Litigation Procedure Standing. The City argued that the plaintiff must establish its standing with regard to each individual Section 4(f) property cited in the plaintiffs’ complaint. The court recognized that some courts have allowed “generalized, non-site-specific claims of injury” as the basis for standing to bring Section 4(f) claims. But the court held that, under the case law of the 9th Circuit, “site-specific standing is required in order to bring a Section 4(f) claim.” The plaintiff had challenged FTA’s Section 4(f) determinations with regard to numerous Section 4(f) properties. The court reviewed each claim, and determined that the plaintiff had standing to challenge FTA’s Section 4(f) determination for some properties, but not for others. For example, the court found that the plaintiff had standing to challenge the Section 4(f) determination for one property – Mother Waldron Park – because one of its members alleged that she frequented and enjoyed the open space in that park. Waiver. The City also argued that the plaintiff had waived the right to challenge FTA’s Section 4(f) determinations for some properties by failing to comment on those issues during the NEPA process. The court agreed with the City that “exhaustion requirements” apply to Section 4(f) claims – that is, the plaintiff cannot raise an issue in court if it never raised that concern with the agency during the NEPA process: “Comments that alert an agency to an argument in general terms are enough to avoid waiver, as long as the agency is given the opportunity to bring its expertise to bear to resolve the claim. the issue must be raised with sufficient clarity to allow the decision maker to understand and rule on the issue raised.” The court found that plaintiff had failed to comment specifically on two of the Section 4(f) properties cited in its complaint. Based on the exhaustion requirement, the court ruled against the plaintiff on both of those claims.