concurring and dissenting.
I agree that the Fair Housing Council has standing to assert a claim of retaliation against Montgomery Newspapers under 42 U.S.C. § 3617. However, I would go further and also conclude that the FHC has standing *82to assert a claim of illegal advertising under 42 U.S.C. § 3604(c), and that the FHC is injured because it must divert resources to a large-scale educational campaign to inform landlords, real estate agents, consumers and the defendant newspaper itself that discrimination based on familial status violates the Fair Housing Act. The FHC has proffered evidence that education is necessary because housing providers were continuing to write advertisements that violated 42 U.S.C. § 3604(c), and the defendant itself, Montgomery Newspapers, was continuing to publish the illegal advertisements and promote misunderstanding of the familial status provisions of the Act.
The majority’s view of standing is too narrow, and I am convinced that its opinion will do violence to the law of standing in this circuit. The majority suggests that to be injured, the FHC must have either implemented the educational campaign or submitted a more detailed plan to the district court. In the alternative, the majority states that the FHC could have produced a home seeker who was denied housing, deterred from seeking housing, or formed a misimpression about housing availability as a result of the advertisements published in the Montgomery Newspapers. The majority opines that the FHC did not demonstrate the need for the educational program and also failed to show that the plan was implemented. I disagree. The FHC has submitted a detailed plan for its educational campaign, within which it describes exactly why the campaign is a necessary response to the advertisements. This plan is sufficiently concrete to confer standing. Furthermore, the FHC does not have to produce an aggrieved home seeker because it has clearly demonstrated the need for an educational campaign to counter the advertisements that were placed by housing providers in flagrant disregard of 42 U.S.C. § 3604(c).
The majority also concludes that investigation and litigation costs alone cannot confer standing. Because I find standing for educational costs, it would ordinarily not be neeessary for me to reach this issue. However, I write separately on this issue as well, because I think that costs incurred applying legal pressure to a newspaper publishing illegal advertisements can confer standing.
I. Article III Standing Requirements
A plaintiff organization has standing if it meets the immutable requirements of Article III, Section 2 of the Constitution. First, the plaintiff must have suffered an injury in fact, an invasion of a legally protected interest that is concrete and particularized, and actual or imminent, not conjectural or hypothetical. Lujan v. Defenders of Wildlife, 504 U.S. 555, 560, 112 S.Ct. 2130, 2136, 119 L.Ed.2d 351 (1992). Second, there must be a causal connection between the injury and the challenged action of the defendant. The injury has to be fairly traceable to the defendant’s actions, and not the result of the independent action of a party not before the court. Simon v. Eastern Ky. Welfare Rights Org., 426 U.S. 26, 41-42, 96 S.Ct. 1917, 1926, 48 L.Ed.2d 450 (1976). Third, it must be likely, as opposed to merely speculative, that the injury will be redressed by a favorable decision. Lujan, 504 U.S. at 561, 112 S.Ct. at 2136; Simon, 426 U.S. at 38, 43, 96 S.Ct. at 1924, 1926.1 When the Supreme Court considered a fair housing organization’s standing to sue under the Fair Housing Act, it concluded that Congress intended to abrogate any additional prudential standing requirements and allow standing based only upon the constitutional requirements of Article III. Havens Realty Corp. v. Coleman, 455 U.S. 363, 372, 102 S.Ct. 1114, 1121, 71 L.Ed.2d 214 (1982) (citing Gladstone Realtors v. Village of Bellwood, 441 U.S. 91, 103 n. 9, 109, 99 S.Ct. 1601, 1609 n. 9, 1612, 60 L.Ed.2d 66 (1979)).
Havens held that the plaintiff organization had standing to sue because the activity that allegedly violated the Fair Housing Act perceptibly impaired its counseling and referral services. This impairment met the “injury in fact” test because a concrete and demonstrable drain on resources is a more plausible injury than a conjectural “setback” to an *83organization’s abstract social interests. Id. at 379, 102 S.Ct. at 1124-25 (distinguishing Sierra Club v. Morton, 405 U.S. 727, 92 S.Ct. 1361, 31 L.Ed.2d 636 (1972)). Following Havens, the Courts of Appeals have agreed that a fair housing organization will have standing to challenge a newspaper’s advertising practices under 42 U.S.C. § 3604(c) if it can demonstrate that the newspaper’s discriminatory advertising caused the organization to divert resources to identify and negate the impact of those advertisements. See, e.g., Fair Employment Council of Greater Washington, Inc. v. BMC Mktg. Corp., 28 F.3d 1268, 1276-77 (D.C.Cir.1994); Housing Opportunities Made Equal, Inc. v. Cincinnati Enquirer, Inc., 943 F.2d 644 (6th Cir.1991); Spann v. Colonial Village, Inc., 899 F.2d 24, 27 (D.C.Cir.1990). The FHC has clearly met this burden.
The Circuits are split, though, as to whether the diversion of resources solely for litigation and investigation activities can confer standing. Compare Spann, 899 F.2d at 27 (D.C.Cir.1990) (litigation costs cannot confer standing), with Ragin v. Harry:Macklowe Real Estate Co., 6 F.3d 898, 905 (2d Cir.1993) (finding standing based on staff time spent exclusively on litigation), and Hooker v. Weathers, 990 F.2d 913, 915 (6th Cir.1993) (investigation to confirm facts in complaint insufficient to confer standing), and City of Chicago v. Matchmaker Real Estate Sales Ctr., Inc., 982 F.2d 1086, 1095 (7th Cir.1992) (legal efforts directed against discrimination are sufficient to impart standing). The majority holds that the litigation and investigation costs cannot confer standing. I disagree and would hold that in some situations, like this case, they can constitute an Article III injury.
II. Educational Injury
A. Sufficiency of Evidence
As explained above, the courts interpreting Havens agree that the diversion of resources to educational programs is sufficient to impart Article III standing. See, e.g.,- Spann, 899 F.2d at 27. A “concrete drain on time and resources is sufficient to satisfy Article Ill’s injury in fact requirement.”24 Spann, 899 F.2d at 29. An “identifiable trifle” of this type of injury will suffice to confer standing upon the FHC.2 United States v. Students- Challenging Regulatory Agency Procedures, 412 U.S. 669, 689 n. 14, 93 S.Ct. 2405, 2417 n. 14, 37 L.Ed.2d 254 (1973) (rejecting the argument that standing should be limited to those significantly injured, and ruling that any level of injury is sufficient to confer standing). Accordingly, to demonstrate “educational injury,” the FHC must only raise a genuine issue of material fact that its plan to educate the real estate industry and consumers will be a concrete and demonstrable drain on its resources, and that such education is necessary to counter the illegal housing advertisements.
The FHC has presented sufficient evidence of injury to compel my conclusion that Montgomery Newspapers is not entitled to judgment as a matter of law. James Berry, the executive director of the FHC, described the campaign by which the FHC will attempt to educate real estate professionals. Berry also stated that the FHC will have to spend almost $100,000 in newspaper advertising to counter Montgomery News’ discriminatory messages. Jan Chadwick, Assistant Director of the FHC, explained that the FHC has formulated “an educational plan that would educate both the public and the industry what the proper Fair Housing laws are ... to reverse the damages [caused by discrimination] in the whole region, specifically families with children.” this explanation mirrors FHC’s allegation that
“each act of discrimination conducted in the Delaware Valley causes a setback to the good work accomplished by the FHC’s educational and outreach efforts and to the development of an integrated housing community. As a result, the FHC must launch further efforts to undo the damage that the discrimination has caused.”
*84(Pl.’s Am. Comp. ¶ 10.) The FHC also prepared a detailed plan entitled “Appellants’ Statement of Proposed Education-Repair Campaign.” The purpose of the plan is to reach, among others, consumers, housing providers, and real estate professionals to counteract advertisements that leave readers believing that it is legal to turn away families with children. The “Proposed Plan” explains what the FHC alleges: a large-scale educational campaign is necessary because the continued publication of illegal advertisements causes an “overwhelming misunderstanding” about the Act. The Plan is specific to the extent that it contains sample advertisements to be placed in Montgomery Newspapers, the frequency of planned publication, a proposed budget for executing the Plan, and details of educational efforts other than newspaper advertisements.
The majority states that the only evidence relating to the educational effort produced by the FHC was “an allegation that, at some future time, it would be required to spend almost $100,000 in newspaper advertising and more than $300,000 in seminars and mailings to reach consumers to counter the advertisements’ discriminatory message.” This statement is incorrect, based on the substantial record evidence.
B. The need for corrective action
The majority’s conclusion crumbles upon examination of the entire Proposed Plan and explanations of the FHC staff, discussed above. By focusing only on the necessity to educate home seekers and consumers, the majority overlooks an entire segment of the FHC’s mission: to educate publishers and housing providers. Montgomery Newspapers published discriminatory ads, which itself demonstrates that housing providers and the newspaper do not understand the terms of the Fair Housing Act. Because the FHC aims to ensure compliance by education, it must now divert resources to redress that damage. Thus, I am compelled to conclude that the FHC has suffered the requisite “identifiable trifle” of injury to its educational programs.
The FHC has demonstrated that its educational plan is a necessary response to correct the discriminatory advertisements published by Montgomery Newspapers. The “Proposed Plan” explains that, among others, real estate professionals are ignorant of the family status provisions of the Fair Housing Act. Advertisements that contain comments such as “no children or pets,” and “professional male need only apply” exemplify this ignorance. The FHC intends to reach consumers to explain the Fair Housing Act. However, the majority fails to recognize that the FHC also plans to explain Fair Housing Act compliance to housing providers and real estate professionals, who place and read advertisements in Montgomery Newspapers and perpetuate discriminatory advertising.
The majority suggests that the FHC would have satisfied standing requirements if it could show that home seekers have actually been barred from housing, deterred from seeking housing, or formed a misimpres'sion about housing availability as a result of the advertisements published in the Montgomery Newspapers. This is simply incorrect. An aggrieved home seeker is not necessary to show a violation of section 3604. Housing providers and newspapers violate 42 U.S.C. § 3604(c) upon publication. The Fair Housing Act expressly empowers organizations like the FHC to enforce its provisions without joining a home seeker as a co-plaintiff, 42 U.S.C. §§ 3602, 3613, in the federal district courts, 42 U.S.C. § 3613(a)(1)(A), to seek the award of actual or punitive damages or the grant of permanent or temporary injunctive relief. 42 U.S.C. § 3613(c)(1).
C. Imminent and Concrete Injury
The FHC has successfully adduced facts to show concrete injury that is certainly impending, as required by Lujan, 504 U.S. at 564, 112 S.Ct. at 2138. The majority concludes that the FHC would be injured if it already implemented the educational program. This is not correct. The eases are legion supporting a conclusion that the FHC is not required to actually pay for the advertising campaign before it can assert standing. See, e.g., Pennell v. City of San Jose, 485 U.S. 1, 8, 108 S.Ct. 849, 855, 99 L.Ed.2d 1 (1988) (holding that because it is not unduly speculative to conclude that the ordinance at *85issue mil be enforced against members of the Association, this is a sufficient threat of actual injury to satisfy Article III); Babbitt v. Farm Workers, 442 U.S. 289, 298, 99 S.Ct. 2301, 2308, 60 L.Ed.2d 895 (1979) (“A plaintiff who challenges a statute must demonstrate a realistic danger of sustaining a direct injury as a result of the statute’s operation or enforcement.”); Duke Power Co. v. Carolina Envtl. Study Group, 438 U.S. 59, 98 S.Ct. 2620, 57 L.Ed.2d 595 (1978) (Plaintiff alleged that, if constructed, the power plant’s operation would cause the emission of radiation. The Court held that the plaintiffs alleged injury was sufficiently concrete to confer standing.); Pennsylvania v. West Virginia, 262 U.S. 553, 593, 43 S.Ct. 658, 663, 67 L.Ed. 1117 (1923) (“[OJne does not have to await the consummation of threatened injury to obtain preventive relief. If the injury is certainly impending, that is enough.”); Roe v. Operation Rescue, 919 F.2d 857, 864-65 (3d Cir.1990) (holding that clinics not actually blockaded by defendant organization had standing because the threat that defendants would blockade the clinics in the future was real and immediate); Public Interest Research Group, Inc. v. Powell Duffryn, 913 F.2d 64, 71 (3d Cir.1990) (plaintiffs’ asserted injury, that they would use the water for boating and aesthetic enjoyment if it was not polluted, was sufficient to confer standing, even though they had not used the water in its polluted state).
The FHC also satisfies Lujan by setting forth concrete plans for its educational program. The majority categorizes the FHC plan as the “some day” intentions prohibited by Lujan, 504 U.S. at 560-61, 112 S.Ct. at 2138, and suggests that the FHC has proffered no concrete plans or specifications as to when the plans will be carried out. I disagree. In Lujan, the Supreme Court suggested that had the plaintiffs actually purchased a plane ticket, their plans to observe the endangered species would not be “someday intentions.” Id. Here, the plan submitted by the FHC is more extensive and expensive than the mere plane ticket in Lujan.
Moreover, the majority’s conclusion is at odds with the Supreme Court’s holding in Village of Arlington Heights v. Metropolitan Housing Dev. Corp., wherein mere blueprints and building plans were sufficient to confer standing on a non-profit housing organization. 429 U.S. 252, 261, 97 S.Ct. 555, 561, 50 L.Ed.2d 450 (1977). The housing organization in Arlington Heights planned to build low income housing to further its interest in making low cost housing available in areas where it was scarce, but its plans were thwarted when the local government denied its zoning request. The Court held that the organization’s plans to build, and its related goals, were not an abstract concern and provided the essential dimension of specificity required to determine standing at trial. Id. at 263, 97 S.Ct. at 562. The situation of the FHC is analogous. The FHC plans to educate the public that discrimination based on familial status is illegal. That plan is equally specific and detailed, and therefore sufficient to confer standing.
III. Investigation Injury
The FHC also adduced evidence sufficient to confer standing for a 42 U.S.C. § 3604(c) violation based on the costs to investigate the housing advertisements in the Montgomery Newspapers. Havens found “injury in fact” when a fair housing organization had to divert resources to “identify and counteract” discriminatory practices. 455 U.S. at 379, 102 S.Ct. at 1124. Like “educational injury,” the courts following Havens agree that costs incurred investigating violations of the Fair Housing Act can confer standing. See, e.g., Hooker v. Weathers, 990 F.2d 913, 915 (6th Cir.1993) (costs incurred in the investigation to confirm the facts and circumstances alleged in the complaint constitute injury for standing purposes).
The majority erroneously concludes that the FHC investigation cannot confer standing because it was a regular part of the day-to-day operations of the organization. It cites “depositions of FHC staff” in support of this conclusion. Indeed, there was some suggestion in the deposition of Jan Chadwick that reviewing housing advertisements was a regular matter of business for FHC staffers. However, based on the evidence, one could also reasonably conclude that the FHC investigation followed violations of 42 U.S.C. *86§ 3604(c), and because of repeated violations, became a daily function of the FHC. For standing purposes, we look only for an “identifiable trifle” of injury, so the FHC need only submit evidence to create a genuine issue of whether it diverted the slightest amount of additional time to read the Montgomery Newspapers. U.S. v. Students Challenging Regulatory Agency Procedures, 412 U.S. 669, 689 n. 14, 93 S.Ct. 2405, 2417 n. 14, 37 L.Ed.2d 254 (1973). I believe they have met this burden.
The FHC made a specific showing of its increased efforts to identify and eventually counteract discriminatory ads under 42 U.S.C. § 3604(c). The record shows that investigation efforts began in 1989, when the FHC began reviewing the housing advertisements in the Montgomery Newspapers. The investigation was prompted by the FHC’s discovery that despite a recent amendment to the Fair Housing Act, local papers did not comply with the provisions prohibiting discrimination on the basis of family status. The FHC filed charges with the Pennsylvania Human Relations Commission and the Department of Housing and Urban Development, but the illegal advertisements continued. The graph submitted by the FHC shows that the FHC devoted more resources to identify the discriminatory advertisements in the Montgomery Newspapers than it would have normally directed toward simply reviewing housing advertisements. The FHC also proffered the affidavit of Executive Director James Berry explaining the increased investigative efforts, and this was supported by the materials charting the resources dedicated to investigating the housing advertisements in the Montgomery News.
Counsel for Montgomery Newspapers suggested during oral argument that the FHC could have sent testers to determine whether the ads were placed with the intention of discrimination on the basis of familial status. Certainly, that was one potential investigatory technique available to it. However, no one technique is required to establish standing. A violation of section 3604(c) occurs upon publication. This is distinguishable from a violation of section 3604(d), which occurs when misleading information is given to a tester. Naturally, one method of identifying violations under section 3604(c) is to read the newspaper. FHC did just that, and its efforts were intended to identify the pattern and practices of discriminatory conduct and to counteract it through legal pressure and education.
Congress intended to confer broad rights to enforce the Fair Housing Act. See Havens, 455 U.S. at 374 n. 14, 102 S.Ct. at 1122 n. 14. For example, a tester may pose as a prospective purchaser, expect unlawful practices based on race, and have standing to sue under 42 U.S.C. § 3604(d) if the housing provider misrepresents the availability of housing. This is distinguishable from 42 U.S.C. § 3604(a), which requires a bona fide offer for housing to present a claim of a discriminatory refusal to sell or rent. However, like the tester provision, there is no “bona fide” requirement for enforcement of the advertisement provision.
Nevertheless, the majority suggests that the investigation must be motivated by a complaint about advertising in the Montgomery Newspapers. This is not correct. Independent investigations not initiated by complaints were also a part of the regular activities of the fair housing organization in Havens. In Havens, the organization’s activities included:
“conducting independent investigations of real estate brokers located in the metropolitan area to determine whether housing is being made available without regard to race; and taking appropriate steps to eliminate any racial discriminatory housing practices it may have found to exist.”
Coles v. Havens Realty Corp., 633 F.2d 384, 385 (4th Cir.1980), affd sub. nom. Havens Realty Corp. v. Coleman, 455 U.S. 363, 102 S.Ct. 1114, 71 L.Ed.2d 214 (1982). The Court of Appeals for the Fourth Circuit concluded that the drain on resources necessary to identify violations of the Fair Housing Act is sufficient to confer standing, irrespective of whether such investigation was motivated by a complaint.
*87IV. Litigation Injury
The FHC’s “litigation injuries” in the form of attorneys’ fees to bring this case are insufficient to impart standing under the Fair Housing Act, especially since the act provides for recovery of attorneys’ fees. 42 U.S.C. § 3613(c)(2). My agreement with the majority stops there.
Havens did not specifically decide whether the costs of litigation or enforcement of the Fair Housing Act are sufficient to confer standing. Arguably, this activity would fall under the category of activities intended to “counteract” discrimination. Courts from the Second and Seventh Circuits have read Havens to confer standing even when resources are diverted for litigation purposes only. See, e.g., City of Chicago v. Matchmaker Real Estate Sales Ctr., Inc., 982 F.2d 1086, 1095 (7th Cir.1992); Village of Bell-wood v. Dwivedi, 895 F.2d 1521, 1526 (7th Cir.1990); Ragin v. Harry Macklowe Real Estate Co., 6 F.3d 898, 905 (2d Cir.1993). The majority does not find these cases persuasive, instead relying on the Court of Appeals for the District of Columbia Circuit’s conclusion that litigation costs alone cannot confer standing because it would allow litigants to achieve manufactured, or “purely self-referential injury” by merely filing the complaint. Fair Employment Council of Greater Washington, Inc. v. BMC Marketing Corp., 28 F.3d 1268 (D.C.Cir.1994); Spann v. Colonial Village, Inc., 899 F.2d 24 (D.C.Cir. 1990).
In my opinion, the FHC has standing, even under the Court of Appeals for the District of Columbia Circuit’s holdings, because many activities that fall between investigation and litigation can confer standing under Havens. For example, in this case, the FHC chose many non-litigation methods to apply legal pressure upon the Montgomery Newspapers to enforce the Fair Housing Act. The FHC filed a complaint with the. Pennsylvania Human Resources Commission. In addition, the FHC attempted to notify the newspaper of its violations of section 3604(c). My conclusion to confer standing upon fair housing organizations for enforcement activities, other than the filing of the lawsuit, does not conflict with the Court of Appeals for the D.C. Circuit’s eases that the majority finds persuasive. BMC Marketing and Spann only prohibit conferral of standing from the act of filing the lawsuit.
My conclusion is also entirely consistent with the policies of the Fair Housing Act. First, Congress intended that groups like the FHC take action to enforce the provisions of the Fair Housing Act. If we do not recognize the efforts that precede litigation as injury, we will cramp the options now open to fair housing organizations that are laboring to counteract discrimination. Large scale, long term pre-litigation efforts that draw from program resources should constitute injury for standing purposes even if they culminate in litigation. Second, I see little danger that plaintiffs may “manufacture standing” in the context of the Fair Housing Act. It is not that easy. The greater danger is exaggerating the risk of nullifying Article III, and thereby eviscerating the statutory scheme of the Fair Housing Act, which clearly relies upon private enforcement to ensure compliance.
The FHC correctly states that the Fair Housing Act relies upon private attorneys general to enforce its provisions. See 42 U.S.C. § 3613;3 Traficante v. Metropolitan Life Ins. Co., 409 U.S. 205, 210-211, 93 S.Ct. 364, 367-68, 34 L.Ed.2d 415 (1972) (noting the paucity of statutory remedies); Hooker v. Weathers, 990 F.2d 913, 915 (6th Cir.1993) (finding standing under Havens due to the increase of resources devoted to programs *88independent of its suit challenging the action); Housing Opportunities Made Equal v. Cincinnati Enquirer, Inc., 943 F.2d 644, 646 (6th Cir.1991) (“Courts have given a broad reading to the FHA in order to fulfill its remedial purpose.”). Accordingly, we have an obligation to address the issue of standing (pursuant to “litigation injuries”) so as to fulfill the private enforcement provisions of the Fair Housing Act. “We can give vitality to [The Fair Housing Act] only by a generous construction which gives standing to sue to all ... who are injured by ... discrimination ... within the coverage of the statute.” Trafficante, 409 U.S. at 212, 93 S.Ct. at 368. We should carefully consider which “litigation injuries” confer standing to maintain the integrity of Article III, while still allowing fair housing organizations to fulfill their role as private attorneys general. Spann, 899 F.2d at 30 (citing Trafficante, 409 U.S. at 211, 93 S.Ct. at 368). As explained above, I believe I have done so in this case: allowing the FHC’s investigations and legal pressure, applied through letters or administrative proceedings to confer standing, but rejecting the theory that the FHC’s costs to file this lawsuit can impart standing.
Finally, we cannot overlook the will of the legislature in determining whether the FHC has standing to sue. Havens, 455 U.S. at 373, 102 S.Ct. at 1121. The injury “required by Article III may exist solely by virtue of ‘statutes creating legal rights, the invasion of which creates standing.’ ” Id. (citing Warth v. Seldin, 422 U.S. 490, 500, 95 S.Ct. 2197, 2205, 45 L.Ed.2d 343 (1975)). “The policies of the Act and the concrete injuries alleged by the plaintiff organizations thus intertwine to support plaintiffs’ standing to bring this suit.” Spann, 899 F.2d at 31 (citations omitted). Congress specifically endorsed the values that the FHC seeks to enforce and their methods of enforcement, in the Fair Housing Act:
“The Congress finds that (1) in the past half decade there have been major legislative and administrative changes in Federal fair housing and fair lending laws and substantial improvements in the Nation’s understanding of discrimination in the housing markets; ... (9) the proven efficacy of private nonprofit fair housing enforcement organizations and community-based efforts makes support for these organizations a necessary component of the fair housing enforcement system.”
Fair Housing Act of 1968, Pub.L. No. 102-550, Section 905(a), 106 Stat. 3869 (1992).
In sum, we should not so fear the possibility of “manufactured standing” that we set barriers artificially high and thereby nullify the private enforcement provisions of the Fair Housing Act.
V. Conclusion
For all the foregoing reasons and upon all the foregoing grounds, I conclude that the FHC has standing to advance a claim under 42 U.S.C. § 3604(c). I would give the FHC its day in court.
. The district court only addressed the first element of standing, holding that the FHC did not show Article III injury. Accordingly, I do not address the final two elements of causation and redressability, although I will point out that those two elements are clearly present here.
. We do not confuse this with a "scintilla of evidence” which is unquestionably insufficient to defeat a motion for summary judgment. Anderson v.-Liberty Lobby, 477 U.S. 242, 252, 106 S.Ct. 2505, 2512, 91 L.Ed.2d 202 (1986). In this case, the FHC has presented'Sufficient evidence to allow a reasonable jury to return a verdict in its favor on the issue of standing to sue under the Fair Housing Act.
. A violation of the Fair Housing Act does not constitute per se injury to a fair housing organization. The FHC is mistaken, to the extent that it reads Bennett v. Spear to confer standing without meeting Article III requirements. 520 U.S. 154, 117 S.Ct. 1154, 137 L.Ed.2d 281 (1997). Bennett discusses the "zone of interest test,” a jurisprudential test for standing, which applies above and beyond the Article III. Id. at-, 117 S.Ct. at 1160 (stating Article III is an irreducible constitutional minimum). The "zone of interest test” does not apply to standing to pursue an action under the Fair Housing Act. Traficante v. Metropolitan Life Ins. Co., 409 U.S. 205, 209, 93 S.Ct. 364, 367, 34 L.Ed.2d 415 (1972). Despite its misinterpretation of Bennett, the Council has struck on an important point regarding their role in ensuring compliance with the Fair Housing Act.