Northern Laramie Range Alliance v. Federal Energy Regulatory Commission, 733 F.3d 1030

Wasatch Wind Intermountain sought FERC certification for two wind facilities; Alliance opposed and appeals FERC decision.
Standing turns on traceability and redressability; Alliance argues rate increases link to Wasatch certification, but causation is uncertain.
Alliance members buy electricity from Rocky Mountain Power (RMP); two contracts with Wasatch ended; facilities not completed; no buyer secured.
Regulatory framework under PURPA required utilities to buy qualifying facility output; Wasatch certified as two facilities, though debate if they’re one or two.
RMP agreed to 20-year purchase contracts triggered by Wasatch’s certification; those agreements were signed in 2010; some affected costs.
Wyoming Public Service Commission determined avoided costs and rate levels; a 2012 stipulation reduced the increase, but does not reveal whether Wasatch caused rate changes.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing (traceability and redressability)	Alliance claims rate increases are traceable to Wasatch certification.	Rates depend on RMP and Wyoming Commission decisions, not solely on Wasatch certification.	Alliance lacks standing; petition dismissed.

Lujan v. Defenders of Wildlife, 504 U.S. 555 (Supreme Court, 1992) (standing burden; traceability and redressability required)
Nova Health Sys. v. Gandy, 416 F.3d 1149 (10th Cir. 2005) (standing analysis for administrative appeals)
Clapper v. Amnesty Int’l USA, 133 S. Ct. 1138 (Supreme Court, 2013) (traceability requires causation and not speculative harms)
Iowa League of Cities v. EPA, 711 F.3d 844 (8th Cir. 2013) (summary-judgment-like standard for standing in agency-review cases)
Sierra Club v. EPA, 292 F.3d 895 (D.C. Cir. 2002) (standing burden in administrative appeals; use of summary-judgment framework)
Klamath Water Users Ass’n v. F.E.R.C., 534 F.3d 735 (D.C. Cir. 2008) (redressability requires likelihood of relief producing actual rate changes)