Carpenters Industrial Council v. Ryan Zinke, 854 F.3d 1

In 2012 the U.S. Fish and Wildlife Service designated ~9.5 million acres of federal forest in CA, OR, and WA as critical habitat for the northern spotted owl, restricting commercial timber harvest on large swaths (including >3 million acres of "matrix" lands once earmarked to supply federal timber).
The American Forest Resource Council (a trade association for lumber companies) sued to challenge the Final Rule, alleging the Service failed to use the "best scientific data available" as required by the Endangered Species Act.
The Council submitted a declaration from its president (Thomas Partin) asserting that several member firms rely on timber from the designated lands and will suffer economic injury (lost sales, reduced production, closures, layoffs) because the designation will reduce timber supply.
The Service initially did not challenge standing in district court, but after this Court’s decision in Swanson Group Manufacturing v. Jewell, the district court sua sponte questioned standing and ultimately held the Council lacked Article III standing.
On appeal the D.C. Circuit (Kavanaugh) reviewed standing de novo, concluded Partin’s declaration and the complaint demonstrated a substantial probability of injury, causation, and redressability, and reversed and remanded.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Article III standing to challenge critical habitat designation	Council: its members will suffer concrete economic injury because the designation will decrease timber supply from lands they rely on	Service: plaintiffs’ declarations are conclusory and do not show a substantial probability of injury (per Swanson)	Held: Council has standing; Partin’s declaration shows substantial probability of injury, causation, and redressability
Causation standard for future economic harm from government regulation	Decrease in supply from a relied-upon source that cannot be replaced at no cost suffices to show causation	Service: plaintiffs must show more specific, non-conclusory link between rule and economic harm	Held: Court adopts commonsense three-step test—substantial probability rule will (1) decrease supply from a particular source, (2) show plaintiff obtains raw material from that source, and (3) show economic harm will result; those elements are met here
Effect of Swanson v. Jewell on standing proofs	Council: Swanson does not control because Partin’s declaration contains concrete, non-conclusory factual detail linking supply reductions to specific member harms	Service: Swanson requires dismissal because declarations here are similarly conclusory	Held: Distinguishes Swanson; Partin’s factual assertions resemble Mountain States (92 F.3d 1228) and suffice for standing

Mountain States Legal Foundation v. Glickman, 92 F.3d 1228 (D.C. Cir. 1996) (holding a firm suffers Article III injury when government action constricts its supply of a main raw material)
Swanson Group Mfg. LLC v. Jewell, 790 F.3d 235 (D.C. Cir. 2015) (declinations of standing where declarations were conclusory and failed to show substantial probability of injury)
Lujan v. Defenders of Wildlife, 504 U.S. 555 (U.S. 1992) (Article III standing elements: injury-in-fact, causation, redressability)
Sierra Club v. FERC, 827 F.3d 59 (D.C. Cir. 2016) (associational standing—an organization can sue on behalf of a member with standing)
Chamber of Commerce v. EPA, 642 F.3d 192 (D.C. Cir. 2011) (standard that future economic harm requires a substantial probability of injury)
Dynalantic Corp. v. Department of Defense, 115 F.3d 1012 (D.C. Cir. 1997) (noting overlap of causation and redressability in standing analysis)