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Rh Lemon v. Geren, 514 F. 3d 1312, 1314–1315 (CADC 2008). But they must still show—pursuant to our customary traceability standards—that the Plan’s substance causes their injury by impairing loan relief under the HEA.

Brown and Taylor cannot meet this standard. “It is purely speculative whether the denia[l]” of HEA loan relief—their ostensible injury—“fairly can be traced to” the Department’s decision to grant loan relief in the Plan. Simon v. ''Eastern Ky. Welfare Rights Organization, 426 U. S. 26, 42–43 (1976); see also Warth v. Seldin'', 422 U. S. 490, 503–504 (1975).

As noted above, HEROES Act loan relief and HEA loan relief function independently of each other. If the Department may lawfully grant loan relief under both the HEROES Act and the HEA, it is entitled to choose to do both, neither, or only one (provided that it sufficiently explains its reasoning, see 5 U. S. C. §706(2)(A)). There is little reason to think that its discretionary decision to pursue one mechanism of loan relief has anything to do with its discretionary decision to pursue (or not pursue) another. “The line of causation between” the Department’s promulgation of the Plan and respondents’ lack of benefits under the HEA “is attenuated at best,” Allen, 468 U. S., at 757, and all too dependent on “ ‘conjecture,’ ” Summers, 555 U. S., at 496.

Respondents’ attempts to tie the Plan to potential HEA relief are unavailing. They point to a handful of documents related to the Plan that say that the Department is providing “one-time” student-loan relief. See, e.g., App. 215, 221, 225. Such statements, Brown and Taylor argue, show that the decision to grant loan relief under the HEROES Act foreclosed HEA relief.

This is insufficient. The Plan itself—the action under review here—contains no reference to “one-time” relief. See