EBEL, Circuit Judge, dissenting from Section I.A., and dissenting in part and concurring in Section II on standing: I dissent from Section I.A. of this opinion and would find justiciability under 43 C.F.R. § 1784.6 -l(e). As to Section II on standing, I join the opinion of the court, except that I believe there is an additional basis for standing for Hou…
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