Full opinion text
Re Document Nos.:. 56, 57, 58, 63, 69 MEMORANDUM OPINION Denying Plaintiffs’ Motion fok Summary Judgment; Granting Defendants’ Cross-Motion for Summary Judgment; Denying as Moot Plaintiffs’ Motion for Admission of Extra-Record Evidence; Granting in Part and Denying in Part Defendants’ Motion to Strike; and Granting in Part and Denying in Part Plaintiffs’ Motion to Strike RUDOLPH CONTRERAS, United States District Judge I. INTRODUCTION Chesapeake Climate Action Network, Friends of the Earth, Sierra Club, West Virginia Highlands Conservancy, Center for International Environmental Law, and Pacific Environment (collectively, “Plain-, tiffs”) initiated the present action to challenge the Export-Import Bank of the United States’ (“the Bank”) approval of a $90 million loan guarantee. The guarantee supports a three-year, $100 million loan-from PNC Bank (“PNC”) to Xcoal Energy & Resources, LLC (“Xcoal”). According to Plaintiffs, the Bank’s guarantee allows Xcoal to export $1 billion in U.S. coal, which in turn results in significant adverse effects on human health and the environment. Plaintiffs contend that the Bank’s failure to consider such environmental impacts prior to approving the loan guarantee violated the National Environmental Policy Act, 42 U.S.C. §§ 4321 et seq. (“NEPA”), and the Administrative Procedure Act, 5 U.S.C. §§ 701 et seq. (“APA”). As a consequence, Plaintiffs seek a declaration that the Bank’s authorization of the loan guarantee violated NEPA, and an injunction ordering the Bank to rescind the guarantee and to comply with NEPA before providing any additional financing to Xcoal. In response, the Bank and its Chairman, Fred Hochberg (collectively, “Defendants”), argue first that Plaintiffs lack standing to assert their claims, and second, that the Bank was not required to consider the potential environmental impact of a loan guarantee under NEPA. Now before the Court are the parties’ cross-motions for summary judgment, as well as competing motions to admit and exclude extra-record evidence offered by both Plaintiffs and Defendants. After considering the parties’ motions, their memo-randa in support thereof and opposition thereto, and the administrative record, the Court hereby allows the introduction of extra-record declarations proffered by both parties for the limited purpose of assessing standing, excludes those portions of the parties’ declarations that are inadmissible, finds that Plaintiffs lack standing, and grants summary judgment in favor of Defendants. II. FACTUAL BACKGROUND A. Statutory background NEPA was enacted in 1970 “to promote efforts which will prevent or eliminate damage to the environment and biosphere....” 42 U.S.C. § 4321. Specifically, NEPA instructs any agency contemplating a “major Federal action[] significantly affecting the quality of the human environment,” to first prepare and solicit public comment on an environmental impact study (“EIS”). See 42 U.S.C. § 4332(C). The goals of the Act are two-fold: first, “it places upon an agency the obligation to consider every significant aspect of the environmental impact of a proposed action,” and second, “it ensures that the agency will inform the public that it has indeed considered environmental concerns in its decision-making process.” WildEarth Guardians v. Jewell, 738 F.3d 298, 302 (D.C.Cir.2013) (quoting Balt. Gas & Elec. Co. v. Natural Res. Def. Council, Inc., 462 U.S. 87, 97, 103 S.Ct. 2246, 76 L.Ed.2d 437 (1983). Thus, although NEPA does not require federal agencies to act on the basis of environmental concerns or to make the best decision for the environment, it does require that all agencies take a “ ‘hard look’ at the environmental consequences before taking a major action.” Balt. Gas & Elec., 462 U.S. at 97, 103 S.Ct. 2246. NEPA’s implementing regulations further explain that the term “[m]ajor Federal action includes actions with effects that may be major and which are potentially subject to Federal control and responsibility.” 40 C.F.R. § 1508.18. Covered actions include “new and continuing activities, including projects and programs entirely or partly financed, assisted ... or approved by federal agencies.... ” Id. To determine whether a given action significantly affects the environment, an agency must take into account the action’s cumulative impact on the environment. 40 C.F.R. § 1508.27. However, where a category of agency actions “do not individually or cumulatively have a significant effect on the human environment,” environmental analysis is not required, and the agency can establish procedures for categorically excluding those actions so long as it allows for exceptions in “extraordinary circumstances in which a normally excluded action may have a significant environmental effect.” 40 C.F.R. § 1508.4. Plaintiffs who believe that they have been harmed by an agency’s failure to comply with NEPA may bring suit under the APA, which provides a cause of action to “[a] person suffering legal wrong because of agency action, or adversely affected or aggrieved by agency action,” 5 U.S.C. § 702, if the agency action is final and “there is no other adequate remedy in a court,” 5 U.S.C. § 704. B. The Export-Import Bank of the United States Established as an independent federal agency in 1954, the Bank’s purpose is “to facilitate exports of goods and services ... and in so doing to contribute to the employment of United States workers.” See 12 U.S.C. § 635(a)(1). It does so by providing “loans, guarantees, insurance, and credits” to support U.S. exports. Id. Since 1982, Congress has specifically directed the Bank to: establish a program to provide guarantees for loans extended by financial institutions ... [to] exporters, when such loans are secured by export accounts receivable, [or] inventories of exportable goods ..., and when in the judgment of the Board of Directors — (1) the private credit market is not providing adequate financing to enable otherwise creditworthy export trading companies or exporters to consummate export transactions; and (2) such guarantees would facilitate expansion of exports which would not otherwise occur. 12 U.S.C. § 635a-4. In accordance with these instructions, the Bank established the working capital guarantee program (“WCGP”), which allows the.Bank to.enter into Master Guarantee Agreements (“MGAs”) with lenders on behalf of an exporter-borrower. See generally Export-Import Bank of the United States, Working Capital Guarantee Program Manual (effective Dec. 21, 2005), available at http://www.exim.gov/tools/applications andforms/working-capital-applications-and-forms.cfm. The Bank has promulgated a number of regulations to fulfill its obligations under NEPA. Although the Bank determined that “[h]istorically, virtually all financing provided by Eximbank has been in aid of U.S. exports which involve no effects on the quality of the environment within the United States,” 12 C.F.R. 408.3, it adopted procedures to govern “the. relatively rare cases where Eximbank financing of U.S. exports may affect environmental quality in the United States.... ” Id. More specifically, the Bank determined that “[alp-plications for Eximbank financing in the form of insurance or guarantees” normally do not require environmental assessments and are categorically excluded from NEPA’s EIS requirement unless “the presence of extraordinary circumstances indicates that some other level of environmental review may be appropriate.” 12 C.F.R. § 408.6. C. The Bank’s Approval of the Loan Guarantee Xcoal is one of the largest coal exporters in the United States, sending millions of tons of metallurgical coal overseas each year since its founding in 2004.. AR 32A, 34A, 133. The company takes possession of coal at mines in Pennsylvania and West Virginia, and it transports the coal by rail to port terminals in Maryland and Virginia. AR 34A, 35A. From there, Xcoal sends the coal to its export destination, usually China, South Korea, or Japan. AR 29A, 39A. To finance its export business, Xcoal has obtained lines of credit from PNC in the United States, as well as from several European banks. AR 35A-37A. In December 2011, Xcoal’s Vice President of Finance Craig McLane and a Senior Vice President at PNC completed a joint application for an export working capital guarantee from the Bank. AR 21. Xcoal had previously obtained a $25 million line of credit from PNC with the Bank’s support, and it sought to replace the preexisting guaranteed loan with a guaranteed loan of $100 million. AR 19, 273. At the time, Xcoal’s export sales were increasing and the company had $530 million in uncommitted lines of credit provided by nine European banks in addition to the $25 million from PNC. AR 32A, 36A. However, due to the European sovereign debt crisis, Xcoal was “concerned that its European banks may not be in a position to fund the Company in the future, and [it sought] to replace those financing arrangements with an increase in the Ex-Im Bank Loan Facility.” AR 32A. For that reason, and because PNC “traditionally does not (without Ex-Im Bank support) provide financing against accounts receivable due from foreign buyers,” Xcoal and PNC applied for a loan guarantee from the Bank. AR 32A. According to the joint application, the $100 million loan from PNC would support $1 billion in export sales of metallurgical coals, AR 20, and would primarily be used for working capital advances and to support the issuance of standby letters of credit as performance bonds, AR 20, 33A. Bank staff subsequently reviewed the application and prepared a written report recommending approval of the loan guarantee. See AR 31A-52A. In a section titled “Justification for Ex-Im Bank Support,” the Bank observed that Xcoal did “not have the ability to internally generate the necessary working capital,” that “[domestic financial institutions are not willing to provide enough financing to XCoal without the Ex-Im Bank guarantee,” and that with the Bank’s support, the company “will be able to ensure liquidity and access to capital should XCoal’s European banks hesitate in providing the necessary working capital financing.” AR 37A. At no point, during its consideration of the application did the Bank ever request or receive an EIS or an environmental analysis. On May 24, 2012, the Bank approved a $100 million transaction-specific revolving working capital guarantee loan from PNC to Xcoal with a term of 36 months. AR 1, 30A, 273. The loan is supported by the Bank’s $90 million loan guarantee, AR 30A, and is subject to the Bank’s Master Guarantee Agreement, AR 53-99. The Bank’s WCGP procedures dictate that “all transactions ... require approval by Ex-Im Bank staff prior to being included under the ... Loan Facility.” AR 33A. Since the Bank approved the loan guarantee, Xcoal has sought and received the Bank’s approval for more than a dozen transactions. See AR 135-205. On July 31, 2013, Plaintiffs initiated this suit to challenge the Bank’s authorization of the $90 million loan guarantee by filing a complaint in U.S. District Court for the Northern District of California. The case was transferred to this Court on November 20, 2013, and it is presently before the Court on the parties’ cross-motions for summary judgment. III. ANALYSIS A. Standing Federal courts are courts of limited jurisdiction, possessing “only that power authorized by Constitution and statute, which is not to be expanded by judicial decree.” Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375, 377, 114 S.Ct. 1673, 128 L.Ed.2d 391 (1994) (citations omitted). “It is to be presumed that a cause lies outside this limited jurisdiction, and the burden of establishing the contrary rests upon the party asserting jurisdiction.” Id. (citations omitted)'. The judicially created doctrine of standing derives from Article III of the U.S. Constitution, which confines the federal courts to adjudicating actual “Cases” and “Controversies, U.S. Const, art. Ill, § 2, cl. 1, and from “the separation-of-powers principles underlying that limitation.” Lexmark Int'l, Inc. v. Static Control Components, Inc., — U.S.-, 134 S.Ct. 1377, 1386, 188 L.Ed.2d 392 (2014). Thus, a showing of standing “is an essential and unchanging” predicate to any exercise of this Court’s jurisdiction. Lujan v. Defenders of Wildlife, 504 U.S. 555, 560, 112 S.Ct. 2130, 119 L.Ed.2d 351 (1992). The Court-must therefore determine first if it has jurisdiction over a given action before ruling on.the-merits. Al-Zahrani v. Rodriguez, 669 F.3d 315, 318 (D.C.Cir.2012). Ordinarily, a party has established standing if it shows that, at the time the complaint was filed: (1) “the ’ party has suffered an ‘injury in fact,’ ” (2) “the injury is ‘fairly traceable’ to the challenged action of the defendant,” and (3) “it is ‘likely, as opposed to merely speculative, that' the injury will be redressed by a favorable decision.’ ” Grocery Mfrs. Ass’n v. EPA, 693 F.3d 169, 174 (D.C.Cir.2012) (citing Defenders of Wildlife, 504 U.S. at 560-61, 112 S.Ct. 2130); La Botz v. Fed. Election Comm’n, No. 13-cv-997, 61 F.Supp.3d 21, 28-30, 2014 WL 3686764, at *4-5 (D.D.C. July 25, 2014) (“[Standing in the present action is ascertained from the facts as they existed when [the plaintiff] first filed his complaint in this Court in 2013.”). The standing inquiry is modified, however, in cases where a plaintiff, alleges a violation of his or her procedural- rights. In such cases — as when a plaintiff sues over the failure to conduct an EIS under NEPA — the plaintiff must “show that the interest asserted is more than a mere general interest.in the alleged procedural violation common to all members of the public, the plaintiff must show that the government act performed without the procedure in question will cause a distinct risk to a particularized interest of the plaintiff.” Fla. Audubon Soc. v. Bentsen, 94 F.3d 658, 664 (D.C.Cir.1996) (internal quotation marks and citation omitted). Although procedural rights plaintiffs need not show that, but for the procedural defect, the agency would have reached a different decision, they must establish “a causal relationship between the final agency action and the alleged injuries.” Ctr. for Law & Educ. v. Dep’t of Educ., 396 F.3d 1152, 1160 (D.C.Cir.2005). The causation prong of the standing inquiry looks to the “causal nexus between the agency action and the asserted injury, while re-dressability centers on the causal connection between the asserted injury and judicial relief.” Id. at 1160 n. 2 (quoting Freedom Republicans v. FEC, 13 F.3d 412, 418 (D.C.Cir.1994)). Furthermore, in those cases where the plaintiff was not the subject of government action or inaction, and where the harm to the plaintiff comes instead from the agency’s regulation of an independent third party not before the court, standing is ordinarily “substantially more difficult to establish.” See Defenders of Wildlife, 504 U.S. at 562, 112 S.Ct. 2130 (internal quotation marks omitted). In such instances, the elements of causation and redressability “hinge on the independent choices of the regulated third party,” and “it becomes the burden of the plaintiff to adduce facts showing that those choices have been or will be made in such manner as to produce causation and permit redressability of injury.” Ctr. for Law & Educ., 396 F.3d at 1161 (quoting Nat’l Wrestling Coaches Ass’n v. Dep’t of Educ., 366 F.3d 930, 938 (D.C.Cir.2004)). The Plaintiffs, as the parties invoking this Court’s jurisdiction, bear the burden of establishing all three elements of standing. WildEarth Guardians, 738 F.3d at 305. At the summary judgment stage, Plaintiffs bear the burden of showing that, taking their facts as true and drawing all reasonable inferences in their favor, a reasonable juror could find that they have standing. Dominguez v. UAL Corp., 666 F.3d 1359, 1362 (D.C.Cir.2012). To meet this burden, Plaintiffs must put forth specific facts — not mere allegations— that show a “substantial probability” that Plaintiffs were injured, that the Defendants caused the injury, and that a favorable decision of this Court could redress that injury. Sierra Club v. EPA 292 F.3d 895, 898-99 (D.C.Cir.2002). Where a plaintiff is an organization suing on behalf of its members — as is the case here for Plaintiffs Chesapeake Climate Action Network (“CCAN”), Friends of the Earth, Sierra Club, and West Virginia Highlands Conservancy (“WVHC”) — the organization has “representative” or “associational” standing if: “(1) at least one of its members would have standing to sue in his own right; (2) the interests the association seeks to protect are germane to its purpose, and (3) neither the claim asserted nor the relief requested requires that an individual member of the association participate in the lawsuit.” Id. at 898. Because the Center for International Environmental Law (“CIEL”) and Pacific Environment are organizations suing' on their own behalf, however, they “must make the same showing required of individuals: an actual or threatened injury in fact that is fairly traceable to the defendant’s allegedly unlawful conduct and likely to be redressed by a favorable court decision.” ASPCA v. Feld Entm’t, Inc., 659 F.3d 13, 24 (D.C.Cir.2011). Ultimately, the Court need only find that one plaintiff has established standing to allow a case to proceed to the merits. See Comcast Corp. v. FCC, 579 F.3d 1, 6 (D.C.Cir.2009) (“[I]f one party has standing in an action, a court need not reach the issue of the standing of other parties when it makes no difference to the merits of the case.”). B. Admissibility of Extra-Record Evidence Although judicial review of agency action is typically confined to the administrative record, where there is not sufficient evidence of standing in the record because the question was not before the agency, plaintiffs may submit extra-record evidence to establish standing. Sierra Club, 292 F.3d at 899. Indeed, if standing is not self-evident, a plaintiff “must supplement the record to the extent necessary to explain and substantiate its entitlement to judicial review.” Id. at 900 (emphasis added). In this case, both parties have submitted declarations to support or oppose a finding of standing. Additionally, both parties argue that a declaration offered by their opponents is inadmissible and cannot be considered even for the limited purpose of determining standing. See Ass’n of Flight Attendants-CWA, AFL-CIO v. U.S. Dep’t of Transp., 564 F.3d 462, 465 (D.C.Cir.2009) (holding that affidavits and other evidence offered to establish standing at the summary judgment stage are subject to the provisions of Federal Rule of Civil Procedure 56); see also Fed. R.Civ.P. 56(c)(4) (requiring that an “affidavit or declaration used to support or oppose a motion must be made on personal knowledge, set out facts that would be admissible in evidence, and show that the affiant or declarant is competent to testify on the matters stated.”). As a consequence, before the Court can conduct its standing analysis, it must first resolve the question of which declarations can be considered for standing purposes. See Fed. R.Evid. 104(a) (“The court must decide any preliminary question about whether a witness is qualified, a privilege exists, or evidence is admissible.”). Collectively, Plaintiffs have provided the Court with a total of thirteen declarations to establish standing. Seven of those declarations’ are from individual members of CCAN, Sierra Club, WVHC, and Friends of the Earth, who live, work, or recreate in Maryland, Virginia, or West Virginia. Two of the declarations are from representatives of CIEL and Pacific Environment. In addition, Plaintiffs have provided three declarations from experts to describe the environmental impact of coal exports. Defendants do not object to the Court’s consideration of any of these twelve declarations for the limited purpose of assessing standing. See Defs.’ Mot. Strike at 1, ECF No. 58; Defs.’ Mem. Support Mot. Strike at 1 n.2, ECF No. 59. Defendants do, however, object to Plaintiffs’ introduction of the declaration of Tom Sanzillo, a purported expert in finance, to explain the financial importance of the Bank’s loan guarantee to Xcoal. See Sanzillo Deck Ex. 4, ECF No. 56-4. Defendants argue that the Sanzillo declaration cannot be considered even for standing purposes because Mr. Sanzillo’s findings are unreliable, irrelevant, and unsupported such that they are inadmissible under the Federal Rules of Evidence. Defs.’ Mem. Support Mot. Strike at 8-9. Plaintiffs, on the other hand, argue that the declaration of Xcoal’s Vice President of Finance Craig McLane, offered by Defendants to show that Xcoal’s coal export activities do not depend upon the loan guarantee, is inadmissible. Plaintiffs argue first that the McLane declaration should not be considered because the Court should accept as true the facts averred by Plaintiffs with respect to standing, Pis.’ Mot. Strike McLane Decl. at 2 n.l, ECF No. 69, and second, that portions of the declaration constitute inadmissible speculation, Pis.’ Reply Mot. Strike McLane Deck at 5-6, ECF No. 74. The Court addresses the admissibility of the Sanzillo declaration and the McLane declaration in turn. 1. The Sanzillo Declaration Plaintiffs have asked the Court to consider the extra-record declaration of Tom Sanzillo, a purported financial expert and co-founder of the Institute for Energy Economics and Financial Analysis, an “organization dedicated to finding alternatives to fossil fuels, particularly coal.” Sanzillo Deck App’x A at 1. Mr. Sanzillo reviewed the administrative record, nine online sources and one additional document in this case in order to reach three conclusions regarding Xcoal’s financial need for the Bank’s guarantee. See San-zillo Deck ¶ 7. Defendants challenge the admissibility of Mr. Sanzillo’s declaration generally and his conclusions specifically, arguing that they cannot be considered even for standing purposes because they are not sufficiently supported, relevant, or reliable to satisfy the Federal Rules of Evidence. Defs.’ Mem. Support Mot. Strike at 11. After careful consideration, the Court agrees with Defendants. Rule 702, which governs the use of expert testimony, provides that a qualified expert may testify to assist the trier of fact “if the testimony is based on sufficient facts or data,” “the testimony is the product of reliable principles and methods,” and “the expert has reliably applied the principles and methods to the facts of the case.” Fed.R.Evid. 702. The Rule requires trial courts to assume a “gatekeeping role,” ensuring that the methodology underlying an expert’s testimony is valid and the expert’s conclusions are based on “good grounds.” Daubert v. Merrell Dow Pharm., Inc., 509 U.S. 579, 590-97, 113 S.Ct. 2786, 125 L.Ed.2d 469 (1993); see also Meister v. Med. Eng’g Corp., 267 F.3d 1123, 1127 (D.C.Cir.2001). Testimony based on “subjective belief or unsupported speculation” is not admissible as expert testimony. Daubert, 509 U.S. at 590, 113 S.Ct. 2786. “A court may refuse to admit expert testimony if it concludes that ‘there is simply too great an analytical gap between the data and the opinion proffered.’ ” Groobert v. President & Directors of Georgetown Coll., 219 F.Supp.2d 1, 6 (D.D.C.2002) (quoting Gen. Electric Co. v. Joiner, 522 U.S. 136, 146, 118 S.Ct. 512, 139 L.Ed.2d 508 (1997)); see also Fla. Audubon Soc., 94 F.3d at 667-68 (holding that Plaintiffs failed to produce competent evidence of injury where they relied on expert’s speculative testimony that a tax credit would encourage farmers to increase corn or sugar production in a manner that would increase agricultural pollution and damage wildlife areas). As an initial matter, this Court is presented with substantial difficulty in assessing the reliability of the principles or methodology used by Mr. Sanzillo as required by Rule 702 because Mr. Sanzillo has not identified any such principles or methodology. Mr. Sanzillo notes only that he reviewed certain documents and reached a series of conclusions. See San-zillo Decl. ¶ 7 (“Based on my review of these documents I conclude as follows-”). Precisely how Mr. Sanzillo’s review of the materials led him to reach his conclusions is nowhere described. For example, he offers no explanation as to how the administrative record’s discussion of Xcoal’s growth and limited access to alternative lines of credit caused him to determine that the removal of a specified percentage of Xcoal’s available financing would cause a reduction in or cessation of business. Put another way, the Court is unable to determine from Mr. Sanzillo’s declaration how he journeyed from the Bank’s finding that third-party banking is necessary for Xcoal to his conclusion that the loss of a particular $100 million line of credit in Xcoal’s $630 million credit portfolio would cause the company to limit or end its business. And despite the fact that Defendants have raised a number of challenges to Mr. Sanzillo’s qualifications and the reliability and admissibility of his conclusions, Plaintiffs have not suggested that additional information about Mr. San-zillo’s methodology is forthcoming or could be expected at trial. See Fed.R.Civ.P. 56(c)(2) advisory committee notes (2010 Amendments) (explaining that at the summary judgment stage, “[t]he burden is on the proponent to show that the material is admissible as presented or to explain the admissible form that is anticipated”). However, the failure of Mr. Sanzillo to identify the methodology or principles he applied is only the first of several problems presented by his declaration. The Court is also concerned about Mr. Sanzil-lo’s silence regarding whether financial experts are typically able to analyze a business’s dependence on a particular source of financing from the type and quantity of evidence that Mr. Sanzillo considered. Also troubling is Mr. Sanzillo’s failure to state how successful he has been in the past at predicting whether a business would be able to continue to operate if a certain percentage of its funding was rescinded. Cf. Estate of Gaither ex rel. Gaither v. District of Columbia, 831 F.Supp.2d 56, 70 (D.D.C.2011) (holding that plaintiffs failed to show that their expert’s opinion was the product of reliable principles and methods where there was no record evidence indicating how often the expert’s predictions turn out to be correct). These omissions are particularly concerning in light of the fact that Mr. Sanzillo reached his conclusion regarding Xcoal’s financial dependence on the Bank’s guarantee without ever actually reviewing Xcoal’s financials, which were redacted from the administrative record. While Mr. Sanzillo could hardly be blamed for failing to analyze documents not available to him, the Court does have serious reservations about his failure.to acknowledge this limitation in his analysis or to explain how he was able to determine Xcoal’s response to the rescission of the Bank’s guarantee without access to facts or data regarding the company’s operating costs or credit utilization rate. Cf. Parsi v. Daioleslam, 852 F.Supp.2d 82, 89 (D.D.C.2012) (explaining that the court was unable to understand how plaintiffs expert could “opine on whether defendant’s writings were properly substantiated,” without first “investigating defendant’s source materials in any systematic way,” and finding that “the ‘facts and data’ [the expert] relied on were patently insufficient for the task he was given”); id. at 95 (“[I]t is hard to see how ‘doing the math’ could be of any help to the factfinder when the math is so untethered from the reality of [the company’s] finances.”). Perhaps most significant, however, is the fact that Mr. Sanzillo’s declaration fails to reconcile the limited facts he did consider with the ultimate conclusion that he reached. Mr. Sanzillo found that Xcoal had already assembled a pre-existing line of credit totaling $530 million spread across multiple European banks “to support the company’s activities” before it obtained the Bank’s $90 million loan guarantee. Sanzillo Deck ¶ 10. Although he notes that in December 2011, Xcoal was concerned about the future availability of its European lines of credit in light of the then-existing European debt crisis, id. ¶ 11, he suggests neither that a $530 million credit portfolio is insufficient to support Xcoal’s export business nor that the availability of that line of credit was in jeopardy at the point in time relevant to determining Plaintiffs’ standing: the date the complaint was filed, July 31, 2013. See Defenders of Wildlife, 504 U.S. at 569 n. 4, 112 S.Ct. 2130 (“The existence of federal jurisdiction ordinarily depends on the facts as they exist when the complaint is filed.” (internal quotation marks omitted)). In fact, Mr. Sanzillo offers no means of connecting or reconciling the existence of size-able alternative lines of credit with his conclusion regarding what Xcoal would do if it lost the Bank’s support. There is thus a significant analytical gap between Mr. Sanzillo’s conclusion and the data on which he relies, and without any information regarding the methodology Mr. Sanzillo used, the Court is unable to bridge the gap. See Federal Rule of Evidence 702 (allowing an expert witness to testify “if ... the testimony is based on sufficient facts or data” and “the expert has reliably applied the principles and methods to the facts of the case”); Kumho Tire Co. v. Carmichael, 526 U.S. 137, 157, 119 S.Ct. 1167, 143 L.Ed.2d 238 (1999) (“[Nothing in either Daubert or the Federal Rules of Evidence requires a district court to admit opinion evidence that is connected to existing data only by the ipse dixit of the expert.” (quoting Gen. Elec. Co., 522 U.S. at 146, 118 S.Ct. 512). Accordingly, the Court finds that Mr. Sanzillo’s opinion as to what Xcoal would do without the loan guarantee is inadmissible and will not be considered because Plaintiffs have failed to establish that it is a product of a reliable methodology properly applied to sufficient facts and data such that it “rests on a reliable foundation.” See Daubert, 509 U.S. at 597, 113 S.Ct. 2786 (1993). 2. The McLane Declaration Defendants have submitted to the Court the declaration of Craig McLane, Xcoal’s Vice President of Finance. The McLane declaration details Xcoal’s financial position both at the time that it sought the loan guarantee in 2011 and presently, disputes the ability of Xcoal to impose environmental conditions on its service providers, and asserts that continuation of Xcoal’s business operations did not in the past and does not at present depend on the Bank’s guarantee. McLane Decl. at 1-2. In response, Plaintiffs first argue that because this case is currently at the summary judgment stage, the Court should accept Plaintiffs’ standing-related assertions as true and not consider contradictory assertions contained in the McLane declaration. Second, they argue that portions of the McLane declaration are too speculative to be admissible. Neither argument passes muster. Beginning with Plaintiffs’ first argument, they are correct to the extent that they argue that at summary judgment, this Court must take as true all “specific facts” set forth in Plaintiffs’ affidavits or other evidence, including those facts related to standing. See Defenders of Wildlife, 504 U.S. at 561, 112 S.Ct. 2130; see also Earle v. District of Columbia., 707 F.3d 299, 304 (D.C.Cir.2012) (“[T]he court must view the evidence in the light most favorable to the nonmoving party, draw all reasonable inferences in her favor, and eschew making credibility determinations or weighing the evidence.” (internal quotation marks omitted)). At the same time, however, a non-movant “may not rest upon mere allegation or denials of his pleading but must present affirmative evidence showing a genuine issue for trial.” Laningham v. U.S. Navy, 813 F.2d 1236, 1241 (D.C.Cir.1987) (internal quotation marks and citation omitted) (emphasis added); Defenders of Wildlife, 504 U.S. at 561, 112 S.Ct. 2130 (“In response to a summary judgment motion, however, the plaintiff can no longer rest on such mere allegations, but must set forth by affidavit or other evidence specific facts .... ” (internal quotation marks and citation omitted)). Additionally, there is a difference between accepting as true a plaintiffs specific facts offered to show standing and accepting as true the plaintiffs conclusion that he or she has standing. See Nat’l Treasury Emps. Union v. United States, 101 F.3d 1423, 1430 (D.C.Cir.1996) (explaining that even at the motion to dismiss stage, “[tjhere is a difference between accepting a plaintiffs allegations of fact as true and accepting as correct the conclusions plaintiff would draw from such facts”). Thus, while the Court will not credit any statements in the McLane declaration that are contradicted by Plaintiffs’ specific facts, Plaintiffs go too far in asking the Court to disregard the entirety of the McLane declaration simply because Plaintiffs allege they have standing. Next, Plaintiffs argue that portions of the McLane declaration on which Defendants depend to contest Plaintiffs’ assertions of standing are inadmissible because they are too speculative. Plaintiffs rely on Federal Rule of Evidence 602, which provides that the testimony of a lay witness is admissible only if based on the witness’s personal knowledge. Fed.R.Evid. 602 (“A witness may testify to a matter only if evidence is introduced sufficient to support a finding that the witness has personal knowledge of the matter.”). Specifically, Plaintiffs take aim at Mr. McLane’s assertions that “[h]ad the PNC Bank export facility not been extended to Xcoal in July of 2012, or had it subsequently been can-celled, Xcoal still would have been able to finance its export business to international coal markets through its European trade banks.” McLane Decl. ¶ 10. Plaintiffs argue that this statement constitutes impermissible speculation because Mr. McLane could not possibly know how such events would have unfolded, and that Plaintiffs are not required to negate such speculation to establish standing. Pis.’ Reply Support Mot. Strike McLane Decl. at 5-6 (citing Duke Power Co. v. Carolina Evil. Study Grp., Inc., 438 U.S. 59, 78, 98 S.Ct. 2620, 57 L.Ed.2d 595 (1978)). Plaintiffs also note that Mr. McLane’s assertion is contrary to the implicit findings of the Bank that Xcoal lacked sufficient financing and that the guarantee would support exports that would not otherwise occur. See 12 U.S.C. § 635a-4 (directing the Bank to “establish a program to provide guarantees ... when in the judgment of the Board of Directors — (1) the private credit market is not providing adequate financing ...; and (2) such guarantees would facilitate expansion of exports which would not otherwise occur”). Defendants dispute Plaintiffs’ interpretation of the Bank’s authorizing statute, which they argue requires consideration of factors like the availability of financing and the facilitation of exports at the programmatic level, and does not require every individual guarantee to meet those requirements. In addition, Defendants argue that Mr. McLane’s statement is based on first-hand knowledge. According to the declaration, Mr. McLane has been Xcoal’s director of finance since 2008, his duties include negotiating and administering “all of the credit facilities required, or deemed prudent, for Xcoal’s exporting business,” and his statement is supported by the fact that Xcoal “was only drawing down approximately 70% of [its] total available credit” when it applied for the loan guarantee. McLane Decl. ¶¶ 1, 4, 7. Nevertheless, the Court is not persuaded that Mr. McLane’s assertion is of any relevance in determining Plaintiffs’ standing. The assertion that Xcoal “would have been able to finance its export business,” even if true, is of little value standing alone because it makes no representation that Xcoal would have been able to finance the same volume of coal exports in the absence of the Bank’s guarantee. On this basis, and in light of the record evidence suggesting that the Bank did, in fact, consider Xcoal’s need for the Bank’s financing prior to authorizing the guarantee, see AR 263, the Court "will disregard the McLane declaration’s statement regarding what Xcoal would have done had it not received the financing in question in July 2012. C. Associational Standing: CCAN, Friends of the Earth, Sierra Club, and WVHC Having disposed of the preliminary questions of admissibility, the Court now considers whether the four Plaintiffs bringing suit on behalf of their members— CCAN, Friends of the Earth, Sierra Club, and WVHC — have established associational standing to bring the instant action. To establish standing to sue in a representative capacity, at least one of the plaintiffs must show that “(1) at least one of its members would have standing to sue in his own right, (2) the interests the association seeks to protect are germane to its purpose, and (3) neither the claim asserted nor the relief requested requires that an individual member of the association participate in the lawsuit.” Sierra Club, 292 F.3d at 898. At issue in this case is the first prong of the associational standing test: whether Plaintiffs have established that their members would have standing to sue in their own right. Defendants do not dispute Plaintiffs’ assertions that their members are injured by pollution produced from the process of exporting coal, but they do contend that Plaintiffs have failed to establish the second and third elements of standing: causation and re-dressability. See Defs.’ Mem. Support Mot. Summ. J. at 11-25, ECF No. 64. More specifically, Defendants argue that Plaintiffs have failed to show that the Bank’s decision to authorize the guarantee to PNC on behalf of Xcoal caused an increase in the volume of coal exported, or that an order of this Court rescinding the guarantee would cause Xcoal to reduce the volume of coal it exports, thereby reducing the pollution injuring Plaintiffs’ members. Because Plaintiffs have failed to establish any likelihood that third party Xcoal’s choices “will be made in such manner as to ... permit redressability of injury,” this Court agrees with Defendants that Plaintiffs have failed to establish redressability and thus lack associational standing to pursue their claims. See Ctr. for Law & Educ., 396 F.3d at 1161. The causation or traceability element of standing requires that “there must be a causal connection between the injury and the conduct complained of — the injury has to be fairly traceable to the challenged action of the defendant, and not the result of the independent action of some third party not before the court.” Defenders of Wildlife, 504 U.S. at 560, 112 S.Ct. 2130 (internal quotation marks and alterations omitted). To establish the redressability element of standing, “it must be likely, as opposed to merely speculative, that the injury will be redressed by a favorable decision.” Id. at 561, 112 S.Ct. 2130 (internal quotation marks omitted); see also Vill. of Bensenville v. FAA, 457 F.3d 52, 69 (D.C.Cir.2006) (“[F]or purpose of determining the petitioners’ standing, the court must decide whether the practical consequence of [vacating the agency’s decision] would amount to a significant increase in the likelihood that [plaintiffs’] would obtain relief that directly redresses the injury suffered.” (internal quotation marks omitted)). In a case like this concerning the alleged violation of procedural rights, the standards for redressability and immediacy are relaxed to a certain extent, meaning that the Plaintiffs need not establish with any certainty that the Bank would reach a different decision regarding the loan guarantee if it first considered possible environmental consequences. See Defenders of Wildlife, 504 U.S. at 572 n. 7, 112 S.Ct. 2130 (noting that if a federal agency issues a license to authorize construction of a dam without first preparing an EIS, individuals living adjacent to the dam have standing without needing to show that the agency would have withheld the license had it prepared an EIS). But the agency’s decision is only one piece of the re-dressability puzzle in a case where a plaintiff alleges that government funding to an independent third party has caused the third party to injure the plaintiff. In such cases, plaintiffs must satisfy normal re-dressability standards as to the third party whose actions are directly causing the plaintiffs injuries. St. John’s United Church of Christ v. FAA, 520 F.3d 460, 463 (D.C.Cir.2008) (holding that where plaintiffs alleged that agency funding to a third party was authorized in violation of the plaintiff’s procedural rights, redressa-bility standards were relaxed only as to the agency and not the third party); see also Nat’l Parks Conservation Ass’n v. Manson, 414 F.3d 1, 5 (D.C.Cir.2005) (“The relaxation of procedural standing requirements would excuse [Plaintiffs] from having to prove the causal relationship regarding the [agency] action, but its burden regarding the action of the [third party] would not change.”). As a consequence, although Plaintiffs need not show that the Bank’s consideration of environmental impacts would cause it to modify its decision, they must provide some basis for finding that the “nonagency activity” that affects then&wkey; namely, Xcoal’s exporting of coal — “will be altered or affected by the agency activity they seek to overturn.” St. John’s United Church of Christ, 520 F.3d at 463 (quoting Defenders of Wildlife, 504 U.S. at 571, 112 S.Ct. 2130); see also Newdow v. Roberts, 603 F.3d 1002, 1012 (D.C.Cir.2010) (applying Defenders of Wildlife’s “third party” analysis to the redressability prong of the standing test); Renal Physicians Ass’n v. U.S. Dep’t of Health & Human Servs., 489 F.3d 1267, 1275 (D.C.Cir.2007) (“[T]o establish redressability ... we required that the facts alleged be sufficient to demonstrate a substantial likelihood that the third party directly injuring the plaintiff would cease doing so as a result of the relief the plaintiff sought.”). Plaintiffs contend that they have been injured by export-related pollution produced by coal mining and transportation, that the Bank’s loan guarantee to PNC allowed Xcoal to export more coal than would have been possible without the Bank’s assistance, and that rescinding the Bank’s financing for the remainder of the loan term will reduce the additional coal that Xcoal can export until the Bank conducts an EIS in compliance with NEPA. Pis.’ Reply Support Mot. Summ. J. at 1-2, ECF No. 70. Plaintiffs’ assertion of redressability thus hinges on the proposition that if this Court orders the Bank to rescind its guarantee and comply with NEPA: (1) regulated third party PNC will, in turn, rescind, reduce, or otherwise modify its loan to third party Xcoal, (2) Xcoal will respond to this change in available credit by reducing the amount of coal that it exports, and (3) the reduction in Xcoal’s exports will decrease the coal-related pollution harming Plaintiffs’ members. Unfortunately for Plaintiffs, however, a review of the administrative record and the parties’ declarations shows that Plaintiffs have failed to establish that any alteration in the Bank’s decision to authorize the loan guarantee could or would affect the amount of coal that Xcoal exports. The declarations of Plaintiffs members all describe the negative effects of coal pollution, concern that the loan guarantee will increase pollution, and the belief that the members’ interests would be better protected by the Bank’s compliance with NEPA. As Defendants point out, however, the members’ hopes or beliefs that an order rescinding the guarantee would redress their injuries, however genuine, do not constitute “specific facts” showing re-dressability. See Wilkerson v. Wackenhut Protective Servs., Inc., 813 F.Supp.2d 61, 67 (D.D.C.2011) (explaining that personal belief, speculation, and hearsay are insufficient to defeat a motion for summary judgment). Plaintiffs also assert in their reply brief that a favorable decision by this court ordering the Bank to rescind the guarantee “would reduce the volume of coal exported and directly redress Plaintiffs’ substantive harms,” Reply Support of Pis.’ Mot. for Summ. J. at 10, but they cite nothing in the record to support this assertion. See Defenders of Wildlife, 504 U.S. at 561, 112 S.Ct. 2130 (“In response to a summary judgment motion, ... the plaintiff can no longer rest on such mere allegations, but must set forth by affidavit or other evidence specific facts .... ” (internal quotation marks and citation omitted)). .The McLane declaration, in contrast, contains specific facts supporting Defendants’ assertion that because Xcoal has accumulated enough alternative sources of credit, even if Plaintiffs obtain the relief they seek, the company’s coal exports will continue unchecked and Plaintiffs’ injury will not be redressed. Cf. Vill. of Bensenville, 457 F.3d at 70 (holding that petitioners’ injury was not redressable by a decision vacating $337 million in agency funding for a project because the project could continue on the basis of other sources of financing). Specifically, Mr. McLane testified that because the “European banking crisis has eased substantially” since Xcoal completed its application for the loan guarantee in December 2011, “even in the absence of the PNC Bank export facility, Xcoal would readily be able to support its current volume of business through its unused and available financing.” McLane Deck ¶ 10. As support, Mr. McLane explains that “Xcoal has available approximately $535 million in commodity trade facilities, including the $100 million facility from PNC, spread among eight (8) lending institutions.... ” Id. ¶ 8. The Bank’s loan guarantee thus supports 18.7% of Xcoal’s total credit. Although 18.7 is not an insignificant percentage, the McLane declaration further reveals that Xcoal’s credit utilization rate is only 30%, meaning that the company has “approximately $374 million in unused credit available.” Id. In response to Mr. McLane’s declaration, Plaintiffs have not come forward with any specific facts that rebut or cast doubt on Mr. McLane’s testimony. They do not dispute his assertion that the European banking crisis has eased substantially or that Xcoal is only using 30% of its available lines of credit. They do not suggest that Xcoal’s existing alternative lines of credit are unstable or insufficient, or that Mr. McLane has in any way misrepresented Xcoal’s available financing. Although the Sanzillo declaration posits that it would be difficult for Xcoal to obtain additional sources of funding at this time given the present state of the coal industry, see San-zillo Decl. at 6-9, that fact does nothing to dispute the Defendants’ assertion that the financing Xcoal has already obtained is sufficient to support its export business. Similarly, even if Mr. Sanzillo is correct that Xcoal “would have agreed” to environmental conditions imposed by the Bank because its financing “was imperiled” by the European debt crisis when it sought the Bank’s assistance in 2011, see id. ¶ 22, he does not suggest that Xcoal’s pre-exist-ing financing was perceived to be at risk by the time that Plaintiffs filed their complaint in 2013. See Freedom Republi cans, Inc. v. FEC, 13 F.3d 412, 418 (D.C.Cir.1994) (observing that while “[cjausation remains inherently historical^] ... redressability [is] quintessential^ predictive”). On facts like these, the D.C. Circuit Court’s redressability analysis in St. John’s United Church of Christ v. FAA, 520 F.3d 460 (D.C.Cir.2008), is particularly instructive. In that case, plaintiffs sought to challenge the Federal Aviation Administration’s (“FAA”) $29.3 million airport improvement grant to the City of Chicago. Id. at 462. The grant was one of several from the agency designed to reimburse Chicago for up to $337 million spent on airport improvement projects that plaintiffs claimed would cause them a variety of injuries. Id. at 461. The plaintiffs argued that the FAA’s decision to award the grant violated their procedural rights and caused their injuries, and that their injury was redressable because Chicago could not complete the projects in question without the FAA’s assistance. Id. at 462. The Circuit Court disagreed, however, and found that Chicago provided most of its own funding “and [was] prepared to obtain funding from other sources if federal money is unavailable.” Id. at 463. Because Chicago was committed to completing the project with or without FAA funding, which was replaceable, the court held that the plaintiffs had failed to establish re-dressability because they did not show a “substantial probability” that the city “would scrap the ... project if the court vacated the $29.3 million grant.” Id. (explaining that the plaintiffs’ “redressability obstacle” was “uncertainty over what Chicago would do — not the FAA,” so petitioners had to satisfy normal redressability standards despite their claim of procedural injury). The court concluded that on the facts before it, it was “entirely conjectural whether the nonagency activity that affects petitioners will be altered or affected by the agency activity they seek to overturn.” Id. (internal quotation marks omitted). Plaintiffs here run into the same “re-dressability obstacle” as the petitioners in St. John’s. The proposition that Xcoal would export less coal if the Court orders the Bank to rescind its guarantee is, at best, entirely conjectural in light of the availability of alternative funds and Xcoal’s stated commitment to exporting the same volume of coal regardless of whether the loan guarantee is rescinded. Such record evidence “that the third parties whose conduct injured the plaintiffs would have had reason to continue their injurious conduct unaltered in the absence of the challenged government action” is significant, and distinguishes the case at hand from those cases “where the record presented substantial evidence of a causal relationship between the government policy and the third-party conduct, leaving little doubt as to causation and the likelihood of redress.” Nat’l Wrestling Coaches Ass’n, 366 F.3d at 941-43. Accordingly, even if the Court accepts Plaintiffs’ position that the guarantee authorized in May 2012 was intended to support an increase in exports, and even if the Court assumes traceability, in light of the uncontested specific facts of the McLane declaration, Plaintiffs are still no closer to establishing that their injury was redressa-ble at the time they filed their complaint. See Renal Physicians Ass’n v. U.S. Dep’t of Health & Human Servs., 489 F.3d 1267, 1278 (D.C.Cir.2007) (“[C]ausation does not inevitably imply redressability.”); see also Bennett v. Donovan, 703 F.3d 582, 587 (D.C.Cir.2013) (summarizing cases in which no redressability was established despite the fact that “third parties ... took actions because of allegedly unlawful agency decisions” where the third parties “would have no compelling reason to reverse those actions were the [agency] decisions held unlawful by a court”). As the D.C. Circuit Court explained in Renal Physicians, there are cases where “governmental action is a substantial contributing factor in bringing about a specific harm, but the undoing of the governmental action will not undo the harm, because the new status quo is held in place by other forces.” 489 F.3d at 1278. In sum, Plaintiffs have failed to show that a favorable decision from this Court is likely to cause Xcoal to reduce the volume of its exports. See Defenders of Wildlife, 504 U.S. at 561, 112 S.Ct. 2130 (“[I]t must be-likely, as opposed to merely speculative, that the injury will be redressed by a favorable decision” of the Court, (internal quotation marks omitted)); see also Nat’l Wrestling Coaches Ass’n, 366 F.3d at 938 (“[T]he Supreme Court has made clear that a plaintiffs standing fails where it is purely speculative that a requested change in government policy will alter the behavior of regulated third parties that are the direct cause of the plaintiffs injuries”). Defendants have presented specific facts establishing that the European banking crisis has eased substantially since December 2011, that Xcoal has $535 million in credit, that the company’s credit utilization rate is only 30%, and that Xcoal “would readily be able to support its current volume of business” with its existing lines of credit even if the Bank rescinded its loan guarantee. See McLane Decl. ¶¶ 7, 10. Plaintiffs have not come forward with any evidence that casts doubt on these facts. See also Brady Campaign to Prevent Gun Violence United with the Million Mom March v. Ashcroft, 339 F.Supp.2d 68, 78 (D.D.C.2004) (“[Ajbsent such factual allegations to demonstrate how the relevant third parties are likely to conduct themselves if the requested judicial relief were to be granted, the [Plaintiff] fails to satisfy the heavy burden imposed by the ... re-dressability prong of the standing inquiry where third party action is a cause of injury”). Accordingly, the Court concludes that Plaintiffs have failed to establish that a favorable decision by this Court could redress their injuries. Cf. Defenders of Wildlife, 504 U.S. at 571, 112 S.Ct. 2130 (holding that the fact that agencies supplied only a fraction of the funding for a disputed project was an “impediment to redressability” where “Respondents have produced nothing to indicate that the projects they have named will either be suspended, or do less harm to listed species, if that fraction is eliminated.”). Plaintiffs CCAN, Friends of the Earth, Sierra Club, and WVHC have thus failed to establish an essential element of Article III standing. D. Organizational Standing: CIEL and Pacific Environment Plaintiffs CIEL and Pacific Environment both allege that they have been harmed by the Bank’s decision to authorize a $90 million loan guarantee on behalf of a coal exporter without first considering the potential environmental consequences. Unlike CCAN, Friends of the Earth, Sierra Club, and WVHC, however, Plaintiffs CIEL and Pacific Environment do not claim to have standing to sue on behalf of their members who are harmed by coal-export related pollution. Instead, both CIEL and Pacific Environment claim standing in their own right, arguing that they have each suffered injuries to their organizations’ missions, activities, and resources sufficient to convey organizational standing under Havens Realty Corp. v. Coleman, 455 U.S. 363, 102 S.Ct. 1114, 71 L.Ed.2d 214 (1982). See Pis.’ Reply Support Mot. for Summ. J. at 13. Defendants dispute this claim, arguing that the organizations have failed to establish standing because they have failed to show injury-in-fact. Defendants point out that mere interest in a topic or tension between agency action and an organization’s policy agenda is insufficient to convey standing under the test established by the Supreme Court in Havens. See Mem. Support Defs.’ Mot. Summ. J. at 25-26. Based on the record established by the parties, the Court agrees with Defendants that neither CIEL nor Pacific Environment has established the injury in fact necessary to convey organizational standing. “To show injury-in-fact, an organization must allege more than a mere ‘setback to [its] abstract social interests.’ ” Competitive Enter. Inst. v. Nat’l Highway Traffic Safety Admin., 901 F.2d 107, 122 (D.C.Cir.1990) (quoting Havens Realty Corp., 455 U.S. at 378-79, 102 S.Ct. 1114). Accordingly, mere organizational interest in the environment, “no matter how longstanding the interest and no matter how qualified the organization is in evaluating the problem, is not sufficient by itself to render [an] organization adversely affected or aggrieved within the meaning of the APA.” Sierra Club v. Morton, 405 U.S. 727, 739, 92 S.Ct. 1361, 31 L.Ed.2d 636 (1972) (internal quotation marks omitted) (holding that the Sierra Club’s well-established interest in protecting the environment was not enough to give the organization standing to challenge governmental action that was harmful to the environment). As the Supreme Court explained in Havens, an organization suing on its own behalf can establish standing by showing that a defendant’s actions have “perceptibly impaired” the organization’s ability to provide services, such that there has been a “concrete and demonstrable injury to the organization’s activities— with [a] consequent drain on resources.” 455 U.S. at 379, 102 S.Ct. 1114; see also Competitive Enter. Inst., 901 F.2d at 122 (requiring organization claiming injury to allege “that discrete programmatic concerns are being directly and adversely affected by the challenged actions” (internal quotation marks omitted)). ■ Building on the Supreme Court’s analysis in Havens, the D.C. Circuit has established two other requirements that must be met in an organizational injury case. First, the government’s conduct must “directly conflict with the organization’s mission,” Nat’l Treasury Emps. Union v. United States, 101 F.3d 1423, 1430 (D.C.Cir.1996) (“[I]n those cases where an organization alleges that a defendant’s conduct has made the organization’s activities more difficult, the presence of a direct conflict between the defendant’s conduct and the organization’s mission is necessary — though not alone sufficient — to establish standing.”). And second, the organization must show that it has expended resources to counteract the injury to its ability to achieve its mission and not simply as a product of “unnecessary alarmism constituting a self-inflicted injury.” Id. 1. Pacific Environment The Court begins by considering Plaintiff Pacific Environment’s assertion of organizational injury. To support its claim of injury in fact, Pacific Environment has provided the Court with the declaration of the organization’s policy director, Douglas Norlen. See Norlen Deck, ECF No. 56-9. Citing the Norlen declaration, Plaintiffs argue that Pacific Environment has established Havens standing in this case by showing that the Bank’s decision to authorize the loan guarantee: (1) conflicts with the organization’s mission, and (2) “will require Pacific Environment to devote additional resources to its work promoting environmentally responsible financing.” Pis. Mot. Summ. J. at 23-24. A careful review of the Norlen declaration, however, reveals that it falls short of establishing standing under Havens. As the Norlen declaration explains, Pacific Environment is an organization incorporated and headquartered in California. Norlen Decl. ¶ 3. The organization’s mission “is to strengthen democracy, support grassroots activism, empower local communities, and redefine international policies in order to protect the living environment of the Pacific Rim.” Id. ¶¶ 3-4 (emphasis added). Although the organization has pursued its mission with a range of activities, including efforts to reform the Bank’s regulations and to require the Bank to adequately assess the environmental impacts of fossil fuel projects, the declaration does not suggest that the specific agency action challenged in this case has any potential whatsoever to affect “the living environment of the Pacific Rim.” Cf. Nat’l Treasury Emps. Union, 101 F.3d at 1430 (granting motion to dismiss for lack of standing where organization failed to establish a direct conflict between its mission of improving worker conditions and the legislation it sought to challenge). In the absence of any evidence suggesting that the particular loan guarantee at issue in this case has even the potential to affect the environment of the Pacific Rim, the Court is unable to discern any direct conflict' between the challenged agency action and the mission of Pacific Environment. The No