She further discusses proximate causation," which introduce notions of foreseeability." 'Harm' applies to significant habitat modification, which foreseeably causes the actual injury or death to the red cockaded woodpecker and northern spotted owl protected under the ESA.
His favourable attitude toward a possible loan for a hydroelectric project to be made through the Federation of Rhodesia and Nyasaland (opposition to which was the proximate cause, many would say, for the independence movement in Nyasaland) reportedly caused Banda to become extremely annoyed.