ILANA DIAMOND ROVNER, Circuit Judge.
Thе United Transportation Union-Uli-nois Legislative Board (the “Union”) challenges several determinations of the Surface Transportation Board (the “Board”) as to whether Effingham Railroad Company (“Effingham Railroad”) required Board authorization to operate various sections of track in and near an industrial park in Effingham, Illinois. The Board, for its part, contends that the Union lacks standing to sue and defends its own determinations. We hold that the Union has standing, but we deny the Union’s petition for review because, under
Chevron, U.S.A., Inc. v. Natural Resources Defense Council, Inc.,
I.
The City of Effingham, Illinois, is served by the Illinois Central Railroad (“Illinois Central”) and Consolidated Rail Corporation (“Conrail”). In November 1996, Eff-ingham Railroad, a new carrier which had not yet begun operations, proposed to the Board (in its “Proposal I”) to operate approximately 206.05 feet of existing track, which it intended to acquire from Agracel Corporation (“Agracel”). This existing track was part of a 490-foot track (called “the beer track” because it was used to transfer beer from rail cars to trucks) connected to Conrail’s line. Effingham Railroad also proposed to construct 9,835 feet of new track within the industrial park. Ready-Mix, an existing shipper located in the industrial park, and which apparently did not have rail service, would be served by 1,867 feet of this new track. This track would also serve new shippers that might locate in the industrial park.
Normally provision of rail service as part of the interstate rail network, 49 U.S.C. § 10501(a)(2), including construction, acquisition, or operation of extended or additional “railroad line[ ],” requires authorization from the Board, see 49 U.S.C. § 10901, unless the transaction is exempted from Bоard regulatory requirements under recent deregulatory initiatives. See 49 U.S.C. § 10502 and 49 C.F.R. § 1150.31(a). However, Board authorization is not required for the construction, acquisition, or operation of “spur, industrial, team, switching, or side traek[ ]” (hereinafter “spur” track). 49 U.S.C. § 10906 (providing an exception to Board authority under § 10901). 1
Effingham Railroad asked the Board for a declaratory order that the Board lacked “jurisdiction” under the § 10906 spur track exception over the new and existing traсk it proposed to operate within the industrial park. Alleging union employee safety and environmental concerns, the Union opposed Effingham Railroad’s petition. The proposed construction, the Union argued, was railroad line under § 10901, requiring Board authorization or exemption. In opposing the petition, the Union did not address the classification of the “beer track” segment. The Board rejected Effingham Railroad’s petition in an оrder of September 8, 1997 (“Decision I”), treating all the track discussed in the petition as § 10901 railroad line and instructing Effingham Railroad to file an application for authorization or a notice of exemption. The Union then petitioned the Board to reconsider its determination *610 that the “beer track” segment in particular was railroad line, arguing that this segment was properly classified as spur and also that the Board should simply have declined to issue a declaratory order and refrained from making any determination about the status of the track. This petition was denied.
A few weeks later in September 1997, Effingham Railroad filed the appropriate notices seeking an exemption for operation of railroad line pursuant to 49 C.F.R § 1150.31(a). Such exemptions are available and effective automatically seven days after filing, see id. § 1150.41 et seq., although they are subject to revocation upon a proper showing that regulation of the track is necessary to carry out federal rail transportation policy. See 49 U.S.C. § 10502(d). By the time of this new filing, Effingham Railroad’s proposal had changed. According to its Proposal II, Effingham Railroad would now operate the 206.05-foot segment of the “beer track” under a lease or operating agreement from Agracel instead of purchasing that track. It would also operate a longer segment of nеw track under sidetrack agreements with Total Quality Warehouse (“TQW”), a noncarrier shipper that would construct and own the track. Effingham Railroad and TQW are distinct and, apart from the arrangement just described, unrelated enterprises. The new track to be constructed by TQW would now comprise two segments: (1) 400 feet of sidetrack (the “warehouse track”) connecting with the beer track, serving a new facility to be built by TQW, which had an existing facility on the beer track, and (2) 9,210 feet of sidetrack (the “long track”) connecting Effingham Railroad with Illinois Central. No one requested Board authorization or filed any notice of exemption for the construction of the long track.
In September and December 1997, the Union filed petitions to “reject, revoke, or stay” ’Effingham Railroad’s exemptions and for reconsideration of Decision I. The Union argued that: (1) the beer track should be classified as excepted spur track; (2) Decision I required that the warehouse track should be classified as railroad line; and (3) the exemption for operation of the long track, undisputedly classified as railroad line, should be withheld because its construction by TQW was a device to circumvent the normal requirement of environmental analysis for such construction. In an order of September 18, 1998 (“Decision II”), however, the Board reaffirmed its determination in Decision I that the beer line was § 10901 railroad line requiring authorization or exemption and further determined that the warehouse track was § 10906 spur track excepted from Board authority. Finally, the Board found that the long track was railroad line and declined to revoke Effingham Railroad’s exemption for that track. This appeal followed.
II.
The Board argues that the Union’s petition should be dismissed for lack of standing because the Union failed to show the actual or imminent, concrete and particularized injury,
see Lujan v. Defenders of Wildlife,
In any event, the environmental concerns raised by the Union about health and safety risks posed to its members by the construction of the warehouse track and the long track are sufficient to establish Union standing. All three Article III standing requirements are satisfied: (1) the risk of environmental injury to employees (2) caused by railroad construction and operation is both obvious and acknowledged by the Board’s own regulations, see 49 C.F.R. § 1105.6 (requiring Environmental Impact Statement for certain railroad construction), and (3) the requested remedy is essential to redressing the harm alleged. The prudential requiremеnts are satisfied, since the governing statute expressly makes it federal rail transportation policy “to encourage ... safe and suitable working conditions in the railroad industry,” 49 U.S.C. § 10101(11). Unionized railroad employees who have health and safety concerns about the environment at work are within the zone of protection of § 10901 because they are among the chief intended beneficiaries of the federal rail transportation poliсy under § 10101.
The Board further disputes whether environmental concerns are germane to the Union’s purpose,
5
but it is difficult to see what might be more germane to the purpose of a union than protecting its members from environmental risks that could affect job-related health and safety. In labor relations, practices affecting safety, sanitation, and health are considered mandatory subjects of bargaining.
See, e.g., Library of Congress v. Federal Labor Relations Authority,
III.
In a recently decided case, United Transp., Union-Illinois v. Surface Transportation Board,
If we reframe its argument in terms of whether Chevron applies,
6
the Union can be taken to urge that the Board's determinations about the proper classification of track are not entitled to deference because § 10906 states that the Board "has no authority" over the construction, acquisition, or operation of spur track, and therefore lacks "jurisdiction" over such transactions. The Union interprets the question of how track is to be classified as one concerning the scope of agency jurisdiction, and maintains that courts will therefore closely examine the Board's decision. The Union cites no authority for this proposition, but an agency's determination about the scope of its ow~i jurisdiction indeed does receive de novo review and not Chevron deference. See Chicago Rail Link,
The statutory language the Union cites, however, does not support any less deferential review than dictated by Chevron. The § 10906 exception states that the Board "does not have authority" over "construction, acquisition, operation, abandonment, or discontinuance of spur track," but this does not mean that the Board lacks jurisdiction over such transactions. That would flatly contradict the unambiguous statutory language providing that the Board has "exclusive" jurisdiction over the "construсtion, acquisition, operation, abandonment, or discontinuance" of spur track. 49 U.S.C. § 10501(b)(2). Statutory provisions are to be interpreted to be consistent with one another. Chicago Rail Link,
Since the Board's jurisdiction over railroad line under § 10901 is uncontested and its jurisdiction over spur track is manifest, the dispute here about classification of the track at issue, like the dispute in Chicago Rail Link, is not about whether the Board has jurisdiction, but about under which provision of the statutes administered by the Board it exercises jurisdiction. "When one among several statutes
*613
that an agency administers [clearly] applies, but it is unclear from the plain language of the statute itself precisely which one is applicable, the agency’s choice among which of the several statutes to apply is not a jurisdictional but an interpretative decision that is located squarely in the heartland оf
Chevron
deference.”
Chicago Rail Link,
We therefore apply
Chevron.
Under the first step of a
Chevron
analysis, courts do not defer to even reasonable agency interpretation if “Congress has spoken directly to the precise point at issue,”
Chevron,
With respect to the Board’s decisions to classify the beer track segment as railroad line and the warehouse track as spur, the Union offers no argument that the statute plainly dictates contrary results, and so we inquire here only whether the Board’s determinations wеre reasonable. In deciding how to classify each track, the Board applied a test based on the “intended use” of the track. See
Nicholson v. Interstate Commerce Comm’n,
In
Chicago Rail Link,
In Decision II, the Board then found that the warehouse track in Proposal II was excepted spur. It found that Effingham Railroad was then the carrier serving the industrIal park, with the beer track as its railroad line, and that the warehouse track therefore would not extend Effingham Railroad's operations into the territory of another railroad. The long track, by contrast, extended beyond the boñndaries of the industrial park to establish connections with other railroads, and so, under the tenant use test, was railroad line properly subject to a notice of exemption. The Union correctly argues that the Board's determination that the warehouse track was spur cannot .be sustained if we set aside as unreasonable the Board's prior determination that the beer track was railroad line. Since we do not disturb the beer track finding, however, we have no reason to disturb the warehouse track determination.
The last issue concerns the construction of the long track, undisputedly properly classified as railroad line under 49 U.S.C. § 10901. Effingham Railroad obtained only an exemption for operation of the long track and not its construction. The long track was to be constructed by TQW, a noncarrier shipper not affiliated with Effingham Railroad, neither of whiсh sought authorization or exemption for this construction, The Union claims that it was illegal for Effii~gham Railroad's operation to be exempted unless TQW's construction was authorized or exempted. The Union's underlying concern appears to be that without Board authorization, the long track can be constructed without the normally required environmental analysis, see 49 C.F.R. §~ 1105.5(b)(1) & 1105.6, thereby risking exposing Union members who work in the industrial park to environmental hazards сaused by that construction.
The Union offers no reason beyond bald assertion to doubt that Chevron applies to the Board decisions to exempt the operation of the long track from authorization, so we apply that standard. Because the statutory language of § 10901 does not clearly and unambiguously compel the re-suit the Union desires, we review the agency's determination under the second prong of Chevron, giving deference to reasonable agency interpretation of the statute. The Union seems to argue that the Board's interpretation was unreasonable because the language of § 10901 requires "a person" to obtain Board authorization to "construct an extension to any of its railroad lines" or "construct an additional railroad line." The Union argues that TQW is a "person," for § 10901 purposes, referring to Texas & New Orleans R.R. Co. v. Northside Ry. Co.,
But first, § 10901 does not unambiguously say that a noncarrier shipper is a "person" within the meaning of the statute. The question is not much illuminated by the rather old cases cited in Texas & New Orleans R.R. (itself not current) which at any rate address only noncarriers that, unlike TQW, would become carriers upon commencing operation over newly constructed line. It would have been reasonable, therefore, for the Board not to have treated TQW as a "person" requiring authorization or exemption for construction of railroad linе under § 10901. Furthermore, even if TQW were a "person" within the meaning of § 10901, the language of the statute does not make it clear whether, in the circumstances, the long track is an *615 “exten[ded]” or “additional” railroad line. These are the only sorts of track construction of which requires authorization under § 10901 by the terms of the statute. Since nothing in the record indicates that TQW has any other railroad lines for the long track to be an extension of or addition to, the Board would not have been unreasonable to find that the long track was not extended or additional railroad line. Finally, even if TQW did require authorization or exemption for the construction of the long track — we do not say that TQW required any such thing — it simply does not follow that Effingham Railroad may not be exempted from authorization to operate the track. The language of § 10901 does not say or imply that track newly constructed without proper authorization by a noncarrier shipper may not properly be granted authorization or exemption for operation by a completely different and unrelated carrier. The Board would not have been unreasonable to refuse to read into the statute a novel and nontextual principle of this sort.
The Union’s petition for review of the determinations of the Board is therefore Denied.
Notes
. To be exact in our terminology, transactions involving track classified as "railroad line,” over which the Board has authority under 49 U.S.C. § 10901, but which have been exempted under 49 U.S.C. § 10502 and 49 C.F.R. § 1150.31(a), are referred to as "exempted.” Transactions involving track classified as "spur track,” over which the Board has no authority under 49 U.S.C. § 10906, are referred to as "excepted.”
. In order for a party to bring suit in federal court, three constitutional requirements under Article III must be met: (1) the party must have personally suffered an аctual or threatened injury caused by the defendant's illegal conduct; (2) the injury must be fairly traceable to the challenged conduct; and (3) the injury must be one that is likely to be redressed by a favorable decision.
Simmons v. Interstate Commerce Comm’n,
. For the “zone of interest” test,
see Simmons,
. In some circumstanсes, moreover, we may "elide the jurisdictional issue” in order to reach the merits even prior to resolving a question of statutory or prudential standing.
See McNamara v. City of Chicago,
.An association such as the Union has standing to represent its members if: (1) its members could sue in their own right; (2) the interests asserted are germane to the Union’s purpose; and (3) individual Union members are not needed to participate.
Simmons,
. The Union's other arguments that some other standard of review than Chevron should apply in this case are canvassed and rejected in Chicago Rail Link,