3“timeliness, interest, impairment of interest, and adequacy of representation”—andHARDI also “possess[es] standing under Article III of the Constitution.”
Jones v. Prince George’s County
, 348 F.3d 1014, 1017 (D.C. Cir. 2003) (citing
Fund for Animals, Inc. v. Norton
, 322 F.3d 728, 731-32 (D.C. Cir. 2003);
City of Cleveland v. Nuclear Regulatory Comm’n
, 17 F.3d 1515, 1517 (D.C. Cir. 1994)).
HARDI Has Standing To Intervene.
Because HARDI will be adversely affected by the direct final rule, it hasstanding to intervene in an action initiated to review that rule, where, as here,applicable standing requirements are also met. Under the Energy Policy andConservation Act of 1975 (“EPCA”), “[a]ny person who will be adversely affected by a rule . . . may . . . file a petition with the United States court of appeals . . . for judicial review of such rule.” 42 U.S.C. § 6306(b)(1). As this Court noted in
In reCenter for Auto Safety
, where an injury is present, “standing to petition for reviewof . . . standards under EPCA extends to the full limits permitted by Article III,”and thus it is unnecessary to “pursue an inquiry into the prudential requirements for standing.” 793 F.2d 1346, 1351 (D.C. Cir. 1986);
see, e.g., Ctr. for Auto Safety v. Nat’l Highway Traffic Safety Admin
., 793 F.2d 1322, 1330 (D.C. Cir. 1986) (“The petitioners plainly satisfy the Article III prerequisites for standing and Congress, inenacting EPCA, has removed any reason to invoke the restraints on judicial review provided by the prudential principles of the standing doctrine.”).