Yesler asserts that it was injured when HUD, without following notice and comment rulemaking procedures, determined *446that Washington PHAs can' dispense with grievance hearings in crime-related evictions. There is no question that a “procedural injury” can constitute an injury in fact for the purpose of establishing standing. See Defenders, — U.S. at-n. 7, 112 S.Ct. at 2142 n. 7;- Dellums v. Smith, 797 F.2d 817, 821 (9th Cir.1986). However, not every procedural injury will do. To have standing,, a plaintiff must be seeking “to enforce a procedural requirement the disregard of which could impair a separate concrete interest.” Defenders, — U.S. at -, 112 S.Ct. at 2142; see also Salmon River Concerned Citizens v. Robertson, 32 F.3d 1346, - (9th Cir.1994). Thus the Court opined in Defenders that someone living next door to the site of a proposed federally licensed dam would have standing to challenge the licensing agency’s failure to prepare an environmental impact statement, whereas someone living across the country from the proposed dam would not have standing. Id. at-, 112 S.Ct. at 2142 n. 7; see also Pacific Northwest Generating Coop v. Brown, 25 F.3d 1443, 1449 (9th Cir.1994) (plaintiffs whose way of conducting business may be affected by agencies’ failures to comply with Endangered Species Act “can be compared to the person living next to the proposed dam”); City of Davis v. Coleman, 521 F.2d 661, 670-71 (9th Cir.1975) (“The procedural injury implicit in agency failure to prepare an EIS — the creation of a risk that serious environmental impact will be overlooked — is itself a sufficient ‘injury in fact’ to support standing, provided this injury is alleged by a plaintiff having a sufficient geographical nexus to the site of the challenged project.”).