supplementation of the record, and accordingly a greater showing is demanded of the plaintiff." Wilderness Society v. Griles, 262 U.S. App. D.C. 277, 824 F.2d 4, 16 (D.C. Cir. 1987).
The case law exploring the application of the distinction between a motion to dismiss and a motion for summary judgment in a challenge to standing has its most recent genesis in United States v. SCRAP, 412 U.S. 669, 37 L. Ed. 2d 254, 93 S. Ct. 2405 (1973). In that case, which has since been recognized as the Court's most expansive application of the standing doctrine in the realm of environmental challenges, the Court noted that the challenge to plaintiff's standing had been raised in a motion to dismiss and that, although the allegations were sufficient to survive at that stage, upon a motion for summary judgment, plaintiff might have to show injury with greater specificity. Id. at 689-90 n.15. See also Gwaltney of Smithfield, Ltd. v. Chesapeake Bay Foundation, Inc., 484 U.S. 49, 108 S. Ct. 376, 385-86, 98 L. Ed. 2d 306 (1987). The Court has subsequently observed that SCRAP might indeed have turned out differently had it been before the Court upon a motion for summary judgment. Simon v. Eastern Kentucky Welfare Rights Organization, 426 U.S. 26, 45 n.25, 48 L. Ed. 2d 450, 96 S. Ct. 1917 (1976).
Standing doctrine involves both limitations imposed by the "case or controversy" requirement of Article III of the Constitution and certain "prudential considerations." Valley Forge Christian College v. Americans United for Separation of Church and State, 454 U.S. 464, 471, 70 L. Ed. 2d 700, 102 S. Ct. 752 (1982). The test for standing is a familiar one. The party invoking a federal court's jurisdiction must demonstrate (1) "some actual or threatened injury" that (2) "fairly can be traced to the challenged action" and (3) "is likely to be redressed by a favorable decision." Id. at 472. Prudential considerations require that a plaintiff assert his or her own specific legal interests, rather than that of a third party, and that the plaintiff's complaint "fall within 'the zone of interests to be protected or regulated by the statute or constitutional guarantee in question.'" Id. at 475 (quoting Association of Data Processing Service Organizations v. Camp, 397 U.S. 150, 153, 25 L. Ed. 2d 184, 90 S. Ct. 827 (1970)).
As this circuit has observed, "standing jurisprudence is a highly case specific endeavor" which turns on the specific allegations of the parties. National Wildlife Federation v. Hodel, 268 U.S. App. D.C. 15, 839 F.2d 694, 703-04 (D.C. Cir. 1988). In the present case, plaintiffs have alleged injury arising out of (1) defendants' continued reliance in certain instances upon the MFP land use plans; (2) the failure of the 1982 and 1986 regulations to include reclaimability in the initial land use planning; (3) the decrease in opportunities for public input into the land use and coal lease planning process; (4) the application of "diligent development" requirements on the date of lease readjustments in pre August 4, 1976 leases; (5) inclusion of what defendants characterize as a "force majeure" provision which could extend the three year period within which operation and reclamation plans are due in the event of interruptions beyond the control of the lessee; (6) changes in the surface owner consent provisions under which a surface owner is presumed to be unqualified if the owner does not submit, or the Secretary cannot independently obtain, adequate proof of qualified status and which make a surface owner's refusal to consent controlling only for the activity planning cycle. In support of these claims of injury, plaintiffs have rested on the bare allegations in the complaint and upon one paragraph in a subsequent pleading which attempts to elucidate the nature of the injuries and the causal link to defendants' actions. The relevant paragraphs of the complaint state:
20. Plaintiff organizations sue on behalf of their members as well as themselves. Plaintiff organizations and their members are suffering and will continue to suffer injury in fact as a result of the challenged actions. Plaintiffs' members include residents, landowners and owners of lands overlying federal coal, who ranch, farm or are engaged in other businesses in areas where federal coal would be leased under the new leasing program. They also include visitors to these areas. These persons live, work and enjoy recreational and other resources of these areas that will be directly and indirectly affected by the actions challenged in this case. Excessive leasing and subsequent mining of federal coal in these areas threaten these persons with destruction or dimunition of the utility of land for commercial, industrial, agricultural and forestry purposes; increased erosion, landslides, subsidence and floods; pollution of water and air; appropriation of scarce water; destruction of fish and wildlife habitat; impairment of natural beauty; loss of recreational opportunities; damage to the property of citizens; creation of hazards dangerous to life and property; degradation of the quality of life in local communities; vastly increased populations and urbanization; and increases in local taxes and costs of doing business.