In Mountain States Legal Found. v. Glickman, 92 F.3d 1228 (1996), an all-conservative panel of the D.C. Circuit found standing by nonprofit groups, lumber companies, and municipalities to challenge a federal agency (Forest Service) decision to allow timber to remain in place which the plaintiffs said "poses an unnecessarily high risk of catastrophic wildfire, endangering the grizzly bear, the forest itself, and people living nearby." Id. at 1232. Plaintiffs also asserted that the plan chosen by the Forest Service unfairly preferred grizzly bears over people.
The D.C. Circuit held that standing existed for these claims because devastating forest fires has a statistical probability that could be challenged. But then the Court held against plaintiffs on the substantive merits.