Each issue against the decision, unreviewed

• PLAN’s match, not yet checked by a personThe agency admits that soil disturbance monitoring has not occurred recently in the project area, meaning there is no current baseline data on existing detrimental soil disturbance, yet the EA still concludes that combined past and proposed activities will not approach the Forest Plan's 15 percent detrimental disturbance threshold.

  The agency admits that soil disturbance monitoring has not occurred recently in the project area, meaning there is no current baseline data on existing detrimental soil disturbance, yet the EA still concludes that combined past and proposed activities will not approach the Forest Plan's 15 percent detrimental disturbance threshold.

  The agency should conduct current soil disturbance monitoring before finalizing this determination or explain what data actually supports the no-threshold-exceedance conclusion in the absence of recent monitoring.

  A hole PLAN found in the agency’s own analysis

  “Because the proposed action includes design criteria protecting soil health and would be implemented consistent with Forest Plan standards and best management practices, it would not result in loss of long-term soil productivity or exceed regulatory thresholds.”

  The agency’s own words, RobyEA-FONSI-Final-Signed ↗, Soil Productivity · PLAN’s match, unchecked

• PLAN’s match, not yet checked by a personThe agency's own Table 22 shows that habitat structural stages 4A and 4B, which together make up the majority of pine acreage in both Management Areas 5.1 and 5.4, would move further away from Forest Plan objectives under the proposed action, not closer, directly undercutting the EA's narrative that the project produces broadly beneficial structural outcomes.

  The agency's own Table 22 shows that habitat structural stages 4A and 4B, which together make up the majority of pine acreage in both Management Areas 5.1 and 5.4, would move further away from Forest Plan objectives under the proposed action, not closer, directly undercutting the EA's narrative that the project produces broadly beneficial structural outcomes.

  The agency should directly reconcile this admitted divergence from Forest Plan objectives with its overall beneficial-effects conclusion and disclose whether the project is consistent with the Forest Plan's structural stage direction.

  A hole PLAN found in the agency’s own analysis

  “The proposed action would cause most structural stages to move toward objectives or result in no change. The following stages would move further from objectives: • 2, 3A, and 3B (in Management Area MA 5.1) • 4A and 4B (in both Management Areas)”

  The agency’s own words, RobyEA-FONSI-Final-Signed ↗, Forest Structure · PLAN’s match, unchecked, an answer in part

• PLAN’s match, not yet checked by a personThe biological assessment reaches a 'may affect, likely to adversely affect' determination for the northern long-eared bat, a federally threatened species, citing potential loss of roost trees, alteration of roost areas, and disruption of hibernation, yet the EA proceeds toward a finding of no significant impact without a detailed public discussion of how this adverse determination squares with that conclusion.

  The biological assessment reaches a 'may affect, likely to adversely affect' determination for the northern long-eared bat, a federally threatened species, citing potential loss of roost trees, alteration of roost areas, and disruption of hibernation, yet the EA proceeds toward a finding of no significant impact without a detailed public discussion of how this adverse determination squares with that conclusion.

  The agency should disclose the full biological opinion analysis and explain how a likely-adverse-effect finding for a threatened species is consistent with a finding of no significant impact.

  A hole PLAN found in the agency’s own analysis

  “On June 9, 2026, the Forest Service requested Endangered Species Act section 7 consultation using expedited procedures. Section 7 implementing regulations include a consultation process to address emergencies and the need to consult on discretionary federal actions in an expedited manner (50 CFR 402.05).”

  The agency’s own words, RobyEA-FONSI-Final-Signed ↗, Endangered Species Act · PLAN’s match, unchecked, an answer in part

• PLAN’s match, not yet checked by a personThe agency's own weed analysis projects that under the proposed action, priority weed infestation could expand at up to 14 percent per year compared with 8 percent under no action, and non-priority weed species could reach as many as 4,400 acres, yet the EA concludes this is outweighed by fire-hazard benefits without quantifying the ecological cost of a potential 4,400-acre weed footprint.

  The agency's own weed analysis projects that under the proposed action, priority weed infestation could expand at up to 14 percent per year compared with 8 percent under no action, and non-priority weed species could reach as many as 4,400 acres, yet the EA concludes this is outweighed by fire-hazard benefits without quantifying the ecological cost of a potential 4,400-acre weed footprint.

  The agency should analyze the 4,400-acre non-priority weed projection in the same detail given to fire hazard and disclose monitoring commitments to verify it does not occur.

  A hole PLAN found in the agency’s own analysis

  “Non-priority species could increase to as many as 4,400 acres. While any increase in weed infestation is undesirable, the proposed action may also prevent much larger infestations in the future that could occur following severe wildfire.”

  The agency’s own words, RobyEA-FONSI-Final-Signed ↗, Non-native Invasive Plants · PLAN’s match, unchecked, an answer in part

• PLAN’s match, not yet checked by a personOutside the four known active goshawk nest area stands, which receive no commercial harvest, the agency's own wildlife analysis states that the proposed action would further decrease potential nesting habitat and retain few stands that could provide near-future habitat if existing habitat is lost, and that this could result in displacement of goshawks or reduced breeding success.

  Outside the four known active goshawk nest area stands, which receive no commercial harvest, the agency's own wildlife analysis states that the proposed action would further decrease potential nesting habitat and retain few stands that could provide near-future habitat if existing habitat is lost, and that this could result in displacement of goshawks or reduced breeding success.

  The agency should analyze the cumulative effect of this habitat reduction on goshawk population viability across the project area rather than limiting mitigation to currently known, already-active territories.

  A hole PLAN found in the agency’s own analysis

  “Outside of the known, existing nest area stands, the proposed action would further decrease potential nesting habitat and retain few stands that could provide near-future preferred habitat in the event of loss of existing habitat. This could result in displacement of goshawks or reduced breeding success.”

  The agency’s own words, RobyEA-FONSI-Final-Signed ↗, Wildlife Species and Habitat · PLAN’s match, unchecked, an answer in part