Full opinion text
MEMORANDUM OPINION ' JAMES E. BOASBERG, District Judge. The Export-Import Bank of the United States has long been in the business of issuing loan guarantees to support foreign airlines’ purchases of aircraft from domestic manufacturers. While the Bank’s involvement in the air-travel industry undoubtedly serves the interests of U.S. aircraft manufactures, those interests do. not necessarily align with the interests of U.S. airlines and their employees. The manufacturers appreciate the help in selling their -planes to foreign buyers, but the airlines resent the boost this provides to their competitors. When in 2011 the Bank approved a series of guarantees to support Air India’s purchase of planes from Boeing, organizations representing some of those domestic airlines and their employees brought this suit. These Plaintiffs claim that the manner in which the Bank processes loan-guarantee applications from foreign airlines is inconsistent with its obligations under the Export-Import Bank Act. In particular, they maintain that the Bank violated both the Bank Act and the Administrative Procedure Act when it approved the 2011 Air India guarantees. Back in January, the Court rejected Plaintiffs’ Motion for Preliminary Injunction because they had failed to demonstrate that they would suffer irreparable harm during the pendency of this suit. Both sides have now filed dispositive motions. In resolving them, the Court must tackle important and difficult questions about constitutional standing, the role of the courts vis-á-vis the Export-Import Bank, and the nature of the Bank’s obligations under the Bank Act. In the end, it finds that Plaintiffs have established standing and that the Bank’s loan-guarantee determinations are, at least in a limited sense, subject to judicial review. But after winning these battles, Plaintiffs lose the war. When all. is said and done, the Bank’s decision to approve the Air India Commitments was neither, arbitrary and capricious nor contrary to law. Summary judgment will thus be entered in Defendants’ favor. I. Background A. The Export-Import Bank The Export-Import Bank of the United States is an indepehdent' federal agency and corporation that has its origins in a 1934 Executive Order issued by then-President Franklin Roosevelt. See Exec. Order No. 6581 (Feb. 2, 1934). The Bank assumed its current form with the passage of the Export-Import Bank Act of 1945 (Bank Act), ch. 341, 59 Stat. 526, which, as amended and codified at 12 U.S.C. § 635 et seq., remains the Bank’s governing charter. That statute provides that “[t]he objects and purposes of the Bank shall be to aid in financing and to facilitate exports of goods and services, imports, and the exchangé of commodities and services between the United States ... and any foreign country ..., and in so doing to contribute to the employment of United States workers.” 12 U.S.C. § 635(a)(1). Consistent with these goals, the Bank is empowered “to provide guarantees, insurance, and extensions of credit.” Id. § 635(b)(1)(A). Loans and guarantees issued by the Bank carry the full faith and credit of the United States government. Id. § 635k. In order to carry out its business, the Bank is required to maintain a Board of Directors, which must consist of the Bank’s President, its Vice President; and three additional persons. See id. § 635a(c). A company seeking Bank financing may apply to the Board for approval of either a preliminary or a final commitment. See Defs.’ Mot., Exh. H (Third Deck of Robert Morin), ¶¶26, 29. If a majority of the Board’s members so votes, an application for a preliminary commitment is approved. See Bylaws of the ExporNImport Bank of the United States, art. I, § 5 (effective Aug. 20, 1998), available at http://www.exim.gov/about/ bylaws/index.cfm. Obtaining a preliminary commitment allows a company to engage in long-term planning, and preliminary commitments may be converted into final commitments by another majority vote of the Board. Third Morin Deck, ¶¶ 31, 33. New commitments of more than $100 million require an additional step: they can be finalized only after Congress has been given the opportunity to review and comment on the transaction. 12 U.S.C. § 635(b)(3); see also Third Morin Deck, ¶ 34. In deciding whether to approve an application for a financial commitment, the Board must consider both the financial wisdom of the loan or guarantee, as well as its impact on U.S. industry and employment. See generally 12 U.S.C. § 635 et seq. ' For example, the statute provides that the Bank shall only make loans that, “in the judgment of the Board of Directors, offer reasonable assurance of repayment.” Id. § 635(b)(1)(B); see also id. § 635j(a). And, more relevant to the instant dispute, it specifies that the Bank must “take into account any serious adverse effect of such loan or guarantee on the competitive position of United States industry ... and employment ... and shall give particular emphasis to the objective of strengthening the competitive position of United States exporters and thereby of expanding total United States exports.” Id. § 635(b)(1)(B). These are not the only limitations the Bank Act places on the Bank’s operations, nor are they the only provisions at issue in this suit. In analyzing Plaintiffs’ claims the Court will individually discuss each portion of the statute on which those claims rely, but, at this juncture, it is sufficient to say that various provisions of the statute require the Bank to consider the ways in which its transactions affect domestic industry and employment. The Bank’s “means for complying with these statutory obligations are its ‘Economic Impact Procedures’ ” (EIPs). ATA & Delta’s Am. Compk, ¶ 64; ALPA’s Compl., ¶ 60; see Export-Import Bank of the United States Economic Impact Procedures (Apr.2007), available at http://www. exim.gov/products/policies/econ_impact_ proc4-07.pdf. The EIPs are comprised of a series of five “screens” that aim to identify the “potential economic impact” of prospective commitments. See EIPs at 1; ATA & Delta’s Am. Compl., ¶ 65; ALPA’s Compl., ¶ 61. The “Ex-Im Bank reviews all transactions it receives” for such impact by applying these screens. EIPs at 1. Only those transactions that are not exempted by any of the five screens are put “through a more extensive process” to further explore their potential economic impact. Id. In other words, if a transaction is exempted by a screen, it need not undergo further economic-impact scrutiny. See id. At issue in this case is the. first of those screens, which qualifies a transaction for further scrutiny only “if the exports involved in [that] transaction will result in the production of an exportable good.” Id. It was the application of this screen that exempted the Air India Commitments and led to Plaintiffs’ claim of injury. B. The Air India Commitments Loans and loan guarantees that support domestic aircraft manufacturing comprise a substantial portion of the Bank’s transactions. See ATA & Delta’s Am. Compl., ¶ 29; ALPA’s Compl., ¶ 28. Such guarantees allow foreign airlines to obtain credit at lower interest rates, which in turn provides them with an incentive to purchase American planes instead of planes manufactured abroad. See ATA & Delta’s Am. Compl., ¶¶ 25, 53-54; ALPA’s Compl., ¶¶ 24, 51-52. This benefits American manufacturers by providing additional buyers for their wares. To give a sense of the scale of the Bank’s involvement in financing foreign airlines’ purchase of domestic aircraft, between 2005 and 2010 the Bank “financed or guaranteed the financing for purchases by foreign airlines of 634 aircraft, adding up to more than $34.5 billion.” ATA & Delta’s Am. Compl., ¶ 29; ALPA’s Compl., ¶ 28. Plaintiffs contend that these transactions have caused them competitive injury. See ATA & Delta’s Ain. Compl., ¶¶ 52-61, 77-101; ALPA’s Compl., ¶¶ 50-58, 73-97. As direct competitors of Air India, ATA’s members, including Delta, claim that the benefits the Bank’s practices have conferred on foreign airlines have put them at a competitive disadvantage and caused them direct financial harm. See ATA & Delta’s Am. Compl., ¶¶ 52-61, 77-101. The financial injuries incurred by the airlines, furthermore, have also been felt by the airlines’ employees, including the pilots that the Air Line Pilots Association (ALPA) represents. See ATA & Delta’s Am. Compl., ¶¶ 67-76; ALPA’s Compl., ¶¶ 64-72. Plaintiffs contend that “[t]he Ex-Im Bank’s subsidies to foreign carriers have forced U.S. airlines to cut between 4,100 and 7,500 jobs.” ATA & Delta’s Am. Compl., ¶ 69; see ALPA’s Compl., ¶ 66. At particular issue in this suit are $3.4 billion in preliminary and final commitments approved by the Board on September 30, 2011. See ATA & Delta’s First Am. Compl., ¶ 30; Administrative Record (A.R.) at 29-30. The $1.3 billion- in final commitments were conversions of preliminary commitments originally approved in 2006 and intended to support Air India’s purchase of Boeing 787 aircraft. See A.R. at 31. • The remaining $2.1 billion in preliminary commitments will support the airline’s acquisition of Boeing 787 and 777-300ER planes. See id. These are “wide-body,” “medium-sized aircraft (200 to 300 seats) with a range (7,500 nautical miles to 8,500 nautical miles) that previously has only been available with much larger aircraft.” Id. at 67. C. The Current Action Plaintiff ATA is a trade organization, headquartered in Washington, D.C., that represents United States airlines. See ATA & Delta’s First Am. Compl., ¶ 11. ATA’s members include AirTran Airways; Alaska Airlines, Inc.; ASTAR Air Cargo, Inc.; Delta Air Lines, Inc.; Evergreen International Airlines, Inc.; Hawaiian Airlines; JetBlue Airways Corp.; Southwest Airlines Co.; U.S. Airways, Inc.; United Air Lines, Inc.; Continental Airlines, Inc.; American Airlines, Inc.; Atlas Air, Inc.; Federal Express Corp.; and United Parcel Service Co. Id., ¶ 11 n. *. ATA “work[s] with its members in legal, political, and regulatory arenas to foster a business and regulatory environment that promotes a safe, secure, and financially successful U.S. airline industry.” Id., ¶ 11. ATA filed its Complaint on behalf of nine of its member airlines. See id., ¶ 11 n. *. Six of those members, United, Continental, American, Atlas Air, FedEx, and United Parcel Service, declined to join the suit. Id. One of those members, Delta, joined the Complaint as an individual Plaintiff. “Delta is a domestic air carrier” that “competes with Air India for passengers traveling to and from international destinations.” Id., ¶ 12. Plaintiff-Intervenor ALPA is an unincorporated labor organization, also based in Washington, D.C., that represents “approximately 47,000 pilots employed by 28 United States commercial airlines.” ALPA’s Compl., ¶ 11. ALPA’s members include pilots that work for airlines that provide “significant international services!,] • • • including Alaska, Continental, Delta, FedEx, Hawaiian, and United.” Id. ALPA’s Complaint is nearly identical to that filed by ATA and Delta. Both Complaints charge the Bank and senior Bank officials with violating the APA by acting arbitrarily and capriciously and violating various provisions of the Bank Act. Plaintiffs’ claims fall generally into three categories. First, Plaintiffs allege that Defendants violated 12 U.S.C. §§ 635(b)(1)(B) and 635a-2 by “approving the Air India Commitments without considering the extent to which they are likely to have an adverse effect on the domestic airline industry” and on “domestic employment.” ATA & Delta’s Am. Compl., ¶ 103; ALPA’s Compl., ¶ 99. Second, they contend that the Bank violated § 635(e)(1) when it “approved the Air India Commitments without considering whether they cause a substantial injury to the domestic airline industry.” ATA & Delta’s Am. Compl., ¶ 109; see ALPA’s Compl., ¶ 105. Third, Plaintiffs claim that the Bank violated § 635(e)(7) by approving the Air India Commitments “without providing notice, soliciting comment, and providing a reasoned explanation for its decision.” ATA & Delta’s Am. Compl., ¶ 112; ALPA’s Compl., ¶ 108. Plaintiffs argue both that these violations occurred with respect to the Air India Commitments specifically and that the Bank’s policies regarding foreign-airline transactions generally conflict with the Bank Act and the APA. Along with their initial Complaint, ATA and Delta filed a Motion for Temporary Restraining Order and Motion for Preliminary Injunction, both of which claimed that expeditious relief was required due to the impending delivery of aircraft from Boeing to Air India. See Mot. for TRO & PI at 3. On November 16, 2011, Chief Judge Royce Lamberth denied the Motion for TRO because, “[i]n absence of the administrative record relied upon by the defendant Export-Import Bank in approving the loan guarantees at issue, the Court cannot satisfy itself that plaintiff has shown a [sufficient] likelihood of success of the merits.” Air Transp. Assoc. of America, Inc. v. Export-Import Bank of the United States, No. 11-2024 (D.D.C. Nov. 16, 2011) (order denying temporary restraining order). Chief Judge Lamberth ordered Defendants to file the administrative record with the Court, id., and Defendants did so on November 29, 2011. Following briefing and a hearing, this Court denied Plaintiffs’ Motion for Preliminary Injunction on January 13, 2012, primarily on the ground that Plaintiffs had failed to “demonstrate[ ] a likelihood that they will suffer irreparable harm during the pendency of the lawsuit in the absence of an injunction.” See Air Transp. Assoc. of America, Inc. v. Export-Import Bank of the United States., 840 F.Supp.2d 327, 329-30 (D.D.C.2012).' Plaintiffs have now filed Motions for Summary Judgment, and Defendants have filed a Motion to Dismiss or for Summary Judgment. It is to the resolution of these Motions that the Court now turns. II. Legal Standard Whereas Plaintiffs’ Motions are for summary judgment only, Defendants’ Motion seeks both dismissal and, in the alternative, summary judgment. Taken together, the three motions are brought pursuant to three different Federal Rules of Civil Procedure and thus implicate three, distinct standards of review. Defendants’ argument that Plaintiffs lack standing will be adjudicated under the standard applicable to Rule 12(b)(1) motions to dismiss for lack of subject-matter jurisdiction. Defendants’ argument that Plaintiffs’ claims are not justiciable under the APA’s “committed to agency discretion” exception, conversely, will be resolved in accordance with Rule 12(b)(6). Finally, both parties’ seek summary judgment on the merits, which will be adjudicated consistent with the summary-judgment and APA standards enumerated in Part II.B, infra. A. Motion to Dismiss In evaluating Defendants’ Motion to Dismiss, the Court must “treat the [C]omplaint[s’] factual allegations as true ... and must grant [P]laintiff[s] ‘the benefit of all inferences that can be derived from the facts alleged.’ ” Sparrow v. United Air Lines, Inc., 216 F.3d 1111, 1113 (D.C.Cir.2000) (quoting Schuler v. United States, 617 F.2d 605, 608 (D.C.Cir.1979)) (internal citation omitted); see also Jerome Stevens Pharms., Inc. v. FDA, 402 F.3d 1249, 1253-54 (D.C.Cir.2005). This standard governs the Court’s considerations of Defendants’ Motion under both Rules 12(b)(1) and 12(b)(6).' See Scheuer v. Rhodes, 416 U.S. 232, 236, 94 S.Ct. 1683, 40 L.Ed.2d 90 (1974) (“in passing on a motion to dismiss, whether on the ground of lack of jurisdiction over the subject matter or for failure to state a cause of action, the allegations of the complaint should be construed favorably to the pleader”); Walker v. Jones, 733 F.2d 923, 925-26 (D.C.Cir.1984) (same). The Court need not accept as true, however, “a legal conclusion couched as a factual allegation,” nor an inference unsupported by the facts set forth in the Complaint. Trudeau v. Fed. Trade Comm’n, 456 F.3d 178, 193 (D.C.Cir.2006) (quoting Papasan v. Allain, 478 U.S. 265, 286, 106 S.Ct. 2932, 92 L.Ed.2d 209 (1986)) (internal quotation marks omitted). Federal Rule of Civil Procedure 12(b)(6) provides for the dismissal of an action where a complaint “fail[s] to state a claim upon which relief can be granted.” Although the notice pleading rules are “not meant to impose a great burden on a plaintiff,” Dura Pharm., Inc. v. Broudo, 544 U.S. 336, 347, 125 S.Ct. 1627, 161 L.Ed.2d 577 (2005), and “detailed factual allegations” are not necessary to withstand a Rule 12(b)(6) motion, Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555, 127 S.Ct. 1955, 167 L.Ed.2d 929 (2007), “a complaint must contain sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face.” Ashcroft v. Iqbal, 556 U.S. 662, 678, 129 S.Ct. 1937, 173 L.Ed.2d 868 (2009) (internal quotation omitted). Plaintiffs must put forth “factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id. Though Plaintiffs may survive a 12(b)(6) motion even if “recovery is very remote and unlikely,” Twombly, 550 U.S. at 565, 127 S.Ct. 1955 (citing Scheuer v. Rhodes, 416 U.S. 232, 236, 94 S.Ct. 1683, 40 L.Ed.2d 90 (1974)), the facts alleged in their Complaints “must be enough to raise a right to relief above the speculative level.” Id. at 555,127 S.Ct. 1955. To survive a motion to dismiss under Rule 12(b)(1), Plaintiffs bear the burden of proving that the Court has subject-matter jurisdiction to hear their claims. See Lujan v. Defenders of Wildlife, 504 U.S. 555, 561, 112 S.Ct. 2130, 119 L.Ed.2d 351 (1992); U.S. Ecology, Inc. v. U.S. Dep’t of Interior, 231 F.3d 20, 24 (D.C.Cir.2000). A court has an “affirmative obligation to ensure that it is acting within the scope of its jurisdictional authority.” Grand Lodge of Fraternal Order of Police v. Ashcroft, 185 F.Supp.2d 9, 13 (D.D.C.2001). “For this reason ‘the [p]laintiff s factual allegations in the complaint ... will bear closer scrutiny in resolving a 12(b)(1) motion’ than in resolving a 12(b)(6) motion for failure to state a claim.” Id. at 13-14 (quoting 5A Charles A. Wright & Arthur R. Miller, Federal Practice and Procedure § 1350 (2d ed.1987) (alteration in original)). Additionally, unlike with a motion to dismiss under Rule 12(b)(6), the Court “may consider materials outside the pleadings in deciding whether to grant a motion to dismiss for lack of jurisdiction.” Jerome Stevens, 402 F.3d at 1253; see also Venetian Casino Resort, LLC v. EEOC, 409 F.3d 359, 366 (D.C.Cir.2005) (“given the present posture of this case — a dismissal under Rule 12(b)(1) on ripeness grounds — the court may consider materials outside the pleadings”); Herbert v. Nat’l Acad. of Sciences, 974 F.2d 192,197 (D.C.Cir.1992). B. Motion for Summary Judgment Summary judgment may be granted “if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” Fed.R.Civ.P. 56(a); see also Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 247-48, 106 S.Ct. 2505, 91 L.Ed.2d 202 (1986); Holcomb v. Powell, 433 F.3d 889, 895 (D.C.Cir.2006). A fact is “material” if it is capable of affecting the substantive outcome of the litigation. Holcomb, 433 F.3d at 895; Liberty Lobby, Inc., 477 U.S. at 248, 106 S.Ct. 2505. A dispute is “genuine” if the evidence is such that a reasonable jury could return a verdict for the nonmoving party. See Scott v. Harris, 550 U.S. 372, 380, 127 S.Ct. 1769, 167 L.Ed.2d 686 (2007); Liberty Lobby, Inc., 477 U.S. at 248, 106 S.Ct. 2505; Holcomb, 433 F.3d at 895. Although styled as Motions for Summary Judgment, the pleadings in this case more accurately seek the Court’s review of an administrative decision. The standard set forth in Rule 56(c), therefore, does not apply because of the limited role of a court- in reviewing the administrative record. See Sierra Club v. Mainella, 459 F.Supp.2d 76, 89-90 (D.D.C.2006) (citing National Wilderness Inst. v. United States Army Corps of Eng’rs, 2005 WL 691775, at *7 (D.D.C.2005); Fund for Animals v. Babbitt, 903 F.Supp. 96, 105 (D.D.C.1995), amended on other grounds, 967 F.Supp. 6 (D.D.C.1997)). “[T]he function of the district court is to determine whether or not as a matter of law the evidence in the administrative record permitted the agency to make the decision it did.” Sierra Club, 459 F.Supp.2d at 90 (quoting Occidental Eng’g Co. v. INS, 753 F.2d 766, 769-70 (9th Cir.1985)) (internal quotation marks omitted). Summary judgment thus serves as the mechanism for deciding, as a matter of law, whether the agency, action is supported by the administrative record and otherwise consistent with the APA standard of review. See Richards v. INS, 554 F.2d 1173, 1177 (D.C.Cir.1977), cited in Bloch v. Powell, 227 F.Supp.2d 25, 31 (D.D.C.2002), aff'd, 348 F.3d 1060 (D.C.Cir.2003). The Administrative Procedure Act “sets forth the full extent of judicial authority to review executive agency action for procedural correctness.” FCC v. Fox Television Stations, Inc., 556 U.S. 502, 513, 129 S.Ct. 1800, 173 L.Ed.2d 738 (2009). It requires courts to “hold unlawful and set aside agency action, findings, and conclusions” that are “arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law.” 5 U.S.C. § 706(2)(A). This is a “narrow” standard of review as courts defer to the agency’s expertise. Motor Vehicle Mfrs. Ass’n of U.S., Inc. v. State Farm Mut. Auto. Ins. Co., 463 U.S. 29, 43, 103 S.Ct. 2856, 77 L.Ed.2d 443 (1983). An agency is required to “examine the relevant data and articulate a satisfactory explanation for its action including a rational connection between the facts found and the choice made.” Id. (internal quotation omitted). The reviewing court “is not to substitute its judgment for that of the agency,” id., and thus “may not supply a reasoned basis for the agency’s action that the agency itself has not given.” Bowman Transp.; Inc. v. Arkansas-Best Freight Sys., Inc., 419 U.S. 281, 285-86, 95 S.Ct. 438, 42 L.Ed.2d 447 (1974). Nevertheless, a decision that is not fully explained may be upheld “if the agency’s path may .reasonably be discerned.” Id. at 286, 95 S.Ct. 438. III. Analysis Plaintiffs claim that the Ex-Im Bank and its officers violated various provisions of the Bank Act and, by extension, the APA when they approved the 2011 Commitments to Ar India. But Defendants correctly point out that before the Court can reach the merits of Plaintiffs’ claims, it must first ensure that it has jurisdiction to decide them. See, e.g., Dominguez v. UAL Corp., 666 F.3d 1359, 1362 (D.C.Cir.2012) (“[E]very federal court has a ‘special obligation to satisfy itself of its own jurisdiction before addressing the merits of any dispute.”) (quoting Bender v. Williamsport Area Sch. Dist., 475 U.S. 534, 541, 106 S.Ct. 1326, 89 L.Ed.2d 501 (1986)). The Court’s analysis will thus begin with the question of Plaintiffs’ standing, which the Court has previously recognized raises “serious questions.” ATA 840 F.Supp.2d at 329. Ultimately concluding that Plaintiffs do have constitutional and prudential standing to pursue their claims, the Court will next address another potential obstacle to its review of the merits: Defendants’ contention that the Bank’s loan-guarantee determinations are “committed to agency discretion,” 5 U.S.C. § 701(a)(2), and thus not subject to judicial review. Again, it finds that Plaintiffs have the better of the argument. While the Court’s role in reviewing the Bank’s decision is undoubtedly limited, loan-guarantee determinations are not entirely committed to the Bank’s discretion, and the Court thus has some part to play in ensuring the Bank abides by the limitations that Congress has set forth. Having cleared away those significant threshold questions, the Court will then reach the merits of Plaintiffs’ allegations. In the end, it determines that the Bank acted neither arbitrarily and capriciously nor contrary to its governing statute when it approved the 2011 Commitments to Air ■India. A. Standing Article III of the Constitution limits the power of the federal judiciary to the resolution of “Cases” and “Controversies.” U.S. Const, art. Ill, § 2; see also Allen v. Wright, 468 U.S. 737, 750, 104 S.Ct. 3315, 82 L.Ed.2d 556 (1984) (discussing the case- or-controversy requirement). “This limitation is no mere formality: it ‘defines with respect to the Judicial Branch the idea of separation of powers on which the Federal Government is founded.’ ” Dominguez, 666 F.3d at 1361 (quoting Allen, 468 U.S. at 750, 104 S.Ct. 3315). Because “standing is an essential and unchanging part of the case-or-controversy requirement of Article III,” Lujan v. Defenders of Wildlife, 504 U.S. 555, 560, 112 S.Ct. 2130, 119 L.Ed.2d 351 (1992), finding that a plaintiff has standing is a necessary “predicate to any exercise of [the Court’s] jurisdiction.” Fla. Audubon Soc’y v. Bentsen, 94 F.3d 658, 663 (D.C.Cir.1996). “Every plaintiff in federal court,” consequently, “bears the burden of establishing the three elements that make up the ‘irreducible constitutional minimum’ of Article III standing: injury-in-fact, causation, ■ and redressability.” Dominguez, 666 F.3d at 1362 (quoting Lujan, 504 U.S. at 560-61, 112 S.Ct. 2130). Taken together, these elements require a plaintiff to demonstrate the existence of a “personal injury fairly traceable to the [opposing party’s] allegedly unlawful conduct and likely to be redressed by the requested relief.” Allen, 468 U.S. at 751, 104 S.Ct. 3315. In addition to the constitutionally derived test for standing, Plaintiffs must also satisfy “the judicially created zone-of-interests test for standing.” Patchak v. Salazar, 632 F.3d 702, 704 (D.C.Cir.2011). This latter test, which was originally characterized as a “gloss” on: § 702 of the Administrative Procedure Act, see Clarke v. Secs. Indus. Ass’n, 479 U.S. 388, 395-96, 107 S.Ct. 750, 93 L.Ed.2d 757 (1987) (interpreting 5 U.S.C. § 702), requires a plaintiff to demonstrate that its suit seeks to protect an interest that is “arguably within the zone of interests to be protected” by the relevant statutory provisions. See Nat'l Credit Union Admin. v. First Nat’l Bank & Trust Co., 522 U.S. 479, 492, 118 S.Ct. 927, 140 L.Ed.2d 1 (1998) (quoting Assoc. of Data Processing Serv. Orgs., Inc. v. Camp, 397 U.S. 150, 153, 90 S.Ct. 827, 25 L.Ed.2d 184 (1970)) (emphasis in original). All three Plaintiffs — ATA, Delta, and ALPA — bring substantively identical claims in nearly identical language. Compare ATA & Delta’s First Am. Compl., ¶¶ 102-25, with ALPA’s Compl., ¶¶ 98-121. Where multiple plaintiffs bring the same claims, the Court need only ensure that one of those plaintiffs has standing to pursue them. See Mountain States Legal Found. v. Glickman, 92 F.3d 1228, 1232 (D.C.Cir.1996) (“[I]f constitutional and prudential standing can be shown for at least one plaintiff, we need not consider the standing' of the other plaintiffs to raise that claim.”). Because Delta is one of ATA’s members and any injury accruing to ALPA’s pilots derives from the airlines’ injury, ATA is best positioned to demonstrate standing. If any of these Plaintiffs have standing, in other words, it will be ATA. As an association, ATA has standing to challenge the Ex-Im Bank’s decision if three conditions are met: 1) at least one of its members would have standing to sue; 2) the interests the organization seeks to protect are germane to its purpose; and 3) neither the claim nor the requested relief requires its - individual members’ participation. See Hunt v. Washington State Apple Adver. Comm’n, 432 U.S. 333, 343, 97 S.Ct. 2434, 53 L.Ed.2d 383 (1977); United Food and Commercial Workers Union Local 751 v. Brown Group, Inc., 517 U.S. 544, 552-55, 116 S.Ct. 1529, 134 L.Ed.2d 758 (1996). It is undisputed that ATA satisfies the second and third elements of this test. As “the principal trade association representing scheduled airlines in the United States,” “ATA’s purposes include working with its members in legal, political, and regulatory arenas to foster a business and regulatory environment that promotes a safe, secure, and financially successful U.S. airline industry.” ATA & Delta’s First. Am. Compl., ¶ 11. Because this suit is brought to protect domestic airlines’ financial interests, it clearly implicates interests germane to ATA’s purpose. And as ATA’s claims concern the interests of domestic airlines generally and declaratory and injunctive relief — not money damages — are the remedies sought, see id. at 26-27, the Court conceives of no reason why the participation of ATA’s individual members should be required. Cf. Warth v. Seldin, 422 U.S. 490, 515-16, 95 S.Ct. 2197, 45 L.Ed.2d 343 (1975) (where association seeks “prospective relief,” courts assume remedy “will inure to the benefit of those members ... actually injured,” and, accordingly, individual participation not required). The first prong — whether ATA’s members would have standing to sue in their own right — is thus all that remains. To proceed, then, ATA must demonstrate that at least one of its members would satisfy both the constitutional and the prudential tests for standing, see, e.g., Util. Air Regulatory Group v. EPA, 320 F.3d 272, 277 (D.C.Cir.2003), and the Court will address these two sets of requirements separately. Although “standing ... is ordinarily substantially more difficult to establish” where, as here, “the plaintiff is not himself the object of the government action ... he challenges,” Summers v. Earth Island Institute, 555 U.S. 488, 493, 129 S.Ct. 1142, 173 L.Ed.2d 1 (2009) (quoting Lujan, 504 U.S. at 562, 112 S.Ct. 2130) (internal quotation marks omitted), the Court ultimately concludes that ATA has constitutional and prudential standing to challenge the Ex-Im Bank’s 2011 Commitments to Air India. 1. Constitutional Standing To repeat, to establish constitutional standing ATA’s members must satisfy three requirements: injury in fact, causation, and redressability. The Court will consider these in sequence. a. Injury in Fact To establish an “injury in fact,” ATA’s members must identify “an invasion of a legally protected interest which is (a) concrete and particularized, and (b) actual or imminent, not conjectural or hypothetical.” Lujan, 504 U.S. at 560, 112 S.Ct. 2130 (internal citations and quotations omitted). It is well established in this Circuit that “economic actors ‘suffer [an] injury in fact when agencies lift regulatory restrictions on their competitors or otherwise allow increased competition’ against them.” Sherley v. Sebelius, 610 F.3d 69, 72 (D.C.Cir.2010) (quoting La. Energy & Power Auth. v. FERC, 141 F.3d 364, 367 (D.C.Cir.1998)) (alteration in original); see also New World Radio, Inc. v. FCC, 294 F.3d 164, 172 (D.C.Cir.2002) (“basic law of economics” that increased competition leads to actual injury). This so-called competitor-injury doctrine “recognizes probable economic injury resulting from [governmental actions] that alter competitive conditions as sufficient to satisfy the [Article III ‘injury-in-fact’ requirement].” Clinton v. City of New York, 524 U.S. 417, 433, 118 S.Ct. 2091, 141 L.Ed.2d 393 (1998) (quoting 3 K. Davis & R. Pierce, Administrative Law Treatise 13-14 (3d ed.1994)) (alterations in original). The D.C. Circuit’s “cases addressing competitor standing have articulated various formulations of the standard for determining whether a plaintiff asserting competitor standing has been injured.” Sherley, 610 F.3d.at 73. It ,is clear, though, that the injury-in-fact requirement may be satisfied before an injury from increased competition actually occurs. See id. at 72. “Because increased competition almost surely injures a seller in one form or another, he need not wait until ‘allegedly illegal transactions ... hurt [him] competitively’ before challenging the regulatory ... governmental decision that increases competition.” Id. (quoting La. Energy, 141 F.3d at 367) (alteration in original). So long as a plaintiff can demonstrate an “imminent increase in competition,” the court recognizes that that “increase ... will almost certainly cause an injury in fact.” Id. at 73. It is crucial, however, that the increase in competition and corresponding injury be^ “imminent,” not merely “speculative.” Compare La. Energy, 141 F.3d at 367 (finding competitor standing where injury was “imminent”), and Sherley, 610 F.3d at 73-74 (same), with DEK Energy Co. v. FERC, 248 F.3d 1192, 1196 (D.C.Cir.2001) (no competitor standing where only “some vague probability” of increased ■ competition and “a still lower probability” of injury stemming from that competition). Put differently, to demonstrate a constitutionally sufficient competitive injury, a plaintiff must show that the challenged action has “the clear and immediate potential” to cause competitive harm. Associated Gas Distribs. v. FERC, 899 F.2d 1250, 1259 (D.C.Cir.1990); see also New England Pub. Comm. Council, Inc. v. FCC, 334 F.3d 69, 74 (D.C.Cir.2003). In general terms, ATA maintains that the Bank’s allegedly unlawful loan guarantees to foreign airlines have injured its members in the past and that the 2011 Commitments will cause additional and imminent injury. More specifically, Plaintiffs contend that the Bank’s acts have had — and, with respect to the 2011 Commitments, will imminently have — the effects of permitting foreign airlines to borrow at cheaper rates and operate at lower costs than domestic airlines and of increasing competition in the market for air travel on certain international routes. See generally Exhibits cited in ATA & Delta’s Mot. at 14 and in ATA & Delta’s Opp. & Reply at 8-9. This increased competition, ATA further argues, will cut its members’ profits, force them to abandon particular routes, or prevent them from initiating service on those routes, any of which would in turn cause economic loss and compel the airlines to eliminate jobs or refrain from hiring. To support these contentions, Plaintiffs have provided declarations from experts and industry participants demonstrating both that previous guarantees made by the Ex-Im Bank to Air India and other foreign airlines have injured Delta and ATA’s other members, see generally, e.g., ATA & Delta’s Am. Compl., Exh. B (Decl. of Richard Anderson), and that the 2011 Commitments to Air India in particular will cause imminent competitive injury. See, e.g., id., Exh. D (Decl. of Daniel Kasper) at D-5 to D-6. Evidence submitted concerning the effects of prior Ex-Im guarantees includes declarations by Delta’s Chief Executive Officer and its Senior Vice President of Finance/Treasurer, which explain how the Bank’s financing of foreign airlines’ aircraft purchases allows foreign airlines to borrow at better terms than Delta and other domestic airlines and gives foreign airlines access to a larger pool of credit than that available to ATA’s members. See Decl. of Richard Anderson, ¶¶ 15-24; see generally ATA & Delta’s First Am. Compl., Exh. C (Decl. of Paul Jacobson). Plaintiffs also rely in particular on the declaration of Daniel Kasper, an expert on “issues involving economics, finance, competition, and competition policy in the aviation and aerospace industries,” Kasper Decl. at D-l, who speaks generally to the important role played by the Ex-Im Bank’s guarantees in financing foreign airlines’ purchases of aircraft. See id. at D-4 to D-12. In addition, Kasper explains that many of the foreign airlines’ Bank-financed aircraft have been deployed in direct competition with U.S. airlines, and he provides estimates of the total losses to U.S. airlines attributable to financing extended by the Ex-Im Bank to foreign airlines. See id. at D-6. With respect to past guarantees made to Air India specifically, one declarant from Delta states that :Air India used Bank-financed aircraft to start a nonstop service between Mumbai and New York that directly competed with Delta’s pre-existing service. See Anderson Decl., ¶¶ 25-32. Because of the resulting increased capacity on that route, operating the New York-Mumbai service became cost-prohibitive, and Delta was forced to discontinue that service in October 2008. See id. at 30. While Defendants are likely correct that all of the economic hardships faced by ATA’s members in recent years cannot be laid at the feet of the Ex-Im Bank, see Defs.’ Mot. & Opp. at 2-3, the evidence submitted by Plaintiffs decisively establishes what seems a matter of common sense: the loan guarantees provided by the Ex-Im Bank to foreign airlines, in the aggregate, have injured ATA’s members. But Plaintiffs are not challenging the Bank’s prior guarantees; instead, this suit is directed in particular at the 2011 Commitments to Air India. It is the sufficiency of Plaintiffs’ showing of imminent injury with respect to those guarantees, accordingly, that Defendants primarily dispute. And while Plaintiffs’ showing that prior Bank guarantees have injured ATA’s members provides some support for their argument that this guarantee will imminently cause them injury, see Canadian Lumber Trade Alliance v. U.S., 517 F.3d 1319, 1334 (Fed.Cir.2008) (“rational to infer that ... distribution] of money to an entity that aims to take away market share from [the plaintiff] and has already been somewhat successful in that effort ... is likely to inflict further economic injury on [the plaintiff]”), it does not get them all the way there. See City of Los Angeles v. Lyons, 461 U.S. 95, 103, 103 S.Ct. 1660, 75 L.Ed.2d 675 (1983) (“[P]ast wrongs do not in themselves amount to that real and immediate threat of injury necessary to make out a case or controversy.”). The Court must thus direct its attention to the injury that is directly attributable to the 2011 Air India Commitments. Although no party has submitted anything to suggest that the 787s purchased by Air India with the help of the' Bank’s financing have yet been put in the air, Plaintiffs have proffered evidence that seeks to demonstrate that the 2011 Commitments “will result in substantial injury to U.S. carriers.” Kasper Decl. at D-5. While it is not clear precisely how the injury will manifest — i.e., on which particular routes the subsidized planes will be put to use, or whether the increased competition will force ATA’s members out of the market on those routes, prevent them from entering the market on those routes, or simply cut into their profitability — the Court finds that Delta and ATA’s other member airlines “face a substantial enough probability [of injury] to deem the injury to them imminent.” Sherley, 610 F.3d at 74. If the form of the injury remains speculative insomuch as Air India might deploy its new planes on any of several routes and ATA’s members may respond to the increased competition in any number of ways, the fact of imminent injury is not. Cf id. at 72 (“The form of that injury may vary; for example, a seller facing increased competition may lose sales to rivals, or be forced to lower its price or to expend more resources to achieve the same sales, all to the detriment of its bottom line.”). ATA need not show that the particular planes financed by the 2011 Commitments will be put to use on routes on which ATA’s members currently compete in order to show a competitive injury. Irrespective of where the 787s are deployed, it appears beyond dispute that the addition of multiple 787s to Air India’s fleet will “significantly lower Air India’s overall cost structure, thus enabling the carrier to more aggressively price its non-stop and connecting services to the United States.” Pis.’ Opp. & Reply, Exh. A (Supp. Decl. of Daniel Kasper), ¶ 19; see also A.R. at 67 (“The operating costs and maintenance costs of the B787 are estimated to be 30% lower than those of comparable aircraft.”). The “new aircraft,” furthermore, “will free up other planes for the airline to expand service to North America” or on other non-stop or connecting routes where ATA’s members compete with Air India for customers. See ATA & Delta’s Am. Compk, Exh. E (Heimlich Deck), ¶ 35. That conferring such a benefit to one entity constitutes a constitutionally cognizable injury to that entity’s competitors was confirmed by then-judge Scalia in Sea-Land Serv., Inc. v. Dole, 723 F.2d 975 (D.C.Cir.1983). In Sea-Land, the D.C. Circuit held that a shipping company had standing to challenge a subsidy provided to one of its competitors “because it operates vessels upon some of the trade routes on which the [subsidized competitor’s] nonsubsidized operations may be conducted.” Id. at 977-78 (emphases added). Because boats are fungible, the court specifically noted that plaintiff did not have to show that its competitor would use the government subsidies on the particular routes on which the two shipping companies competed in order to demonstrate injury. See id. at 978. Rather, the mere fact of the government’s subsidy to the plaintiffs direct competitor was sufficient to confer standing. See id.; see also Auto-log Corp. v. Regan, 731 F.2d 25, 30-31 (D.C.Cir.1984) (finding injury even where plaintiff did not compete on particular route on which challenged agency action authorized increased competition). The Court conceives of and Defendants have identified no reason why planes of similar capacity and capability should not be considered as fungible as Sea-Land’s boats. See Sea-Land, 723 F.2d at 978. As a result, ATA need not show that the Bank-subsidized planes will be deployed on routes where ATA’s members compete. In any event, the new planes are very likely to compete directly with service provided by ATA’s members. Indeed, Plaintiffs’ expert and other industry participants have attested to their belief that at least some of the Bank-subsidized 787s are destined for U.S. routes. See, e.g., Supp. Kasper Deck, ¶ 5 (concluding that it is “highly likely that Air India would deploy a substantial proportion of its 787 capacity on routes to and from the United States”); Anderson Deck, ¶ 32; Heimlich Deck, ¶ 35. Specifically, Kasper opines that the 2011 Commitments to Air India are “almost certain to result in Air India increasing capacity to the United States by well over 1% of aggregate U.S. carrier capacity serving India.” Kasper Deck at D-5 to D-6. This increased capacity, he further explains, will cause significant economic losses to domestic airlines. See id., ¶¶ 19-20; cf. Panhandle Producers and Royalty Owners Assoc. v. Economic Reg. Admin., 822 F.2d 1105, 1108 (D.C.Cir.1987) (“Under undisputed economic principles, ... an increase in supply is likely to depress ... prices.”). Although the Court does not necessarily credit the precise calculations Kasper proffers, his testimony that at least some of the new aircraft are substantially likely to be used on U.S. routes appears reasonable and is consistent with the statements of Plaintiffs’ other declarants. See, e.g., Anderson Deck, ¶ 32; Heimlich Deck, ¶ 35. These losses, as another declaration makes clear, will accrue not merely to U.S. carriers generally, but to ATA’s members specifically. See Heimlich Deck, ¶¶ 30-35. Even putting aside the fact that two of ATA’s members that have declined to join this lawsuit currently compete directly with Air India’s existing nonstop United States-India service, see id., ¶¶ 31-33, additional competition on U.S.-India routes will make it more difficult (or perhaps impossible) for ATA’s other members to expand their offerings in that market. Indeed, Delta officials have stated not only that previous loan guarantees to Air India forced Delta to terminate its non-stop service between the United States and India, but also that the 2011 Commitments will “foreclose[] [Delta] from that- nonstop market for the foreseeable future.” Anderson Deck, ¶32. Should Air India deploy its new aircraft on routes between the United States and India, Anderson avers, it will become “economically impossible for Delta to reenter and compete.” Id. Consistent with the D.C. Circuit’s decision in U.S. Telecom Ass’n v. FCC, 295 F.3d 1326 (D.C.Cir.2002), evidence that a government action will prevent a plaintiff from entering a market and competing there can suffice to demonstrate competitive injury. See id. at 1331 (subsidy that foreclosed would-be competitor from entering market “on an equal basis” sufficient for injury). Even if Air India does not use the Bank-subsidized planes on U.S. routes, furthermore, Plaintiffs have provided evidence that ATA’s members will nevertheless face increased direct competition on other international routes. See Supp. Kasper Deck, ¶¶ 6-16. At least some of the new 787s, which are “widebody aircraft” particularly suitable for “long-haul routes,” Kasper Deck, ¶ 28, will likely be put to use on international routes originating in either New Delhi, Air India’s primary hub, or Mumbai, India’s business center. See Supp. Kasper Deck, ¶ 8 & n. 9. Because Air India currently offers nonstop service between the United States and those cities, any nonstop service provided from those cities to another international destination will result in a new one-stop service between the United States and that destination. See id., ¶ 9. “For example, because Air India already offers non-stop service from Delhi to both New York City and Bangkok, it is also able to offer connecting service for passengers wanting to travel between New York City and Bangkok.” Id. (emphasis in original). If Air India deploys its new planes on non-U.S. routes, the resulting connecting-service will compete with connecting service provided by ATA’s members. Kasper’s supplemental declaration explains in more detail how Air India’s use of the Bank-subsidized planes on various international routes will compete with service provided by ATA’s members. See id., ¶¶ 6-16. And although Defendants challenge Kasper’s estimates in various respects, it is clear that the new planes will cause a nontrivial increase in competition on international routes served by ATA’s members. ATA has thus not only demonstrated that its members will be competitively injured by the 2011 Commitments regardless of whether the new planes are put to use on routes on which its members compete directly, but it has also shown that additional direct competition on international routes is substantially certain. Acknowledging the “gulf between ... the ‘imminent’ injury that suffices' and the merely ‘conjectural’ one that does not,” DEK Energy, 248 F.3d at 1195, the Court thus finds that ATA has made a factual showing sufficient to establish that it faces imminent competitive injury. There is more than a “vague probability” that the subsidized planes will compete on routes served by ATA’s members and an even more significant probability that said competition “will cause [those members] to lose business or drop its prices.” DEK Energy, 248 F.3d at 1196 (rejecting competitor standing where only “vague probability” of competition and “a still lower probability” of injury stemming from that competition). Irrespective of where Air India deploys its planes, the Bank’s guarantees “‘will almost surely’ cause [ATA’s members] ‘to lose business,’ ... or to cut prices in order to preserve business.” Id. (quoting El Paso Natural Gas Co. v. FÉRC, 50 F.3d 23, 27 (D.C.Cir.1995)). Defendants make three primary counterarguments that merit mention. First, they suggest that the Court’s previous Opinion in this ease, which denied Plaintiffs’ Motion for Preliminary Injunction on the ground that they had not demonstrated irreparable harm, see ATA, 840 F.Supp.2d at 329-30, found or implied that Plaintiffs had not shown an injury in fact. In that decision, however, the Court concluded only that Plaintiffs had not shown that they would be irreparably harmed by the one or two planes that might be delivered in the months while this suit was pending. See id. at 337-38. The irreparable-harm standard requires a more significant showing than the injury-in-fact standard. See, e.g., In re Navy Chaplaincy, 534 F.3d 756, 766 (D.C.Cir.2008) (“[T]o show irreparable harm, ‘[a] plaintiff must do more than merely allege ... harm sufficient to establish standing.’”) (quoting Associated Gen. Contractors of Cal., Inc. v. Coal. for Econ. Equity, 950 F.2d 1401, 1410 (9th Cir.1991)) (alteration in original). The Court’s conclusion that there would be no irreparable harm, accordingly, does not entail a lack of injury in fact. The harm likely to ensue from the delivery of all of the planes provided for in the 2011 Commitments, furthermore, is much more significant than what can be attributed to the delivery of just one or two planes — all that the Court considered at the preliminary-injunction stage. Second, Defendants suggest that competitor standing has been limited to cases in which the challenged action permitted “competitors to enter a market from which they previously had been excluded.” See Defs.’ Mot. & Opp. at 18. Because this case .involves increased competition from existing, competitors — as opposed to new competition from new competitors — Defendants argue that Plaintiffs cannot look to competitive-injury doctrine to show injury. See id. While the “new competitor” fact pattern has undoubtedly been a common one in competitor-standing cases, Defendants point to nothing in those cases suggesting that the only kind of competitive injury sufficient to constitute injury in fact is that caused by the entry of a new competitor. Indeed, in Shays v. FEC, 414 F.3d 76 (D.C.Cir.2005), which addressed whether political candidates suffered injury in fact when FEC regulations permitted their rivals to engage in campaign practices that the plaintiffs contended were unlawful, see id. at 82, our Court of Appeals rejected precisely this argument. Recognizing that “the challenged rules create^] neither more nor different rival candidates — the electoral analogue to participants in a market,” the court nevertheless found that “intensified competition” caused a constitutionally cognizable injury. Id. at 86 (emphasis in original). “.Given that accounting for additional rivals constitutes injury in fact,” the court reasoned, the “need to account for additional practices — and thus ... additional campaign activity ... — likewise supports Article III standing.” Id. (emphases in original). “[B]oth [of] these changes — additional competitors and additional tactics — fundamentally alter the environment in which rival parties defend their concrete interests {e.g., their interest in persuading regulators, retaining customers, or winning reelection).” Id. In other words, regardless of whether the increased competition comes from a new competitor’s entrance into the market or from “intensified competition” from existing competitors, the injury — additional competition and the losses inhering therein — is effectively the same. In addition, while Shays is perhaps the most direct and certainly the most in-depth rejection of Defendants’ argument that only new entries into a market can cause a cognizable competitive injury, it is not the only time the D.C. Circuit has suggested that increased competition from existing competitors suffices. Of particular relevance here, the Court of Appeals has expressly acknowledged that “regulatory ■ decisions that permit subsidization of some participants in a market can have the requisite injurious impact on those participants’ competitors.” U.S. Telecom, 295 F.3d at 1331 (citing Exxon Co., U.S.A. v. FERC, 182 F.3d 30, 43 (D.C.Cir.1999); Liquid Carbonic Indus. Corp. v. FERC, 29 F.3d 697, 701 (D.C.Cir.1994)). In several other cases, furthermore, courts have suggested that increased competition in forms other than new competitors serves as injury in fact. See, e.g., La. Energy, 141 F.3d at 367 (“We repeatedly have held that parties suffer constitutional injury in fact when agencies lift regulatory restrictions on their competitors or otherwise allow increased competition.”) (emphasis added); Associated Gas Distribs. v. FERC, 899 F.2d 1250, 1259 (D.C.Cir. 1990) sufficient injury where “challenged action authorizes allegedly illegal transactions that have the clear and immediate potential to compete with- the petitioners’ own sales”; Panhandle Prods., 822 F.2d at 1108 (competitors injured by agency order permitting increase in gas supply because “such an increase in supply is likely to depress the prices that [competitors] can secure”). ' Defendants’ attempts to distinguish Shays and these other cases fall short. First, Defendants contend that the outcome in Shays turned on the fact that the plaintiff-candidates “operated in a competitive environment entirely structured by agency rules.” Defs.’ Reply at 3. In Sherley v. Sébelius, however, the Court of Appeals expressly rejected the “suggestion that only a ‘participant [] in [a] strictly regulated economic' market[ ]’ may assert competitor standing.” 610 F.3d at 72 (quoting Sherley v. Sebelius, 686 F.Supp.2d 1, 7 (D.D.C.2009)) (first alteration added). Second, Defendants maintain that a competitive injury is only cognizable where the plaintiff itself competed for the benefit conferred upon its competitor. See Defs.’ Reply at 4. Because ATA’s members do not compete with Air India for loan guarantees, the Government argues, they cannot claim competitor standing. See id. In support of this contention, Defendants cite Gottlieb v. FEC, 143 F.3d 618 (D.C.Cir.1998), a campaign-finance case distinguished by Shays that provided that the plaintiff, a political action committee, could not “claim standing as a ‘competitor’ of the Clinton campaign because it was never in a position to receive [the] matching funds [at issue in the case] itself.” Id. at 621. “Only another candidate,” the court stated, “could make such a claim.” Id. While this language in Gottlieb admittedly suggests otherwise, other cases make clear that competitor standing is not limited to those instances where the plaintiff was competing for .the governmental benefit in question. See, e.g., U.S. Telecom., 295 F.3d at 1331 (sufficient for standing that plaintiffs “members are ready, willing, and able to compete” in a given market and that government “subsidy prevents them from doing so on an equal basis”). Indeed, they make clear that competitor standing need not involve a government benefit at all. For example, “competitors of financial institutions have standing to challenge agency action relaxing statutory restrictions on the activities of those institutions.” Nat’l Credit Union Admin., 522 U.S. at 488, 118 S.Ct. 927; see also La. Energy, 141 F.3d at 367 (“We have repeatedly held that parties suffer constitutional injury in fact when agencies lift regulatory restrictions on their competitors .... ”); Shays, 414 F.3d at 93 (“FERC litigants may challenge administrative procedures that could benefit rivals .... ”). The logic of the competitor-standing doctrine, moreover,, is that a plaintiff is injured by increased competition, not by having been denied- a benefit. See Canadian Lumber, 517 F.3d at 1334 (“[I]n most ‘competitor standing’ cases, ... it is presumed ... that a boon to some market participants is a detriment to their competitors.”) (emphasis in original). Having been denied a governmental benefit may well be a distinct injury; it is not, however, a prerequisite for competitor standing. Gottlieb’s suggestion that only another candidate — and not a political action committee — could have competitor standing to challenge a campaign-financing scheme, accordingly, might best be read to stand for the proposition that only a direct competitor has standing to challenge a benefit conferred upon a rival. ATA’s member airlines, which compete directly with Air India, certainly fit this bill. While Gottlieb may thus cast doubt on whether other members of the air-travel industry who are not direct competitors with Air India— for example, the airlines’ employees, air traffic controllers, etc. — would have standing, the Court does not read it to require a plaintiff to have itself competed for a governmental benefit in order to challenge its conferral on a rival. Finally, Defendants argue that if competitive harms such as those demonstrated by ATA’s members constituted a constitutionally cognizable injury, every entity in the airline industry would have a viable claim to standing based on sheer speculation. See Defs.’ Mot. & Opp. at 17. This is far from the truth. ATA’s members— unlike most other entities in the airline industry — are direct competitors with Air India, an entity upon whom the government has conferred a significant benefit. See U.S. Telecom, 295 F.3d at 1331 (“[R]egulatory decisions that permit subsidization of some participants in a market can have the requisite injurious impact on those participants’ competitors.”); see also Canadian Lumber, 517 F.3d at 1334. They have made a factual showing, moreover, that prior Bank guarantees caused them significant, concrete injuries and that the 2011 Commitments are substantially certain to cause them further injury. Plaintiffs are not uninterested members of the public seeking to interfere in an agency decision in which they have no particularized interest; they are, instead, direct competitors who have made a clear showing of injury. Defendants’ contention that finding injury here would create a slippery slope by which anyone could challenge the Bank’s decisions, accordingly, is overblown. b. Causation Having cleared the injury-in-fact hurdle, things become substantially simpler for ATA. While Defendants are undoubtedly correct that the Bank’s allegedly unlawful financing practices are not solely responsible for the financial woes of ATA’s members, see Defs.’ Mot. & Opp. at 23-21, that argument — which, it seems, is the only leg on which Defendants purport to stand with respect to causation — does not undermine Plaintiffs’ position. After all, ATA need not show that all the economic losses of its members are attributable to the Ex-Im Bank’s actions; it need only show that the imminent competitive injuries just discussed are “fairly traceable” thereto. Summers, 555 U.S. at 493, 129 S.Ct. 1142. Just as the Sea-Land court seemed to have little trouble concluding that the subsidization of its rival caused that plaintiffs competitive injury, see 723 F.2d at 978, so too does the Court here conclude that the Bank’s commitments caused the airlines’ competitive injury. See also Shays, 414 F.3d at 93 (characterizing plaintiffs’ causation theory as “unremarkable” and emphasizing that “by tolerating what the law condemned, the government caused plaintiffs’ injury”). c. . Redressability Redressability similarly poses few problems for Plaintiffs. “[A] person who has been accorded a procedural right to protect his concrete interests -can assert that right without meeting all the normal standards for redressability and immediacy.” Lujan, 504 U.S. at 572 n. 7, 112 S.Ct. 2130. More specifically, where an agency has allegedly failed to comply with a procedural requirement that was intended to protect a plaintiffs interests, that plaintiff “need not show that better procedures would have led to a different substantive result” in order to establish redressability. Renal Physicians Ass’n v. U.S. Dept. of Health and Human Servs., 489 F.3d 1267, 1278 (D.C.Cir.2007); see also Sugar Cane Growers Co-op. v. Veneman, 289 F.3d 89, 94-95 (D.C.Cir.2002). Instead, it need only show that a court order requiring the agency to follow the procedures at issue would result in “a significant increase in the likelihood that [they] would obtain relief that directly redresses the injury suffered.” . Utah v. Evans, 536 U.S. 452, 464, 122 S.Ct. 2191,. 153 L.Ed.2d 453 (2002). This procedural-injury standard benefits Plaintiffs here. The provisions of the Bank Act Plaintiffs seek to enforce set forth procedural requirements explicitly intended to protect the concrete interests of domest