Litigation Procedure Standing. The defendants argued that the plaintiff could not establish standing to bring a NEPA lawsuit because, as a business, the plaintiff solely alleged economic injuries, which fell outside the zone of interests protected by NEPA. The Court found that courts in other jurisdictions had reached conflicting decisions on the issue of whether an economic injury alone was sufficient to establish standing to bring a NEPA claim. After considering those other cases, the court held that an economic injury was not sufficient to establish standing and therefore dismissed the case: “NEPA was enacted to address environmental concerns. It was not meant to address the economic consequences of federal actions. The plaintiffs’ allegations of personal injury cannot confer prudential standing because they assert economic injuries, not environmental ones. These injuries are not within NEPA’s zone of interests.” … “The plaintiffs argue that harm under NEPA to the “human environment” can include economic, aesthetic, health, and safety injuries. While these injuries may help establish standing under NEPA, they alone cannot require the preparation of an EIS, the ultimate relief which the plaintiffs seek. … “Even if the plaintiffs were trying to preserve the ‘character’ and ‘ambiance’ of the Route 222 Corridor, they would be unable to establish standing because they would not be the ones whose recreational use or enjoyment of the environment would be impaired. MCA is a commercial entity, which by its very nature can’t ‘enjoy’ the aesthetics of its surroundings.” The court also considered whether the plaintiff should be allowed to amend its complaint to include additional allegations focusing on environmental harms. The court denied that request, finding that it would be futile for the plaintiff to amend its complaint, because the additional allegations that the plaintiff sought to make would still be insufficient to establish standing. Therefore, the court dismissed the lawsuit.