Does the Secretary of State for Environment, Environment, Food and Rural Affairs have the authority to deny appellants' claim that the impact upon the food chain and its consequences were speculative?

The Secretary argues that appellants' allegations regarding the impact upon the food chain and its consequences were speculative. But it is well established that plaintiffs need only allege facts that raise a substantial question of detrimental impact upon the environment to successfully challenge an Assessment; they need not prove such an impact. As we recently said in Save the Yaak Comm. v. Block, No. 86-3808, slip op. at 5321 (9th Cir. May 11, 1988), amending 840 F.2d 714, 717-8 (quoting Steamboaters v. F.E.R.C., 759 F.2d 1382, 1393 (9th Cir.1985)):