The Secretary of the Department of Interior (defendant) delegated activities concerning the withdrawal of federal lands from research development to the Bureau of Land Management (BLM). The National Wildlife Federation (NWF) (plaintiff) challenged BLM’s implementation of its “land withdrawal review program” on the grounds that it violated the Federal Land Policy and Management Act and the National Environmental Policy Act. To establish its standing to pursue the litigation, NWF submitted multiple affidavits from its members. Four of these affidavits alleged standing on the ground that the “land withdrawal review program” itself harmed the individual members. The United States Supreme Court granted certiorari.