact” must be “concrete and particularized” and “actual or imminent, not conjectural or hypothetical”; second, that injury must be fairly traceable to the defendant’s conduct; and third, the judicial relief requested must be likely to redress the injury. Lujan v. Defenders of Wildlife, 504 U.S. 555, 560-61, 112 S.Ct. 2130, 2136-37, 119 L.Ed.2d 351 (1992) (internal quotation marks omitted); see also Valley Forge Christian College v. Americans United for Separation of Church & State, Inc., 454 U.S. 464, 472, 102 S.Ct. 752, 758-59, 70 L.Ed.2d 700 (1982). Because NEPA contains no private right of action, the plaintiffs in the instant case have brought suit under § 10(a) of the Administrative Procedure Act (APA), 5 U.S.C. § 702 (1994). They must therefore show also that the interest they seek to protect falls “ ‘arguably within the zone of interests to be protected or regulated by’ ” NEPA. Clarke v. Securities Indus. Ass’n, 479 U.S. 388, 396, 107 S.Ct. 750, 755, 93 L.Ed.2d 757 (1987) (quoting Association of Data Processing Orgs., Inc. v. Camp, 397 U.S. 150, 153, 90 S.Ct. 827, 829-30, 25 L.Ed.2d 184 (1970)).
NEPA requires federal agencies, before undertaking “major ... actiqns significantly affecting the quality of the human environment,” to prepare what has become known as an environmental impact statement. NEPA § 102(2)(C), 42 U.S.C. § 4332(2)(C); see also 40 C.F.R. §§ 1502.1-.25 (1995).
The statutory requirement that a federal agency contemplating a major action prepare such an environmental impact statement serves NEPA’s “action-forcing” purpose in two important respects. It ensures that the agency, in reaching its decision, will have available, and will carefully consider, detailed information concerning significant environmental impacts; it also guarantees that the relevant information will be made available to the larger audience that may also play a role in both the decisionmaking process and the implementation of that decision.
Robertson v. Methow Valley Citizens Council, 490 U.S. 332, 349, 109 S.Ct. 1835, 1845, 104 L.Ed.2d 351 (1989). The court acknowledges that appellants have a “procedural right” under NEPA. See Majority Opinion (“Maj. Op.”) at 663-665. In other words, Congress has made the risk of environmental harm from the government’s failure to prepare an EIS a legally cognizable injury. Courts will give effect to that congressional determination in standing cases: “The actual or threatened injury required by Art. Ill may exist solely by virtue of ‘statutes creating legal rights, the invasion of which creates standing.’” Warth v. Seldin, 422 U.S. 490, 500, 95 S.Ct. 2197, 2205-06, 45 L.Ed.2d 343 (1975) (quoting Linda R.S. v. Richard D., 410 U.S. 614, 617 n. 3, 93 S.Ct. 1146, 1148-49 n. 3, 35 L.Ed.2d 536 (1973)); see also Lujan v. Defenders of Wildlife, 504 U.S. at 578, 112 S.Ct. at 2145-46; Havens Realty Corp. v. Coleman, 455 U.S. 363, 373, 102 S.Ct. 1114, 1121, 71 L.Ed.2d 214 (1982); see generally William A. Fletcher, The Structure of Standing, 98 Yale L.J. 221, 253-62 (1988).
*674In the past, this circuit has applied a two-part test to claims of standing under NEPA, requiring the plaintiff to show that the agency’s failure to prepare an EIS “‘creat[es] a risk that serious environmental harms will be overlooked’ ” and that he “ ‘ha[s] a sufficient geographical nexus to the site of the challenged project that he may be expected to suffer whatever environmental consequences the project may have.’ ” City of Los Angeles, 912 F.2d 478, 492 (D.C.Cir.1990) (quoting City of Davis v. Coleman, 521 F.2d 661, 671 (9th Cir.1975)). The first part of this test asks whether the plaintiff has suffered a cognizable injury under NEPA — that is, whether NEPA affords him a “procedural right.” The second part of the test asks whether the plaintiff has suffered injury in fact for standing purposes. See Douglas County v. Babbitt, 48 F.3d 1495, 1500 n. 5 (9th Cir.1995) (stating that the “geographic nexus” test is equivalent to “the ‘concrete interest’ test of Lujan”), cert. denied, — U.S. -, 116 S.Ct. 698, 133 L.Ed.2d 655 (1996). Although the court criticizes the City of Los Angeles test for not clearly requiring a showing of increased risk to “a particularized interest of the plaintiff, rather than the environment in general,” Maj. Op. at 666-67, the “geographic nexus” test instantiates in the NEPA context precisely the showing of injury in fact that the court also requires.2 It is consistent, moreover, with instruction from the Supreme Court. See Lujan, 504 U.S. at 572 n. 7, 112 S.Ct. at 2142 n. 7.
In eases involving a procedural right, such as the preparation of an EIS under NEPA, it is inherently speculative whether the decision maker will reconsider the decision that causes the plaintiff’s injury in fact. Thus, in Lujan v. Defenders of Wildlife, 504 U.S. 555, 572, 112 S.Ct. 2130, 2142, 119 L.Ed.2d 351 (1992), the Supreme Court acknowledged the special nature of “a case where plaintiffs are seeking to enforce a procedural requirement the disregard of which could impair a separate concrete interest of theirs (e.g., ... the procedural requirement for an environmental impact statement before a federal facility is constructed next door to them).” In such a case, the Supreme Court declared, “[t]he person who has been accorded a procedural right to protect his [or her] concrete interests can assert that right without meeting all the normal standards for redressability and immediacy.” Id. at 572 n. 7, 112 S.Ct. at 2142 n. 7. By analogy, appellants need not show that the preparation of the EIS would lead the Secretary to rescind the tax credit, nor that the environmental harm threatened by the tax credit is imminent.
As the opinion for the court states, Maj. Op. at 668, the plaintiff in a NEPA case must also establish that her injury is fairly traceable to the underlying governmental action for which an EIS was not prepared.3 See Simon v. Eastern Kentucky Welfare Rights Org., 426 U.S. 26, 41-42, 96 S.Ct. 1917, 1925-26, 48 L.Ed.2d 450 (1976); Warth v. Seldin, 422 U.S. 490, 504-05, 95 S.Ct. 2197, 2207-08, 45 L.Ed.2d 343 (1975). The causation inquiry in a NEPA case, however, must be conducted in light of the procedural injury that the statute creates. Because “Congress has the power to define injuries and articulate chains of causation that will give rise to a case or controversy where none existed before,” Lujan, 504 U.S. at 580, 112 S.Ct. at 2146-47 *675(Kennedy, J., concurring in part and concurring in the judgment), the nature of the causation inquiry is shaped by the procedural right asserted under NEPA.4 See Idaho Conservation League v. Mumma, 956 F.2d 1508, 1516 (9th Cir.1992) (“The standing examination ... must focus on the likelihood that the defendant’s action will injure the plaintiff in the sense contemplated by Congress.”). As this court has explained, NEPA “includes a strong mandate to anticipate, and where possible, avoid environmental crises through the explanatory and research device of an EIS.” City of Los Angeles, 912 F.2d at 496. The irony of the rule announced by the court today is that it “in essence ... require[s] that the plaintiff conduct the same environmental investigation that he seeks in his suit to compel the agency to undertake.” City of Davis, 521 F.2d at 671; see also Stephen G. BREyek & Richard B. Stewart, Administrative Law and Regulatory Policy 1107 (2d ed. 1985) (“NEPA has been judicially construed as an essentially procedural statute designed to generate, through an EIS, information on the environmental effects of a proposed action. To require plaintiffs to show what those effects are as a prerequisite to requiring that an EIS be performed seems inconsistent with the basic purpose of NEPA”).
II.
The opinion for the court imposes so heavy an evidentiary burden on appellants to establish standing that it will be virtually impossible to bring a NEPA challenge to rulemak-ings with diffuse impacts. The quantum of proof that the court requires finds no support in the procedural rules on summary judgment, nor in the case law on standing. It also places this circuit in conflict with the Ninth Circuit, which has frequently found standing in cases similar to this one.5 See Douglas County, 48 F.3d at 1499-1501; Resources Ltd. v. Robertson, 35 F.3d 1300, 1302-03 (9th Cir.1993); Salmon River Concerned Citizens v. Robertson, 32 F.3d 1346, 1351-55 (9th Cir.1994); Portland Audubon Soc’y v. Babbitt, 998 F.2d 705, 707-08 (9th Cir.1993); Seattle Audubon Soc’y v. Espy, 998 F.2d 699, 702-03 (9th Cir.1993); Idaho Conservation League, 956 F.2d at 1513-18.
Our review of the district court’s grant of the Secretary’s motion for summary judgment on standing is de novo. Harbor Ins. Co. v. Stokes, 45 F.3d 499, 501 (D.C.Cir.1995). To survive such a summary judgment motion, a plaintiff “must ‘set forth’ by affidavit or other evidence ‘specific facts,’ Fed. Rule Civ. Proc. 56(e), which for purposes of the summary judgment motion will be taken to be true.” Lujan v. Defenders of Wildlife, 504 U.S. at 561, 112 S.Ct. at 2136-37; see also Lujan v. National Wildlife Fed’n, 497 U.S. at 889, 110 S.Ct. at 3189. Of course, the Secretary bears the burden “to show initially the absence of a genuine issue concerning any material fact.” Adickes v. S.H. Kress & Co., 398 U.S. 144, 159, 90 S.Ct. 1598, 1609, 26 L.Ed.2d 142 (1970); see generally 10A Charles A. Wright, Arthur R. Miller & Mary Kay Kane, Federal Practice and Procedure § 2739 (2d ed.1983). Because appellants have presented ample evidence to show that they have suffered an injury in fact, fairly traceable to the Secretary’s action, and the Secretary has presented no genuine issue of material fact as to Ms. Jensen’s standing, appellants are entitled to summary judgment on the standing issue.
*676A.
The ETBE tax credit. The statutory purpose of the tax credit, as well as the Secretary’s rationale for extending the tax credit to ETBE, set the context for demonstrating the lack of merit to the Secretary’s challenge to Ms. Jensen’s standing.
In 1980, Congress enacted the Crude Oil Windfall Profit Tax Act, Pub.L. No. 96-223, § 232(b)(1), 94 Stat. 229, 273-75, in order “to encourage the development of energy sources other than petroleum products for use in motor fuels” by providing a refundable income tax credit on “alcohol (other than alcohol derived from petroleum, natural gas, or coal)” used in motor fuels. S.Rep. No. 394, 96th Cong., 1st Sess. 91 (1979), reprinted in 1980 U.S.C.C.A.N. 410, 499-500. Section 40 of the Internal Revenue Code thus provides a tax credit of 60 cents for each gallon of alcohol used in the production of a “qualified mixture” of alcohol and gasoline. 26 U.S.C. § 40(a), (b)(1) (1994). ETBE is a chemical compound produced in a reaction between ethanol (an alcohol usually produced by fermenting sugar contained in crops such as corn, sugar beets and sugarcane) and isobu-tylene (a petroleum by-product); the ETBE is then typically blended with gasoline for use as a fuel. Before 1990, ETBE did not qualify for the § 40 tax credit because, chemically speaking, it is a compound rather than a “mixture” of ethanol and isobutylene. Without the tax credit, ETBE could not compete commercially with a similar fuel additive, methyl tertiary butyl ether. In 1988, sixty-one United States senators6 urged the Secretary to announce that ETBE qualifies for the tax credit, explaining that “[b]y establishing the eligibility of the credit, commercialization can occur immediately, and, in accordance with the intent of the original Act, America’s dependence on foreign oil can be further reduced.”
In 1989, the Secretary issued a proposed rule that would re-interpret “qualified mix-time” to include chemical compounds derived from alcohol. See Alcohol Fuels Credit; Definition of Mixture, 54 Fed.Reg. 48,639 (Nov. 24, 1989). Stating that the rule was based on “policy considerations,” id. at 48i-639, the Secretary’s notice indicated that the proposed ETBE tax credit would have five benefits:
First, allowing the credit will increase the substitution of ETBE for other octane enhancers that cause more pollution. Second, it makes ETBE a more viable means of increasing the oxygen content of gasoline, which should help smooth the transition to oxygenated fuels in those areas that are not in compliance with carbon monoxide standards. Third, it encourages the substitution of ETBE-gasoline blends (gasohol). ETBE does not absorb water, which means it is easier to transport than gasohol, and it can be blended into the gasoline with less pollution than the “splash blending” of gasohol. Fourth, it may increase the demand of domestic ethanol because ETBE is easier to use than ethanol, which would expand this alternative market for America’s farmers. Fifth, ETBE is a fuel, not just an octane enhancer, and it will displace some gasoline consumption. Substituting a renewable and domestically-produced fuel for imported petroleum will enhance national energy security and will improve the trade balance.
Id. at 48,640 (emphasis added). In comments submitted to the Secretary, the National Corn Growers Association stated that the new rule would “help open the door to a whole new market for the nation’s corn farmer.” Letter from Alan Kemper, President, National Corn Growers Ass’n, to the Commissioner of the Internal Revenue Service (Dee. 8,1989).
In 1990, the Secretary promulgated a final rule. Identical to the proposed rule, it interpreted section 40’s reference to a “qualified mixture” to include products derived from alcohol “even if the alcohol is chemically transformed in producing the product so that the alcohol is no longer present as a separate chemical in the final product, provided that there is no significant loss in the energy content of the alcohol.” Alcohol Fuels Credit; Definition of Mixture, 55 Fed.Reg. 8946, 8946 (1990) (codified at 26 C.F.R. § 1.40-1 *677(1995)). In the notice accompanying the final rule, the Secretary rejected the suggestion that NEPA required him to prepare an environmental impact statement because Treasury Directive 75-02, 45 Fed.Reg. 1828 (Jan. 8, 1980), provided a “categorical exception” from the EIS requirement for IRS regulations “interpreting, implementing, or clarifying” Internal Revenue Code provisions. 55 Fed.Reg. at 8947.
Appellants disagree, and they challenge the Secretary’s failure to prepare an EIS before taking the non-site-specific government action that appellants assert is likely to cause widespread environmental harm. The only question now before the court is whether appellants have standing.
B.
Injury in fact. Appellants have demonstrated concrete and particularized injury by establishing that they have a “geographical nexus” to the threatened environmental injury. The court rejects their showing of proof, however, on the ground that they “have not provided competent evidence that corn farmers in particular areas of Minnesota or Michigan or sugar producers in particular regions of Florida” will increase their crop production. Maj. Op. at 667-68. Unfortunately, the court ignores the voluminous evidence that appellants have provided.
In her sworn declaration, Ms. Jensen explained that she and her family regularly use and enjoy particular locations in Minnesota, including the Sherburne National Wildlife Refuge, Sand Dunes State Forest, and Lac Qui Parle Wildlife Area. At her deposition, in response to the government’s request, she identified ten areas, with an average diameter of twenty-five miles, that she regularly visits for her recreational activities. In her declaration she stated that these activities include hiking, canoeing, cross-country skiing, birdwatching and photography, and fishing throughout undeveloped natural areas adjoining Minnesota land used for corn farming and susceptible to increased corn production. The Secretary does not dispute that Ms. Jensen has more than “ ‘some day1 intentions” to visit these areas, cf. Lujan v. Defenders of Wildlife, 504 U.S. at 564, 112 S.Ct. at 2138, and that she has alleged that these particular locations, and not land in the general vicinity, are likely to be adversely affected by the ETBE tax credit, cf. Lujan v. National Wildlife Fed’n, 497 U.S. 871, 887-89, 110 S.Ct. 3177, 3188-89, 111 L.Ed.2d 695 (1990).
Furthermore, Ms. Jensen has proffered unrefuted evidence that the ETBE tax credit will affect areas she uses. Based on her experience on several Minnesota environmental task forces, state environmental advisory groups, and the state Board of Water and Soil Resources,7 Ms. Jensen states in her sworn declaration that local farmers, who now receive state subsidies to leave some land fallow and rotate fields, are likely to abandon the subsidy and develop these lands in order to take advantage of the tax credit. As a result, Ms. Jensen states, marginally productive lands, which require more fertilizer and pesticides to farm and are more susceptible to erosion, are likely to be cultivated. She further states that greater yields can be obtained from Minnesota farmland already devoted to corn farming through increased use of pesticides and fertilizer, which would threaten wildlife habitats by causing greater soil erosion and water pollution. Ms. Jensen also refers to meetings in which State representatives have advised her that the ETBE tax credit is likely to increase corn farming in Minnesota and that an EIS could destroy market opportunities for Minnesota corn. From this unrefuted evidence, the likelihood that the ETBE tax credit will stimulate increased corn production on lands neighboring *678those used by Ms. Jensen, and the fact that Minnesota is the fourth-largest corn-producing state in the United States, it reasonably follows that Ms. Jensen uses lands likely to be affected by the ETBE tax credit.
Ms. Jensen’s second basis for standing rests on the unrefuted evidence that the ETBE tax credit will affect her drinking water. In her affidavit, she states that the pesticide atrazine, which is commonly used on corn crops, can be found in groundwater as well as in drinking water. According to a national study that appellants have submitted, about 72 million pounds of atrazine were applied in 1992, of which over 60 million pounds were used on corn. National Center for Food and Agricultural Policy, Pesticide Use in U.S. Crop Production tbl. 18 (Feb. 1995). Given that, according to this study, 68% of acres planted with corn are treated with atrazine, id., it is likely that increased corn production would be accompanied by increased use of atrazine. The Environmental Protection Agency, in initiating a Special Review of atrazine and related pesticides, has concluded that “atrazine is the most frequently detected pesticide in the ground water in the midwestern United States, including ... Minnesota.” 59 Fed.Reg. 60,412, 60,427 (Nov. 23, 1994). Appellants have also submitted a drinking-water study that shows that atrazine, which the Environmental Protection Agency has classified as a possible human carcinogen, was found in 58% of tap water samples collected between May 25 and July 1, 1995, in Minneapolis. Environmental Working Group, Weed Killers By the Glass 63 (Aug.1995). Because Ms. Jensen resides in the Minneapolis metropolitan area, it reasonably follows that Ms. Jensen’s drinking water is likely to be affected by the ETBE tax credit.
It is true that Ms. Jensen has not pointed to a particular Minnesotan corn farmer whose possible increased com production will injure the lands she uses or the water she drinks.8 Maj. Op. at 671. But her showing of a localized impact of the ETBE tax credit is more than sufficient to establish the requisite “geographical nexus.” In Oregon Environmental Council v. Kunzman, 817 F.2d 484, 491-92 (9th Cir.1987), residents of Oregon challenged an EIS for a federal program for spraying gypsy moths. The court concluded that the plaintiffs “reside in a state with an actual gypsy moth problem and thus may challenge a nationwide EIS that is applicable to them.” Just so, Ms. Jensen has shown that she is likely to be concretely affected by the ETBE tax credit in a way that distinguishes her from other potential plaintiffs; she seeks redress not for a generalized grievance, but for a particularized interest. See Lujan v. Defenders of Wildlife, 504 U.S. at 573-74, 112 S.Ct. at 2143-44.
Because it cannot be disputed that Ms. Jensen has a concrete, particularized interest in the wildlife areas that she uses and in the water that she drinks, the remaining question is whether the threatened harm to her is sufficiently imminent. The reasoning in the opinion for the court, holding that appellants have not established injury in fact, Maj. Op. at 666-668, may be directed toward this requirement of imminence. Cf. Wilderness Soc’y v. Griles, 824 F.2d 4, 18 (D.C.Cir.1987) (“[T]he likelihood of injury, whether or not that likelihood depends upon a single event or a chain of events, is properly a concern of the personal injury inquiry, not the causation inquiry-”). As the Supreme Court made clear in footnote seven of Lujan v. Defenders of Wildlife, however, a plaintiff asserting a procedural right need not wait for the threatened injury to befall her before bringing suit to force the government to conduct the procedure designed to protect the plaintiffs concrete interest. The “normal standards for ... immediacy” are relaxed, 504 U.S. at 572 n. 7, 112 S.Ct. at 2142 n. 7, because NEPA injury entails simply the “risk of serious environmental harm,” not the certainty of environmental harm. See Salmon River Concerned Citizens v. Robertson, 32 F.3d *6791346, 1355 n. 14 (9th Cir.1994) (“There is no requirement that a plaintiff prove that an injury to his or her concrete interests will occur.”); Sierra Club v. Marita, 46 F.3d 606, 611-12 (7th Cir.1995).
The opinion for the court disputes the connection between evidence of the existing extent of corn farming in Minnesota, near the areas that Ms. Jensen uses, and the likelihood that an expansion of corn production would also take place near those same areas. Similarly, the court would deny any connection between evidence of the existing prevalence of atrazine in the drinking water in Minneapolis and the likelihood that an expansion of corn production would increase those atrazine levels. Yet the Supreme Court has stated that “past wrongs are evidence bearing on whether there is a real and immediate threat of repeated injury.” O’Shea v. Littleton, 414 U.S. 488, 496, 94 S.Ct. 669, 676, 38 L.Ed.2d 674 (1974). Indeed, it should go without saying that appellants “need not be omniscient and pinpoint precisely where the next infraction will occur.” International Union of Bricklayers & Allied Craftsmen v. Meese, 761 F.2d 798, 803 (D.C.Cir.1985). In a NEPA case, where the asserted interest is inherently probabilistic in nature, the plaintiff need show only that the heightened risk to her interest is not conjectural or hypothetical. See Idaho Conservation League, 956 F.2d at 1516.
By concluding that Ms. Jensen has failed to demonstrate a geographic nexus to the risk of serious environmental harm, the court erroneously requires her to demonstrate certainty of injury to her concrete interest in the wildlife areas that she uses and in the water that she drinks. The court is in agreement that, because of the diffuse impact of a rulemaking such as the ETBE tax credit, a prospective plaintiff suffers a particularized injury only if she can show that a localized impact is more likely where she lives than simply anywhere in the country. See Maj. Op. at 667; cf. Lujan v. Defenders of Wildlife, 504 U.S. at 572 n. 7, 112 S.Ct. at 2142 n. 7 (stating that “persons who live (and propose to live) at the other end of the country from the dam” “have no concrete interests affected”)). But Ms. Jensen’s affidavit, taken together with appellants’ expert testimony, establishes a greater likelihood of a localized impact where Ms. Jensen lives. If appellants’ showing is insufficient, as the court concludes, then it is difficult to imagine who would be able to satisfy the injury-in-fact element of standing in a procedural-rights case involving a nationwide rulemaking.9 The standing doctrine, designed to respond to concerns about the separation of powers and avoiding advisory opinions, see Lujan v. Defenders of Wildlife, 504 U.S. at 559-60, 112 S.Ct. at 2135-36, does not lead to such an incongruous result.
C.
Causation. The court holds, in the alternative, that the increased likelihood of harm to the plaintiffs’ concrete interests is not fairly traceable to the ETBE tax credit. Maj. Op. at 669-670. According to the court, the plaintiffs’ “protracted chain of causation fails both because of the uncertainty of several individual links and because of the number of speculative links that must hold for the chain to connect the challenged acts to the asserted particularized injury.” Maj. Op. at 671.
In deciding whether harm caused directly by the actions of a third party are fairly traceable to the defendant, courts must assess the incentives that the defendant’s conduct provided to the third party. “While the personal injury inquiry focuses on concrete facts about harm to the plaintiff, causation questions concern the directness of the link between the defendant’s challenged action and the alleged injury, and focus on the incentive structure to which the intervening third party, who directly causes the injury, is responding.” Griles, 824 F.2d at 17; see also Community for Creative Non-Violence v. Pierce, 814 F.2d 663, 669 (D.C.Cir.1987). There is no per se rule that intervening acts by a third party breaks the chain of causa*680tion. “ ‘[M]ere indirectness of causation is no barrier to standing, and thus, an injury worked on one party by another through a third party intermediary may suffice.’ ” Telephone & Data Sys., Inc. v. FCC, 19 F.3d 42, 47 (D.C.Cir.1994) (quoting National Wildlife Fed’n v. Hodel, 839 F.2d 694, 705 (D.C.Cir.1988)); see also Heldman v. Sobol, 962 F.2d 148, 156 (2d Cir.1992). In addition, “‘[w]e are concerned here not with the length of the chain of causation, but [with] the plausibility of the links that comprise the chain.’” Autolog Corp. v. Regan, 731 F.2d 25, 31 (D.C.Cir.1984) (quoting Public Citizen v. Lockheed Aircraft Corp., 565 F.2d 708, 717 n. 31 (D.C.Cir.1977)).
The Secretary maintains that a complex and improbable sequence of events must ensue in order for the ETBE tax credit to affect appellants’ concrete interest: namely, that the ETBE tax credit must prompt ETBE production, which must increase demand for ethanol, which must increase demand for corn, which must increase corn farming, which must cause environmental harm. With only one exception, however, the Secretary has failed to dispute appellants’ proffered evidence establishing the likelihood of each of these causal links and the connections between them. The Secretary does not dispute record evidence that increased corn farming would adversely affect the environment by, among other things, increasing erosion and water pollution as farmers plant crops on now idle or underused land and expand their use of pesticides and fertilizers. It is also undisputed that an increased demand for ethanol would increase domestic corn production. Appellants pre-. sented a study by Professor Peter Berck, an agricultural and resource economist at the University of California at Berkeley, who estimated that, as a result of the tax credit, the acreage of farm land devoted to growing corn would increase by between 281,000 acres to 14 million acres, depending on which of several projections regarding increased demand for ethanol proves to be correct.10 Insofar as estimates regarding increased ethanol production prove correct, the Secretary does not dispute Professor Berck’s conclusions.11
As a result, the question whether appellants have established the causation element of standing depends solely on the likelihood that the ETBE tax credit will stimulate demand for ethanol. According to data released by the Department of Energy in May 1995, production of ETBE as of January 1, 1995, was 3,980 barrels per day, located at three plants in Virginia, Illinois and Minnesota.12 1 Energy Info. Admin., Petroleum Supply Annual 1994, at 125 tbl. 52 (May 1995). Although the court emphasizes that this level of production remains relatively low, Maj. Op. at 671, the increase in ETBE production from zero when the tax credit was adopted in 1990 to 3,980 barrels per day by the end of 1994 tends to support appellants’ claim that the tax credit is likely to stimulate demand for ethanol. The tax credit of 60 cents per gallon of ethanol amounts to a credit of 25 cents per gallon of ETBE,13 which reduces *681the cost of production of ETBE, according to Secretary Yeutter’s 1989 estimate, from about 95 cents a gallon to around 70 cents a gallon. Letter from Clayton Yeutter, Secretary of Agriculture, to J. Bennett Johnston, Chairman, Committee.on Energy and Natural Resources, United States Senate, attachment at 5 (Nov. 2, 1989). Moreover, this is not a case where a plaintiff has seized on a possible incidental side-effect of a government action; rather, increasing demand for ethanol was one of the Secretary’s stated purposes in proposing extension of the tax credit to ETBE. See Alcohol Fuels Credit; Definition of Mixture, 54 Fed.Reg. 48,689, 48,640 (Nov. 24,1989). The record is replete with evidence that proponents of the ETBE tax credit expected the tax credit to increase demand for ethanol and com production.14 The Secretary’s own experts, Professor Leo Polopolus and Professor Andrew Schmitz, indicated that the “development and growth of the corn based U.S. ethanol industry is due to the various federal and state tax incentives, subsidies, and loan guarantees.” Indeed, unless we assume that the Secretary promulgated the ETBE tax credit as nothing more than an empty gesture, it is difficult to understand his argument that an effective reduction in the price of production from 95 cents to 70 cents a gallon will have no impact on ETBE production.15 In light of appellants’ evidence of a substantial effect from the tax credit, it is more than “somewhat curious” for the Secretary to “minimiz[e] the importance and impact of his own decision[ ]” in order to defeat standing. Securities Indus. Ass’n v. Clarke, 885 F.2d 1034, 1041 (2d Cir.1989), cert. denied, 493 U.S. 1070, 110 S.Ct. 1113, 107 L.Ed.2d 1021 (1990).
The court relies on the analyses of causation in the Supreme Court’s decisions in Allen v. Wright and Simon v. Eastern Kentucky Welfare Rights Organization. See Maj. Op. at 670-671. The Supreme Court has explained, however, that both those decisions were motivated by separation-of-powers concerns that “counsel[] against recognizing standing in a case brought, not to enforce specific legal obligations whose violation works a direct harm, but to seek a restructuring of the apparatus established by the Executive Branch to fulfill its legal duties.” Allen v. Wright, 468 U.S. at 761, 104 S.Ct. at 3329-30; see also Cass R. Sunstein, Standing and the Privatization of Public Law, 88 Colum. L.Rev. 1432, 1451-61 (1988). By contrast, appellants challenge not the ETBE tax credit,16 but rather the Seere-*682tary’s failure to prepare an EIS. The Supreme Court has been far more generous in its causation analysis outside the context of constitutional challenges to a third party’s tax liability. In a NEPA standing case, United States v. Students Challenging Regulatory Agency Procedures, 412 U.S. 669, 93 S.Ct. 2405, 37 L.Ed.2d 254 (1973) (SCRAP), the Supreme Court allowed standing despite what the opinion for the court acknowledges, Maj. Op. at 671-672, is a similarly indirect chain of causation.17 See Defenders of Wildlife v. Hodel, 851 F.2d 1035, 1043 (8th Cir.1988) (distinguishing Allen v. Wright on the ground that it was a “constitutional challenge, whereas this case involves, as did SCRAP, questions of statutory interpretation”); see also Fletcher, supra, at 258-60 (explaining SCRAP as a NEPA case). To take another example, in Duke Power Co. v. Carolina Environmental Study Group, Inc., 438 U.S. 59, 75-77, 98 S.Ct. 2620, 2631-33, 57 L.Ed.2d 595 (1978), in which the plaintiffs challenged a federal statutory limitation on liability for nuclear accidents, the defendants denied that there was causation by asserting that the nuclear power plants near which the plaintiffs lived might have been constructed and operated even without the federal statute. The Supreme Court upheld the district court’s conclusion that, based on congressional testimony by corporate officials and expert testimony presented by the plaintiffs, there was a “substantial likelihood” that the power plants would not have been constructed and operated if it were not for the federal statute. The statements by Cabinet officials about the purposes of the ETBE tax credit and appellants’ expert testimony similarly establish a substantial likelihood that the tax credit will increase the risk of serious environmental harm.
The separation-of-powers concerns that underlay Allen v. Wright and Simon v. Eastern Kentucky Welfare Rights Organization do not apply to appellants’ NEPA claim. The causation element of standing, as employed by the Supreme Court, is “something of a term of art, taking into account not merely an estimate of effects but also considerations related to the constitutional separation of powers as that concept defines the proper role of courts in the American governmental structure.” Haitian Refugee Ctr. v. Gracey, 809 F.2d 794, 801 (D.C.Cir.1987) (opinion of Bork, J.). Appellants’ NEPA claim, however, asks the court to enforce a procedural right of the sort that courts are accustomed to adjudicating and are well-equipped to handle. Vindication of appellants’ procedural right would entail no judicial intrusion into the workings of the executive branch, as might have occurred in Allen and Simon. Moreover, the separation-of-powers concerns in the standing inquiry are different when a plaintiff seeks to enforce a statutory, rather than a constitutional, right. Although the court maintains that hearing this lawsuit would set us up as “a back-seat Congress,” Maj. Op. at 672, the court, by denying standing, effectively second-guesses Congress’ determination to create an inherently predictive right in NEPA.
The opinion for the court principally identifies two links in the chain of causation that it concludes are too weak to sustain standing. First, fuel producers may decide to increase production of ETBE for reasons independent of the challenged tax credit. Second, even if the tax credit causes production of ETBE and ethanol to increase, the resulting marginal effect on corn production may be dwarfed by other causal factors (such as weather) that either increase or reduce the production of corn.18 See Maj. Op. at 670.
*683The question whether the fuel producers’ decisions to increase the production of ETBE are fairly traceable to the ETBE tax credit depends on the importance of the tax credit in their decision. The record shows that fuel producers already have substantial ETBE production capacity, see ETBE: Ethanol’s Motor Fuel Hope?, Chemical Business 38, 38 (Oet.1988) (stating that methyl tertiary butyl ether production facilities can be converted to produce ETBE), so that the decision at the margin whether to produce more ETBE turns on its profitability. If the ETBE tax credit were insufficient to stimulate production of ETBE because the production of any ETBE remained unprofitable, then the plaintiffs’ case for causation would fail. But the plaintiffs have provided evidence that ETBE is in fact now being produced and that the tax credit was designed to be large enough to stimulate production. See supra Parts II A & B. In City of Los Angeles, Judge D.H. Ginsburg would have denied standing because the plaintiffs “ma[de] no allegations concerning the incremental harm wrought by the agency’s decision.” 912 F.2d at 484 (D.H. Ginsburg, J., dissenting in part). By contrast, in the instant case it is precisely the injury caused by the marginal increase in the production of ethanol on which the plaintiffs rely.19
The court rejects much of the plaintiffs’ evidence as “speculation,” relying on United Transportation Union v. ICC, 891 F.2d 908, 912 (D.C.Cir.1989), cert. denied, 497 U.S. 1024, 110 S.Ct. 3271, 111 L.Ed.2d 781 (1990), in which the court stated that, “[w]hen considering any chain of allegations for standing purposes, we may reject as overly speculative those links which are predictions of future events (especially future actions to be taken by third parties) and those which predict a future injury that will result from present or ongoing actions — those types of allegations that are not normally susceptible of labelling as ‘true’ or ‘false.’ ” See Maj. Op. at 667-668, 670. Yet the United Transportation Union court noted also that “applieation[s] of basic economic logic” are not “speculative”: “Allegations founded on economic principles .. .,■ while perhaps not as reliable as allegations based on the laws of physics, are at least more akin to demonstrable facts than are predictions based only on speculation.” 891 F.2d at 912 n. 7; see also Adams v. Watson, 10 F.3d 915, 923 (1st Cir.1993) (noting that economic predictions are routinely used in standing cases). For example, the proposition that the supply of a commodity (here, ETBE) will increase if the government subsidizes the cost of its production is uncontroversial. See Paul A. Samuelson & William D. NoRdhaus, EconomiCS 64 (12th ed.1985). Similarly, the proposition that an increase in the demand for a certain commodity (here, corn) will normally cause the price for that commodity to rise, which will in turn cause the quantity of the commodity supplied to increase until supply again equals demand, is commonly accepted and certainly not “speculative.” Id. at 67. Although the magnitude of the price effects may vary by commodity (depending on the elasticity of demand and of supply, see id. at 379-84), courts may assume for purposes of standing, unless a contrary reason is shown, that a defendant’s actions will have the effect that economics would foretell.20 We need not *684shut our eyes from the reality, as predicted by the two other branches of government as well as the affected industry, that the ETBE tax credit will likely increase the production of ETBE, which in turn will likely increase the production of corn.
The second weak link, in the court’s view, is the relation between a marginal increase in the production of corn fairly traceable to the ETBE tax credit and an overall increase in fact that is not confounded by independent causal factors. Although it is certainly conceivable that a change in weather patterns or a restriction of credit available to farmers could result in a net decrease in the production of com, it is sufficient for standing purposes that the marginal impact from the tax credit increases the risk of environmental injury to the plaintiffs. Even if in a given year the increase fairly traceable to the ETBE tax credit is dwarfed by other factors, the production of corn in that year is still highly likely to be higher than it would have been without the ETBE tax credit — or at least higher over a period of several years than it would have been without the tax credit. This incremental impact satisfies the causation element of the standing inquiry. As the Supreme Court has observed, “[n]oth-ing in our prior cases requires a party seeking to invoke federal jurisdiction to negate the kind of speculative and hypothetical possibilities suggested.” Duke Power, 438 U.S. at 78, 98 S.Ct. at 2633.
D.
Redressability. The nature of the plaintiffs’ NEPA injury demonstrates its redress-ability. The plaintiffs have met their burden to show that the procedural injury they claim' — the risk that serious environmental harms were overlooked in promulgating the ETBE tax credit — will be redressed by having the court order the Secretary to prepare an EIS. As the opinion for the court agrees, Maj. Op. at 663, the plaintiffs need not establish that, in response to a court order to prepare an EIS, the Secretary would rescind or modify the ETBE tax credit and thereby alleviate the threatened injury to their concrete interest. See Lujan v. Defenders of Wildlife, 504 U.S. at 572 n. 7, 112 S.Ct. at 2142 n. 7; Idaho Conservation League, 956 F.2d at 1517; City of Los Angeles, 912 F.2d at 499.
E.
Zone of interests. In enacting NEPA, Congress declared that, in view of
the profound impact of man’s activity on the interrelations of all components of the natural environment ... [and] the critical importance of restoring and maintaining environmental quality to the overall welfare and development of man, ... it is the continuing policy of the Federal Government ... to use all practicable means and measures ... in a manner calculated to foster and promote the general welfare. ...
NEPA § 101(a), 42 U.S.C. § 4331(a). To cany out this policy, Congress “direct[ed] that, to the fullest extent possible, ... all agencies of the Federal Government shall ... include in every ... major Federal action[] significantly affecting the quality of human environment, a detailed [environmental impact statement].” Id. § 102(2)(C), 42 U.S.C. § 4332(2)(C). The environmental harms stemming from increased corn farming suggested by appellants’ proffers, and no less by Ms. Jensen’s sworn declaration, fall within NEPA’s zone of interests. See City of Los Angeles, 912 F.2d at 495.
Accordingly, because Ms. Jensen has adequately demonstrated all the elements for standing, I would reverse the grant of summary judgment to the Secretary on standing, and remand the case to the district court to enter summary judgment for appellants on standing and to address the remaining issues.
. Because I conclude that Ms. Jensen has standing to seek declaratory and injunctive relief requiring the Secretary to prepare an EIS before implementing the tax credit at issue, I have no occasion to address the claims to standing for the other appellants: the Florida Audubon Society, the Florida Wildlife Federation, and the Friends of the Earth. Appellants forthrightly state that if any one of them has shown sufficient evidence to withstand summary judgment on standing, the *673court need not consider the standing of other appellants. See Watt v. Energy Action Educ. Found., 454 U.S. 151, 160, 102 S.Ct. 205, 212, 70 L.Ed.2d 309 (1981); National Mining Ass’n v. United States Dep’t of Interior, 70 F.3d 1345, 1349 (D.C.Cir.1995).
. There is no occasion to rely on appellants’ alternative theory that they have suffered "informational injury.” See Foundation on Economic Trends v. Lyng, 943 F.2d 79, 84 (D.C.Cir.1991) ("[W]e have never sustained an organization’s standing in a NEPA case solely on the basis of 'informational injury, ’ that is, damage to the organization's interest in disseminating the environmental data an impact statement could be expected to contain.”).
. In previous cases, this circuit has held that the causation element of standing can be satisfied by " 'the prospect that the [agency] would rescind its [underlying action] were the environmental consequences of the [underlying action] spelled out in more detail in an EIS: ... this would supply the required causal nexus between the agency’s action — failure to prepare an EIS — and petitioners’ "environmental” injury.' ” City of Los Angeles, 912 F.2d at 496 (quoting Public Citizen v. National Highway Traffic Safety Admin., 848 F.2d 256, 263 n. 27 (D.C.Cir.1988)). The court properly abandons that approach, see Maj. Op. at 668, in light of Supreme Court cases, decided after the Ninth Circuit decision from which this circuit drew its NEPA standing test, that establish the causation element of standing. The panel opinion conducted the proper causation analysis, albeit under a different rubric. 54 F.3d at 878-80.
. Nine of the ten judges who took part in Center for Auto Safety v. Thomas, 847 F.2d 843 (D.C.Cir.1988) (en banc), agreed with this proposition. See id. at 856 (opinion of Wald, C.J.); id. at 874 (opinion of Buckley, J.) (stating that Congress cannot "conclusively establish[]” causation, but “Congress’ understanding might affect the quantum of proof that the [plaintiff] must provide”).
. The circuits are divided over the issue whether challenges to forest management plans under NEPA and the National Forest Management Act, 16 U.S.C. §§ 1600-1614 (1994), are justiciable when the government has yet to develop site-specific projects implementing the plan. Compare Sierra Club v. Marita, 46 F.3d 606, 610-14 (7th Cir.1995) and Idaho Conservation League v. Mumma, 956 F.2d 1508, 1515-16 (9th Cir.1992) (yes) with Wilderness Soc’y v. Alcock, 83 F.3d 386, 389-91 (11th Cir.1996) and Sierra Club v. Robertson, 28 F.3d 753, 757-60 (8th Cir.1994) (no). That consideration is not present in the instant case because the Secretary will not take any site-specific action.
. The letter was signed by all sixty-one senators who had been in the Senate when the Crude Oil Windfall Profit Tax Act was enacted in 1980 and continued in office in 1988.
. Since 1985, Ms. Jensen has been employed by, and since 1987 has been a co-director of, the Minnesota branch of Clean Water Action, a national environmental organization that advocates protection of natural resources. She was a member of a 1989 advisory group that prepared legislation (later adopted by the state legislature) to protect groundwater in Minnesota, and has served, by appointment, on three state environmental advisory groups. In addition, since 1989 she has been the Minnesota State Governor’s appointee to the Great Lakes Protection Fund Board. From 1990 to 1992, she served as the Governor's appointee to the Minnesota Board of Water and Soil Resources, which administers the state soil and water conversation districts, county water planning and the state’s farmland set-aside programs.
. Nor could Ms. Jensen produce such a farmer, given that the impersonal laws of supply and demand would increase com production without the particular farmer being able to attribute the increase in production to demand for ETBE. Ms. Jensen has, however, produced statements from the National Com Growers Association, speaking on behalf of farmers, as well as evidence that elected officials in Minnesota expected that farmers would benefit from the ETBE tax credit.
. Inexplicably, the court notes that Lujan v. Defenders of Wildlife suggests that homeowners upstream from a dam would have standing in a NEPA case, Maj. Op. at 666, but holds that Ms. Jensen, who drinks the affected water, does not. Surely the pollution of one’s drinking water is a concrete and particularized injury. See Maj. Op. at 667 n.4.
. The low-end estimate for increased crop acreage is derived from estimates by com industry groups in letters to the Secretary of Treasury and testimony at a House Ways and Means Committee hearing that com production would increase by about 100 million bushels and is based on a low estimate of the elasticity of the supply of com.
. The Secretary presented a report by Professor Leo Polopolus and Professor Andrew Schmitz that "review[ed] the allegations of this lawsuit concerning sugar crops” but did not address Professor Berck’s conclusions concerning com crops.
. Other sources indicate that ETBE production continues to increase. According to 21st Century Fuels, ETBE production capacity increased from 35,000 barrels a day in late 1994 to 66,100 barrels a day in late 1995 — a growth ascribed to tax credits for ETBE. ETBE Capacity Grows, Carb Fuel Offers New Blending Prospects, 21st Century Fuels, vol. 15, no. 12 (Dec. 1, 1995). In addition, uncertainty about the tax credit's continued viability — stemming in part from this litigation, commenced very shortly after the Secretary’s announcement of the final rule, Maj. Op. at 661 — may explain the ethanol industry's decision to delay investment in ETBE production. Cf. Lawsuit Challenging Credit Still Alive; ETBE Credit Hangs in Balance as Congress Fails to Clarify Issue in Budget Bill, 11 Alcohol Week's New Fuels Report No. -44, at 1 (Nov. 5, 1990).
.The compound ETBE consists of about 42% ethanol.
.See Letter from Clayton Yeutter, Secretary of Agriculture, to Nicholas F. Brady, Secretary of the Treasury (Mar. 20, 1989) ("ETBE, with the blender tax credit, will enable the domestic ethanol industry to expand and provide a growing market for U.S. feed grains.”); Letter from Clayton Yeutter, Secretary of Agriculture, to J. Bennett Johnston, Chairman, Committee on Energy and Natural Resources, United States Senate (Nov. 3, 1989); Letter from Alan Kemper, President, National Com Growers Ass’n, to Commissioner of the Internal Revenue Service (Dec. 8, 1989) (“Every six gallons of ETBE produced will consume approximately one bushel of com. As you can see, in an expanded ETBE market, the potential for the utilization of one of American’s greatest renewable resources (com) would be significant.”); Letter from Criss Davis, President, Wisconsin Com Growers Ass’n, to Commissioner of the Internal Revenue Service (Dec. 20, 1989); Outline of Comments on Tax Credits for ETBE, Frederick C. Spreyer, State of Hawaii, Dep't of Business and Economic Development; Letter of Daryl Reid, President, Illinois Com Growers Ass’n, to Commissioner of the Internal Revenue Service (Dec. 12, 1989); see also Market Hinges on Favorable Treasury Dep't Ruling, Alcohol Week 6-7 (Oct. 24, 1988).
. Although the court is correct that we "do not defer to the views of the IRS ... in determining whether a particular rule will cause injury to a particular plaintiff or as proof of any causal chain necessary for standing,” Maj. Op. at 670-671, the statements by the Secretary of the Treasury and the Secretary of Agriculture simply support the common-sense inference that the tax credit is likely to lead to an increase in the production of ETBE. For standing purposes, contrary to the court's dictum, the court may consider congressional definitions of injury or congressional articulations of chains of causation. See Lujan v. Defenders of Wildlife, 504 U.S. at 578, 112 S.Ct. at 2145-46 (stating that Congress can "elevatfej to the status of legally cognizable injuries concrete, de facto injuries that were previously inadequate in law”); id. at 580, 112 S.Ct. at 2146-47 (Kennedy, J., concurring in part and concurring in the judgment).
. In Allen v. Wright, the plaintiffs alleged that the conduct of the Internal Revenue Service (IRS) violated the Internal Revenue Code, civil rights laws, and the Constitution, 468 U.S. at 745 n. 12, 104 S.Ct. at 3321 n. 12; in Simon, the plaintiffs alleged that the conduct of the IRS violated the Internal Revenue Code and the APA, 426 U.S. at 33-34, 96 S.Ct. at 1921-22.
. Although SCRAP has been limited, see Lujan v. National Wildlife Federation, 497 U.S. at 889, 110 S.Ct. at 3189, it remains binding law in the NEPA context. Because we consider the evidence the plaintiffs have submitted in this case sufficient to warrant summary judgment in their favor on the standing issue, the distinction noted by the court — that SCRAP was decided on its pleadings — does not reduce that case’s support for our conclusion that the plaintiffs in this case have demonstrated standing.
. The other links in the chain of causation need not be treated separately. See Maj. Op. at 669-670. An increase in the production of ETBE necessarily leads to an increase in the demand for ethanol (which comprises 42% of the ETBE compound). Such an increase in the demand for ethanol is highly likely to lead to an increase in the production of ethanol, which necessarily leads to an increase in the demand for the constituent agricultural products (corn or sugar) used in the production of ethanol. In turn, it is highly likely that an increase in the demand for *683com or sugar will lead to an increase in the production of com or sugar. Finally, it is highly likely that much of the increased production of com or sugar will occur on previously unused lands instead of displacing prior agricultural production of another kind.
. Even if the aggregate increase in com farming is not significant, given the total acreage devoted to com farming in the United States, the devotion of now idle or underused land to com farming can dramatically affect the particular environments where it occurs. The resultant harm can include "effects on surface and ground water from changes in water run-off patterns, soil erosion, wildlife effects, and effects on forests if more land is cleared for crop production.” Environmental Protection Agency, Analysis of the Economic and Environmental Effects of Ethanol as an Automotive Fuel, at iv (Apr. 1990). It is that localized incremental impact that appellants directly challenge.
. For example, in Branton v. FCC, 993 F.2d 906 (D.C.Cir.1993), cert. denied, - U.S. -, 114 S.Ct. 1610, 128 L.Ed.2d 338 (1994), the court held that a plaintiff challenging the Federal Communication Commission's failure to levy a fine against a licensee for broadcasting indecent language lacked standing because it was speculative whether the imposition of a fine would redress the plaintiff's injury. The court denied that its opinion was "inconsistent with the fundamental *684principle that increasing the price of an activity ... will decrease the quantity of that activity demanded in the market" because the court concluded that there was a low “elasticity of demand for broadcast indecency." Id. at 911-12 (explaining that non-profit broadcast journalists often ignore monetary incentives). By contrast, appellants have presented uncontroverted expert testimony from Professor Berck as to the demand and supply elasticities for com.