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Climate Attribution and the Willow Project: Federal Obligations to Evaluate the Effects of Fossil Fuel Leasing on Endangered Species

Law Columbia

2003) (finding that NOAA’s defined “action area” was unreasonably narrow because it excluded areas where project impacts were “perhaps less direct but no less certain to occur”). This kind of closed loop, circular reasoning is inappropriate when addressing the impacts of a massive fossil fuel project. 2d 1196, 1212 (D.