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Federal agencies may, and sometimes do, permit persons to intervene in administrative proceedings even though these persons would not have standing to challenge the agency's final action in federal court. Agencies, of course, are not constrained by Article III of the Constitution; nor are they governed by judicially-created standing doctrines restricting access to the federal courts. The criteria for establishing 'administrative standing' therefore may permissibly be less demanding than the criteria for 'judicial standing.' See, e.g., Pittsburgh & W.Va. Ry. v. United States, 281 U.S. 479, 486 (1930); Alexander Sprunt & Son, Inc. v. United States, 281 U.S. 249, 255 (1930); Henry J. Friendly, Federal Jurisdiction: A General View 118 (1973). As Judge Friendly observed: The need for a 'case or controversy' to seek judicial review but not to intervene in an administrative hearing; the differences between statutes and agency rules controlling intervention and statutes controlling judicial review; and the differing characters of administrative and judicial proceedings--all of these negate any general rule linking a person's standing to seek judicial review to the fact that he has been allowed to intervene before the agency. Id. (citing 3 Kenneth Culp Davis, Administrative Law Treatise § 22.08, at 241.

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