Opinion for the court by Circuit Judge ROGERS.
Dissenting opinion by Circuit Judge SENTELLE.
ROGERS, Circuit Judge:
This appeal presents the question whether appellants, three environmental organizations and Diane Jensen,1 have standing under the National Environmental Policy Act (“NEPA”) to challenge the failure of the Secretary of the Treasury and the Commissioner of the Internal Revenue Service (together “the Secretary”) to prepare an environmental impact statement prior to promulgating a final rule to allow a tax credit for an alternative fuel additive known as ethyl tertiary butyl ether (“ETBE”). The district court found that appellants lacked standing and granted summary judgment to the Secretary. Because we conclude that Ms. Jensen has standing, and we need not resolve the remaining standing claims, we reverse.
I.
Section 40 of the Internal Revenue Code provides a tax credit of 60 cents for each gallon of alcohol used in the production of a “qualified mixture” of alcohol and gasoline. 26 U.S.C. § 40(a), (b)(1) (1988 & Supp. V 1994).2 Prior to 1990, ETBE did not qualify for the tax credit because, while derived in part from ethanol (an alcohol produced by fermenting sugar contained in corn, sugar beets, and sugarcane), the final mixture contains no ethanol. Without the tax credit, ETBE could not compete commercially with a similar fuel additive, methyl tertiary ether. In 1988, sixty-one United States senators, including representatives from corn and sugar producing states, urged the Secretary to announce that ETBE qualifies for the tax credit.
[876]*876In 1989, the Secretary issued a proposed rale that would re-interpret “qualified mixture” to include blends derived from but not containing alcohol. See Alcohol Fuels Credit; Definition of Mixture, 54 Fed.Reg. 48,639 (Nov. 24, 1989). Explaining that the rale was based on “policy considerations,” 54 Fed Reg. at 48,639, the Secretary’s notice indicated that the proposed ETBE tax credit:
will increase the substitution of ETBE for other octane enhancers that cause more pollution. Second, it makes ETBE a more viable means of increasing the oxygen content of gasoline, which should help smooth the transition to oxygenated fuels in those areas that are not in compliance with carbon monoxide standards. Third, it encourages the substitution of ETBE-gasoline blends (gasohol). ETBE does not absorb water, which means it is easier to transport than gasohol, and it can be blended into the gasoline with less pollution than the ‘splash blending’ of gasohol. Fourth, it may increase the demand of domestic ethanol because ETBE is easier to use than ethanol, which would expand this alternative market for America’s farmers. Fifth, ETBE is a fuel, not just an octane enhancer, and it will displace some gasoline consumption. Substituting a renewable and domestically-produced fuel for imported petroleum will enhance national energy security and will improve the trade balance.
Id. at 48,640 (emphasis added). Comments submitted to the Secretary anticipated that the proposed tax credit would enlarge the market for sugar-containing crops such as corn and sugarcane. The National Corn Growers Association stated the new rule would “help open the door to a whole new market for the nation’s corn farmer.” Letter from Alan Kemper, President, National Corn Growers Ass’n, to the Commissioner of the Internal Revenue Service (Dec. 8, 1989).
In 1990, the Secretary promulgated a final rale. Identical to the proposed rale, it interpreted Section 40’s reference to a “qualified mixture” to include products derived from alcohol “even if the alcohol is chemically transformed in producing the product so that the alcohol is no longer present as separate chemical in the final product.” Alcohol Fuels Credit; Definition of Mixture, 58 Fed.Reg. 8946 (1990) (codified at 26 C.F.R. Part 1). In the notice accompanying the final rale, the Secretary rejected the suggestion that the National Environmental Policy Act (“NEPA”), 42 U.S.C. § 4332, required him to prepare an environmental impact statement (“EIS”) for this rale modification because Treasury Directive (“TD”) 75-02 provided a “categorical exception” from the EIS requirement for IRS regulations “interpreting, implementing, or clarifying” Internal Revenue Code provisions.
Appellants filed a complaint for a declaratory judgment against the Secretary pursuant to 28 U.S.C. § 2201 and Federal Rule of Civil Procedure 57, and a permanent injunction barring the Secretary from enforcing the final rule on the ground that the Secretary had violated NEPA, 42 U.S.C. § 4332, by promulgating the ETBE tax credit without preparing an EIS. Asserting “a serious potential for harmful environmental consequences,” appellants alleged that neither the Secretary “nor any other agency has undertaken any analysis of the ability of existing soil conservation and other environmental protection programs to mitigate adverse environmental consequences resulting from the ETBE tax credit.” Appellants requested an order directing the Secretary to rescind the final rule and not to reissue a final rale until an adequate EIS has been prepared. They argued that the categorical exemption under TD 75-02 was invalid because it failed, contrary to NEPA regulations, 40 C.F.R. § 1508.4, to provide for “extraordinary circumstances” in which a normally excluded action may have a significant environmental effect requiring preparation of an EIS.
With regard to their standing, appellants alleged that the tax credit would stimulate increased corn cultivation in Minnesota and Michigan, and increased sugarcane farming in Florida. Appellants asserted in their complaint that they regularly used wildlife refuges and other locations in these regions that would likely be adversely impacted as a result of this anticipated increase in farming. They further claimed that the Secretary’s failure to prepare an EIS deprived them of [877]*877information they needed to protect the areas in question.
In response to the parties’ cross-motions for summary judgment on standing, the district court granted the Secretary’s motion. The district court concluded that appellants had not satisfied the geographical nexus and causation requirements necessary to establish standing under NEPA. Appellants filed this appeal, and our review is de novo. See Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248, 106 S.Ct. 2505, 2510, 91 L.Ed.2d 202 (1986); Harbor Ins. Co. v. Stokes, 45 F.3d 499, 501 (D.C.Cir.1995); Washington Post Co. v. U.S. Dep’t of Health and Human Servs., 865 F.2d 320, 325 (D.C.Cir.1989).
II.
To meet the case or controversy requirement of Article III of the Constitution, a litigant in the federal courts must demonstrate that the litigant has suffered (1) an actual or threatened injury that (2) is fairly traceable to the challenged action and (3) is likely to be redressed by a favorable decision. See Valley Forge Christian College v. Americans United for Separation of Church and State, Inc., 454 U.S. 464, 472, 102 S.Ct. 752, 758, 70 L.Ed.2d 700 (1982); City of Los Angeles v. National Highway Traffic Safety Admin., 912 F.2d 478, 483 (D.C.Cir.1990). In Lujan v. Defenders of Wildlife, 504 U.S. 555, 560-61, 112 S.Ct. 2130, 2136, 119 L.Ed.2d 351 (1992), the Supreme Court explained that to satisfy the injury-in-faet requirement, a litigant must demonstrate “an invasion of a legally-protected interest which is (a) concrete and particularized, and (b) actual or imminent, not conjectural or hypothetical.” Defenders of Wildlife, 504 U.S. at 560, 112 S.Ct. at 2136 (citations and internal quotations omitted). Moreover, the Court noted that to satisfy the “causal connection between the injury and the conduct complained of — the injury has to be ‘fairly ... trace[able] to the challenged action of the defendant, and not ... th[e] result [of] the independent action of some third party not before the court.’ ” Id. 504 U.S. at 560, 112 S.Ct. at 2136 (quoting Simon v. Eastern Ky. Welfare Rights Org., 426 U.S. 26, 41-42, 96 S.Ct. 1917, 1926, 48 L.Ed.2d 450 (1976)).
To have standing under NEPA, appellants must show that the Secretary’s alleged noncompliance with NEPA has “adversely affected” or “aggrieved” them, and that they are within the zone of interests protected by NEPA. City of Los Angeles, 912 F.2d at 492; Committee for Auto Responsibility (C.A.R.) v. Solomon, 603 F.2d 992, 997 (D.C.Cir.1979), cert. denied, 445 U.S. 915, 100 S.Ct. 1274, 63 L.Ed.2d 599 (1980); Administrative Procedure Act (“APA”), 5 U.S.C. § 702. Under NEPA, a litigant is “aggrieved” by the agency’s failure to prepare an EIS only if the litigant can show, first, that the failure “ereat[es] ... a risk that serious environmental impacts will be overlooked,” see City of Davis v. Coleman, 521 F.2d 661, 671 (9th Cir.1975); see also City of Los Angeles, 912 F.2d at 492 (“NEPA gives rise to a cognizable injury from denial of its explanatory process, so long as there is a reasonable risk that environmental harm may occur.”); and second, that the litigant has “a sufficient geographical nexus to the site of the challenged project that [the litigant] may be expected to suffer whatever environmental consequences the project may have.” City of Davis, 521 F.2d at 671; see also City of Los Angeles, 912 F.2d at 483, 492.3 The zone of interests requirement is satisfied so long as the litigant’s interests are not “so marginally related to or inconsistent with the purposes implicit in the statute that it cannot reasonably be assumed that Congress intended to permit the suit.” Clarke v. Securities Indus. Ass’n, 479 U.S. 388, 399, 107 S.Ct. 750, 757, 93 L.Ed.2d 757 (1987); see also FAIC Securities, Inc. v. United States, 768 F.2d 352, 357 (D.C.Cir.1985). A litigant who establishes injury within the zone of interests protected by NEPA “will necessarily have satisfied the constitutional injury requirement as well.” City of Los Angeles, 912 F.2d at 483 (citation omitted).
[878]*878Appellants forthrightly state that if any one of them has shown sufficient evidence to withstand summary judgment on standing, the court need not consider the standing of other appellants. See Watt v. Energy Action Educ. Found., 454 U.S. 151, 161, 102 S.Ct. 205, 212-13, 70 L.Ed.2d 309 (1981); Legal Assistance for Vietnamese Asylum Seekers v. Dep’t of State, 45 F.3d 469 (D.C.Cir.1995); City of Los Angeles, 912 F.2d at 485. We therefore confíne our discussion to Ms. Jensen who presented sufficient evidence to demonstrate that she has standing to seek declaratory and injunctive relief requiring the Secretary to conduct an EIS before implementing the ETBE tax credit.
A.
Aggrievement under NEPA: (1) Risk of overlooking serious environmental harm. The Secretary maintains that a complex and improbable sequence of events must ensue in order for the ETBE tax credit to affect the environment as appellants anticipate: namely, that the ETBE tax credit must prompt ETBE production, which must increase demand for ethanol, which must increase demand for corn, which must increase corn farming, which must cause environmental harm. With only one exception, however, the Secretary has failed to dispute appellants’ proffered evidence establishing the likelihood of each of these causal links and the connections between them. The Secretary does not dispute record evidence that increased corn farming would adversely affect the environment by, among other things, increasing erosion and water pollution as farmers plant crops on now idle or underused land and expand their use of pesticides and fertilizers. It is also undisputed that an increased demand for ethanol would increase domestic corn production. Professor Peter Berck, an agricultural resource economist at the University of California (Berkeley), estimated that, as a result of the tax credit, the acreage of farm land devoted to growing corn would increase by between 281,000 acres to 14 million acres, depending on which of several projections regarding increased demand for ethanol proves to be correct. Insofar as estimates regarding increased ethanol production prove correct, the Secretary does not dispute Professor Berck’s conclusions.
As a result, the question whether appellants have established the first prong of NEPA’s injury-in-fact requirement depends solely on the likelihood that the ETBE tax credit will stimulate demand for ethanol. While future demand for ethanol cannot be estimated with certainty, appellants need not proffer conclusive proof that an increase in demand will occur; rather, they need only establish a reasonable risk that such an increase will occur. See City of Los Angeles, 912 F.2d at 492; Salmon River Concerned Citizens v. Robertson, 32 F.3d 1346, 1355 (9th Cir.1994) (upholding standing to challenge adequacy of EIS on proposed use of herbicides and noting that “[speculation that the application of herbicides might not occur is irrelevant”); see also Valley Forge Christian College, 454 U.S. at 472, 102 S.Ct. at 758; Idaho Conservation League v. Mumma, 956 F.2d 1508, 1515 (9th Cir.1992); Oregon Environmental Council v. Kunzman, 817 F.2d 484, 491 (9th Cir.1987); 13 C. Wright, A. Miller & E. Cooper, Federal Practice and Procedure § 3531.4 (2d ed. 1984 & Supp.1994).
Although the Secretary maintains in his brief that the ETBE credit cannot reasonably be expected to increase ethanol demand, this position is in direct conflict with one of his stated purposes in proposing the tax credit. See Alcohol Fuels Credit; Definition of Mixture, 54 Fed.Reg. 48,639 (to be codified at 26 C.F.R. Part 1) (Nov. 24, 1989). It is also contrary to record evidence that proponents of the ETBE tax credit expected the credit to increase demand for ethanol and corn production.4 The Secretary’s own ex[879]*879pert evidence, in a statement of Professor Leo Polopolus and Professor Andrew Schmitz, indicated that the “development and growth of the corn based U.S. ethanol industry is due to the various federal and state tax incentives, subsidies, and loan guarantees.” Indeed, unless we assume that the Secretary promulgated the ETBE tax credit as nothing more than an empty gesture, it is difficult to understand his argument that the credit will have no impact on ETBE and ethanol production. The Secretary’s unsupported contention that the ETBE tax credit cannot reasonably be expected to accomplish its professed purpose fails to give rise to a disputed issue of material fact such that summary judgment would be unwarranted. See City of Los Angeles, 912 F.2d at 492; see Idaho Conservation League, 956 F.2d at 1516 (“[S]hort of assuming that Congress imposed useless procedural safeguards, and that wilderness designation is a superfluous step, we must conclude that the management plan plays some, if not a critical part, in subsequent decisions.”).5
That the environmental harms appellants anticipate result from a chain of events rather than directly from the agency’s action does not defeat their standing under NEPA. See Idaho Conservation League, 956 F.2d at 1515; Wilderness Soc’y v. Griles, 824 F.2d 4, 12, 18 (D.C.Cir.1987). A litigant has standing under NEPA even if third parties must take action before the threatened environmental harm occurs. See United States v. Students Challenging Regulatory Agency Procedures (SCRAP), 412 U.S. 669, 93 S.Ct. 2405, 37 L.Ed.2d 254 (1973); Idaho Conservation League, 956 F.2d at 1515; Kunzman, 817 F.2d at 491. Furthermore, while a litigant can challenge NEPA compliance even where the agency itself must take additional action before the threatened harm can come to pass, see Sierra Club v. Marita, 46 F.3d 606, 612-13 (7th Cir.1995); Idaho Conservation League, 956 F.2d at 1515; Rockford League of Women Voters v. United States Nuclear Regulatory Comm’n, 679 F.2d 1218, 1221-22 (7th Cir.1982); but see Sierra Club v. Robertson, 28 F.3d 753, 785-60 (8th Cir.1994), here the Secretary has completed the relevant portion of his involvement. Indeed, were appellants to wait for the Secretary to accept a particular claim for the tax credit, the environmental damage that NEPA’s forward-looking scheme was intended to avoid might already have happened. The Secretary does not suggest any other point at which appellants could challenge the Secretary’s failure to conduct an EIS.
Thus, the Secretary’s suggestion that appellants lack standing because the injury they allege is speculative confuses the anticipated environmental consequences of the tax credit with the NEPA injury appellants actually claim. Consistent with NEPA standing requirements, appellants claim injury stemming from the Secretary’s failure to consider the anticipated environmental impacts. Where there is a reasonable risk of severe environmental harm and the agency has not complied with NEPA’s requirements, the injury is real, not conjectural. See Robertson v. Methow Valley Citizens Council, 490 U.S. 332, 349, 109 S.Ct. 1835, 1845, 104 L.Ed.2d 351 (1989) (Congress designed NEPA to ensure that “important effects will not be over[880]*880looked or underestimated only to be discovered after resources have been committed or the die is otherwise cast.”); City of Los Angeles, 912 F.2d at 491 (NEPA is a “future-oriented scheme”); id. at 504 (R.B. Ginsburg, J., concurring) (citing Public Citizen v. National Highway Traffic Safety Admin., 848 F.2d 256, 269 n. 2 (D.C.Cir.1988) (Silberman, J., dissenting in part) (“Standing analysis is different under NEPA, which confers a procedural right to have environmental impacts considered. A party is therefore ‘aggrieved’ if an agency fails to take the mandated procedural steps, provided the party actually asserts a bona fide environmental interest and is within the geographical area where the suspected impact is likely to occur.”)); see also Idaho Conservation League, 956 F.2d at 1515.
The possibility that crop production will increase absent the ETBE tax credit does not thwart appellants’ assertion that the failure to prepare an EIS created the risk that a serious environmental impact was overlooked. That the ETBE tax credit contributes to existing environmental harms or encourages new ones is sufficient to confer standing. See City of Los Angeles, 912 F.2d at 495-97; Public Citizen v. Office of the United States Trade Representative, 822 F.Supp. 21, 28 (D.D.C.1993), rev’d on other grounds, 5 F.3d 549 (D.C.Cir.1993), cert. denied., — U.S. —, 114 S.Ct. 685, 126 L.Ed.2d 652 (1994). Appellants have established that the ETBE tax credit is likely to increase corn production in addition to projected expansion unrelated to the credit and it is this marginal impact that appellants challenge through their NEPA claim.
For the same reason, we find unpersuasive the Secretary’s contention that the increase in corn farming anticipated by appellants would not have a perceptible effect given the total acreage already devoted to corn farming in the United States. Even if the aggregate increase in corn farming is not significant, the devotion of now idle or underused land to corn farming can dramatically affect the particular environments where it occurs. It is that localized incremental impact that appellants directly challenge.6 See infra Part II A(2); cf. City of Los Angeles, 912 F.2d at 484 (D.H. Ginsburg, J., dissenting in part) (concluding that environmental organization lacked standing in part because it failed to challenge incremental harm wrought by the agency’s decision).
As the Ninth Circuit has observed, the court must “bear in mind the statutory source that defines appellants’ right and imposes [the Secretary’s] duty. The standing examination, in other words, must focus on the likelihood that the defendant’s action will injure the plaintiff in the sense contemplated by Congress.” Idaho Conservation League, 956 F.2d at 1516. Viewed in this light, the promulgation of the ETBE tax credit without an EIS is harmful for purposes of standing by creating the risk that it will lead, through a reasonably direct chain of events, to serious environmental harm caused by farm run-off and erosion.
(2) Geographical nexus. To establish injury-in-fact under NEPA, a litigant must also have “a sufficient geographical nexus to the site of the challenged project that he may be expected to suffer whatever environmental consequences the project may have.” City of Davis, 521 F.2d at 671. Appellants need not establish with certainty that particular locations they use will be affected by the agency action but rather must establish a sufficient geographical nexus to the location “at which the environmental consequences are likely to be felt.” City of Los Angeles, 912 F.2d at 494; see also Idaho Conservation League, 956 F.2d at 1517. We conclude that Ms. Jensen, based on her sworn declaration and deposition, has established this nexus. Lujan v. Defenders of Wildlife, 504 U.S. at 562-63, 563-64, 112 S.Ct. at 2137, 2138.
In her sworn declaration, Ms. Jensen explained that she and her family regularly use and enjoy particular locations in Minnesota, including the Sherburne National Wildlife Refuge Rum River State Forest, Whitewater Wildlife Area, and Lac Qui Parle [881]*881Wildlife Area. At her deposition, in response to the government’s request, she identified ten areas, with an average diameter of twenty-five miles, that she regularly visits for her recreational activities. In her declaration she stated that these activities include hiking, canoeing, cross-country siding, birdwatching and photography, and fishing throughout undeveloped natural areas adjoining Minnesota land used for corn farming and susceptible to increased corn production. The Secretary does not dispute that Ms. Jensen has more than “ ‘some day’ intentions” to visit these areas, cf. Lujan v. Defenders of Wildlife, 504 U.S. at 563-64, 112 S.Ct. at 2138, and that she has alleged that these particular locations, and not land in its vicinity, are likely to be adversely affected by the ETBE tax credit. Cf. Lujan v. National Wildlife Federation, 497 U.S. 871, 887-89, 110 S.Ct. 3177, 3188-89, 111 L.Ed.2d 695 (1990).
Furthermore, Ms. Jensen has proffered unrefuted evidence that the ETBE tax credit is likely to affect areas she uses. Based on her experience on several Minnesota environmental task forces, state environmental advisory groups, and the state Board of Water and Soil Resources,7 Ms. Jensen states in her sworn declaration that local farmers, who now receive state subsidies to leave some land fallow and rotate fields, are likely to abandon the subsidy and develop these lands in order to take advantage of the tax credit. As a result, Ms. Jensen states, marginally productive lands, which require more fertilizer and pesticides to farm and are more susceptible to erosion, are likely to be cultivated. She further states that greater yields can be obtained from Minnesota farmland already devoted to corn farming through increased use of pesticides and fertilizer, which would threaten wildlife habitats by causing greater soil erosion and water pollution. Ms. Jensen also refers to meetings in which state representatives have advised her that the ETBE tax credit is likely to increase corn farming in Minnesota and that an EIS could destroy market opportunities for Minnesota corn. From this unrefuted evidence, the likelihood that the ETBE tax credit will stimulate increased corn production on lands neighboring those used by Ms. Jensen, and the fact that Minnesota is the fourth-largest corn-producing state in the United States, it reasonably follows that Ms. Jensen uses lands likely to be affected by the ETBE tax credit.
In his memorandum in support of summary judgment the Secretary argued that appellants “do not and cannot specify what lands throughout the nation not already used for agriculture will be converted into croplands, and what lands will be switched from producing other crops to producing corn and beets.” The Secretary stated that Ms. Jensen “does not even attempt to specify which lands will fie affected.” In his brief, the Secretary contends that appellants’ affidavits generally present “no competent evidence indicating that farmers near where plaintiffs recreate are planning to intensify crop production.” The Secretary also points to the fact that Professor Berck acknowledged that he could not determine the precise geographic location where increased corn production would occur.
The critical point, however, is that Ms. Jensen need not establish that increased corn farming is certain to occur and affect adversely the locations she uses and enjoys. Rather, to have standing under NEPA, she need only establish that such farming is likely to affect these regions. City of Los Angeles, 912 F.2d at 494; Salmon River, 32 F.3d at 1355 n. 14; Idaho Conservation League, 956 F.2d at 1517; Resources Ltd., Inc. v. Robertson, 35 F.3d 1300, 1303 (9th Cir.1993).8 [882]*882In Idaho Conservation League, for example, the plaintiffs claimed to use approximately 100,000 acres in the Idaho Panhandle Forest, but they could not identify whether this region, comprising less than one-quarter of the land that the Forest Service had designated for development, would in fact be developed. The Ninth Circuit concluded that the plaintiffs could do no more to identify specific sites in the absence of the. agency’s designation of development areas. 956 F.2d at 1514-17.
Because the geographical nexus component of NEPA standing is properly equated with the “concrete interest” test articulated by the Court in Lujan v. Defenders of Wildlife, see Douglas County v. Babbitt, 48 F.3d 1495, 1500-01 n. 5 (9th Cir.1995), this is a case where the litigant is “seeking to enforce a procedural requirement the disregard of which could impair a separate concrete interest of [hers].” Lujan v. Defenders of Wildlife, 504 U.S. at 571, 112 S.Ct. at 2142. Hence, the district court erred in ruling that Ms. Jensen had failed to established the requisite geographical nexus.9
B.
Causation. The question remains whether appellants have demonstrated that the injury is “fairly traceable” to the proposed ETBE tax credit. City of Los Angeles, 912 F.2d at 496 (citation omitted). Contrary to the Secretary’s contention, causation under NEPA is not lacking simply because the alleged environmental effects will be produced by “the independent choices made by third parties (here, potential ETBE manufacturers and farmers).” This argument is “better addressed to the first prong of the standing test.” Idaho Conservation League, 956 F.2d at 1517 (“in cases involving chains of events, it is common to confuse ... the issue of the likelihood of harm with its cause.”); see also Griles, 824 F.2d at 18 (“[T]he likelihood of injury, whether or not that likelihood depends upon a single event or a chain of events, is properly a concern of the personal injury inquiry, not the causation injury.”).
Here, appellants’ claimed injury is the risk that the failure to prepare an EIS will cause serious environmental consequences to be overlooked. That harm flows directly from the Secretary’s failure to prepare an EIS, notwithstanding the fact that other actors are needed for increased ethanol production to occur. Hence, the Secretary’s reliance on Allen v. Wright, 468 U.S. 737, 104 S.Ct. 3315, 82 L.Ed.2d 556 (1984), and Simon v. Eastern Kentucky Welfare Rights Organization, 426 U.S. 26, 96 S.Ct. 1917, 48 L.Ed.2d 450 (1975), is misplaced because neither case involved NEPA, where the cognizable injury is that the failure to comply with the statute creates the risk environmental harms will be overlooked and not that this failure necessarily causes the ultimate harm anticipated. Moreover, there appears to be a reasonable prospect that full consideration of the environmental consequences of the ETBE tax credit might prompt the Secretary to rescind or otherwise modify the tax credit because the Secretary emphasized, in proposing the rule extending the tax credit to ETBE, that several environmental benefits would result. See 54 Fed.Reg. at 48640. The causal nexus between the alleged injury and absence of an EIS is met by the prospect that the Secretary will rescind or otherwise modify the ETBE tax credit were the environmental consequences of the tax credit spelled out in more detail in an EIS. See Public Citizen v. National Highway Safety Administration, 848 F.2d at 263 n. 27; see also Lujan v. Defenders of Wildlife, 504 U.S. at 572 n. 7, 112 S.Ct. at 2142 n. 7 (“There is much truth [883]*883to the assertion that ‘procedural rights’ are special: The 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.”)
C.
Redressability. The nature of appellants’ claimed injury demonstrates its redressability. Appellants have met their burden to show that the injury they claim — the risk that serious environmental harms were overlooked in promulgating the ETBE tax credit — will be redressed by having the Secretary conduct an EIS. Appellants need not establish that the Secretary would not have promulgated the ETBE tax credit had he conducted an EIS. See Lujan v. Defenders of Wildlife, 504 U.S. at 572-73 n. 7, 112 S.Ct. at 2142-43 n. 7; Idaho Conservation League, 956 F.2d at 1518; City of Los Angeles, 912 F.2d at 499; Munoz-Mendoza v. Pierce, 711 F.2d 421, 428 (1st Cir.1983).10
D.
Zone of Interest. In enacting NEPA, Congress declared that in view of:
the profound impact of man’s activity on the interrelations of all components of the natural environment ... [and] the critical importance of restoring and maintaining environmental quality to the overall welfare and development of man, ... it is the continuing policy of the Federal Government ... to use all practicable means and measures ... in a manner calculated to foster and promote the general welfare. 42 U.S.C. § 4331(a). To carry out this policy, Congress directed that, “to the fullest extent possible, ... all agencies of the Federal Government shall ... include in every ... major Federal action[ ] significantly affecting the quality of the human environment, a detailed [environmental impact statement (‘EIS’) ].” Id. § 4332. The environmental harms stemming from increased corn farming suggested by appellants’ proffers, and no less by Ms. Jensen’s sworn declaration, fall within the broad trusteeship established by NEPA. City of Los Angeles, 912 F.2d at 495; 42 U.S.C. § 4331(b)(1).
Unlike the taxpayer standing cases on which the Secretary relies, appellants do not challenge the tax credit itself, but only the Secretary’s failure to fulfill the continuing federal environmental policy adopted by Congress in NEPA.11 See 42 U.S.C. § 4331(a). As one of NEPA’s sponsors forewarned, “It is far cheaper in human, social, and economic terms to anticipate these problems at an early stage and to find alternatives before they require .the massive expenditure we are now obligated to make to control air, water, and oil pollution.” See 115 Cong.Rec. S3,700 (daily ed. Feb. 18, 1969) (statement of Sen. Jackson). Ms. Jensen has demonstrated her geographical nexus to lands that are likely to be affected by increased corn production by reason of the tax credit. The Secretary’s suggestion, based on the categorical exemption under TD 75-02, that no one has standing to challenge the ETBE tax credit, not just that this case was brought by the wrong litigants, erroneously invokes his position on the merits as the reason to deny her (and the other appellants) standing, see Jacobs v. Barr, 959 F.2d 313, 316 (D.C.Cir.), cert. denied, — U.S. —, 113 S.Ct. 95, 121 L.Ed.2d 56 (1992), and we do not reach the merits here.
Accordingly, we hold that appellants have demonstrated that Ms. Jensen has standing [884]*884to pursue declaratory and injunctive relief in the district court, and we reverse the grant of summary judgment to the Secretary and remand the case with instructions to grant appellants’ cross-motion for summary judgment on standing insofar as Ms. Jensen has established standing.