Stop logging 729 acres in Osceola National Forest

Each issue against the decision, unreviewed

• PLAN’s match, not yet checked by a personThe EA acknowledges that wildlife and fisheries field visits were explicitly deferred until after the decision, yet a FONSI is signed now.

  The EA acknowledges that wildlife and fisheries field visits were explicitly deferred until after the decision, yet a FONSI is signed now.

  Table 2 states that field visits for both Wildlife and Cultural/Heritage resources are 'needed post-decision but pre-implementation.' Signing a FONSI before the field data exist means the no-significant-impact determination rests on incomplete information. The agency should rescind the FONSI, complete the required field surveys, and then re-analyze effects before making any final decision.

  A hole PLAN found in the agency’s own analysis

  “Field Visit: Field visit needed post-decision but pre-implementation and environmental review can be completed. Estimated Total # of Days to Complete Work: <2”

  The agency’s own words, 20260722_Blue MoonFinal_FONSI_signed ↗, Table 2: Documentation of Subject Matter Expert review completion · PLAN’s match, unchecked, an answer in part

• PLAN’s match, not yet checked by a personThe document gives a 'may affect, likely to adversely affect' determination for the tricolored bat, a proposed threatened species, yet the only mitigation listed is to 'protect any known bat roost trees.' No survey for roost trees is required before operations begin, and the field visit for wildlife is deferred until after the decision.

  The document gives a 'may affect, likely to adversely affect' determination for the tricolored bat, a proposed threatened species, yet the only mitigation listed is to 'protect any known bat roost trees.' No survey for roost trees is required before operations begin, and the field visit for wildlife is deferred until after the decision.

  Table 3 states 'it's possible that tricolored bats could be harassed or killed during implementation,' but the EA does not disclose what formal Section 7 consultation outcome, if any, has been reached with USFWS. The agency should produce and disclose the completed Biological Assessment, confirm USFWS concurrence or a formal jeopardy/no-jeopardy determination, and not implement until that record is public.

  A hole PLAN found in the agency’s own analysis

  “While the likelihood is low, it's possible that tricolored bats could be harassed or killed during implementation of the proposed action.”

  The agency’s own words, 20260722_Blue MoonFinal_FONSI_signed ↗, Table 3: May Affect, Likely to Adversely Affect Determination for TEPC Species/Critical Habitat · PLAN’s match, unchecked, an answer in part

• PLAN’s match, not yet checked by a personThe Botany review in Table 2 records zero days of work and no field visit, yet six sensitive plant species are documented on the Osceola National Forest (Table 7) in habitats that overlap directly with the proposed treatment areas—wet flatwoods and mesic flatwoods.

  The Botany review in Table 2 records zero days of work and no field visit, yet six sensitive plant species are documented on the Osceola National Forest (Table 7) in habitats that overlap directly with the proposed treatment areas—wet flatwoods and mesic flatwoods.

  The EA states 'no sensitive plants that are found in the forest have been observed in the project area,' but this conclusion is based on a desk review with no field verification. For a 729-acre project with documented sensitive plant habitat, this is an unreasoned leap. The agency should require a field botanical survey before implementation and disclose its results.

  A hole PLAN found in the agency’s own analysis

  “No sensitive plants that are found in the forest have been observed in the project area.”

  The agency’s own words, 20260722_Blue MoonFinal_FONSI_signed ↗, Sensitive Species · PLAN’s match, unchecked, an answer in part

• PLAN’s match, not yet checked by a personThe IDT screening states the Fisheries review required zero days and no field visit, yet the project area contains perennial and intermittent streams in a region where Gulf sturgeon, a federally listed species, uses connected waterways.

  The IDT screening states the Fisheries review required zero days and no field visit, yet the project area contains perennial and intermittent streams in a region where Gulf sturgeon, a federally listed species, uses connected waterways.

  The ESA section separately notes Gulf sturgeon warrants no long-term benefit because of its aquatic habitat. Conducting no fisheries fieldwork while road reconstruction is planned near streams, and while elevated phosphate and nitrate levels from harvest are acknowledged as risks, is an internal contradiction the EA does not resolve. The agency should require a fisheries field assessment and disclose results before approving road reconstruction near waterways.

  A hole PLAN found in the agency’s own analysis

  “All species, excluding Suwannee alligator snapping turtle and Gulf sturgeon, due to their aquatic habitats, should experience beneficial effects in the long term as ecological conditions more closely approach historical norms”

  The agency’s own words, 20260722_Blue MoonFinal_FONSI_signed ↗, Endangered Species Act · PLAN’s match, unchecked, an answer in part

• PLAN’s match, not yet checked by a personThe Cultural and Heritage section states that archaeological field surveys were completed and no National Register eligible sites were found, but Table 2 also notes the field visit is 'needed post-decision but pre-implementation.' This contradiction leaves open whether the Section 106 'no historic properties affected' determination is based on completed surveys or a desk review.

  The Cultural and Heritage section states that archaeological field surveys were completed and no National Register eligible sites were found, but Table 2 also notes the field visit is 'needed post-decision but pre-implementation.' This contradiction leaves open whether the Section 106 'no historic properties affected' determination is based on completed surveys or a desk review.

  Four tribal nations were consulted, making this ambiguity especially significant. The agency should clarify what physical survey work has actually been completed, release the survey report, and confirm SHPO concurrence before implementation begins.

  A hole PLAN found in the agency’s own analysis

  “Section 106 Review has been completed for the project area and no National Register eligible cultural sites were found.”

  The agency’s own words, 20260722_Blue MoonFinal_FONSI_signed ↗, National Historic Preservation Act – Section 106 Review · PLAN’s match, unchecked, an answer in part