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Friends of Tims Ford v. Tennessee Valley Auth.

ELR Citation: 39 ELR 20259
Nos. No. 08-5706, (6th Cir., 11/06/2009)

The Sixth Circuit held that a group of residents lacked standing to challenge the TVA's implementation of a land management plan for a nearby reservoir under NEPA and the Tennessee Valley Authority Act. The residents failed to connect the procedural harm alleged in their complaint—the creation of a new land use classification in the EIS without an EA in violation of NEPA—to specific harm threatening particular residents. Accordingly, they lack standing for their procedural injuries under NEPA. The residents also lack standing to allege ongoing harm to their aesthetic and recreational enjoyment of the reservoir. The residents failed to allege future injury that could be redressed by the requested declaratory or injunctive relief.