Each issue against the decision, unreviewed

• PLAN’s match, not yet checked by a personThe notice identifies the project location only as 'approximately 23 miles WSW of Hawthorne, NV' and names no watersheds, drainages, sensitive species habitats, or proximity to water sources.

  The notice identifies the project location only as 'approximately 23 miles WSW of Hawthorne, NV' and names no watersheds, drainages, sensitive species habitats, or proximity to water sources.

  Without this information, the public cannot assess impacts to water quality, wildlife corridors, or cultural resources during the comment period. The agency should release a project map and resource overview before the comment deadline so the public can submit meaningful comments.

  A hole PLAN found in the agency’s own notice

  “A hydrologic investigation area (HIA) including the Project area and a one-mile buffer was used to characterize potentially affected surface and groundwater resources. The HIA straddles two Nevada Division of Water Resources hydrographic areas: the East Walker Basin (109) and the Alkali Valley Basin Southern Part (111B).”

  The agency’s own words, Burnt Rock Final EA and Appendices - 20260720_508 ↗, Water Resources · PLAN’s match, unchecked

• PLAN’s match, not yet checked by a personThe notice identifies the Lead Management Unit as the Bridgeport Ranger District but provides a contact address in Bridgeport, California, while the project is located in Mineral County, Nevada.

  The notice identifies the Lead Management Unit as the Bridgeport Ranger District but provides a contact address in Bridgeport, California, while the project is located in Mineral County, Nevada.

  No cooperating agencies, no state agency partners, and no county involvement are mentioned. For a 250-acre disturbance project in Nevada, the agency should disclose whether Nevada Division of Environmental Protection, Nevada Department of Wildlife, or Mineral County have been invited as cooperating agencies in the EA.

  A hole PLAN found in the agency’s own notice

  “Given the nature of the proposal, the responsible official consulted the following parties: Nevada Department of Wildlife, Nevada Division of Natural Heritage, Nevada State Clearinghouse, Bureau of Mining Regulation and Reclamation, United States Fish and Wildlife Service, Mineral County”

  The agency’s own words, Burnt Rock Final EA and Appendices - 20260720_508 ↗, Agencies and Persons Consulted · PLAN’s match, unchecked, an answer in part

• PLAN’s match, not yet checked by a personThe notice states the project proposes 'approximately 266 drill sites' in the first phase and 'up to 334 additional drill sites' in subsequent phases, but provides no analysis, timeline, triggers, or decision criteria for those subsequent phases.

  The notice states the project proposes 'approximately 266 drill sites' in the first phase and 'up to 334 additional drill sites' in subsequent phases, but provides no analysis, timeline, triggers, or decision criteria for those subsequent phases.

  Treating phases separately can artificially shrink the apparent footprint to avoid an EIS, a classic improper segmentation problem under NEPA. The agency should explain in the EA how it will ensure the subsequent 334 sites are analyzed as a connected action rather than deferred to avoid cumulative-impact review.

  A hole PLAN found in the agency’s own notice

  “The Proposed Action would result in up to 250 acres of surface disturbance within the Project area over the 10-year life of the Project. The Proposed Action would initially disturb 121 acres with the drilling results informing the location of future disturbance within the Project area.”

  The agency’s own words, Burnt Rock Final EA and Appendices - 20260720_508 ↗, General Wildlife · PLAN’s match, unchecked, an answer in part

• PLAN’s match, not yet checked by a personThe notice caps total disturbance at '250 acres on NFS lands' but gives no basis for how that ceiling was calculated, whether it includes access roads and staging areas, or whether the subsequent 334 sites are included within that figure.

  The notice caps total disturbance at '250 acres on NFS lands' but gives no basis for how that ceiling was calculated, whether it includes access roads and staging areas, or whether the subsequent 334 sites are included within that figure.

  If the cap covers only the first phase, the real footprint could be far larger. The agency should clarify in the EA exactly what activities and infrastructure are counted toward the 250-acre limit and whether subsequent phases are inside or outside that cap.

  A hole PLAN found in the agency’s own notice

  “with the total disturbance of the Project not to exceed 250 acres for the life of the Project, including a maximum of 600 drill pads, eight laydown areas, and 45 miles of new temporary road.”

  The agency’s own words, Burnt Rock Final EA and Appendices - 20260720_508 ↗, Proposed Action: What are we proposing to do? · PLAN’s match, unchecked

• PLAN’s match, not yet checked by a personThe notice names no tribes, lists no consultation status, and provides no information about cultural resources or sacred sites in the project area, despite the project being located in Nevada on Humboldt-Toiyabe National Forest lands with documented Indigenous presence in the region.

  The notice names no tribes, lists no consultation status, and provides no information about cultural resources or sacred sites in the project area, despite the project being located in Nevada on Humboldt-Toiyabe National Forest lands with documented Indigenous presence in the region.

  The agency should disclose the status of government-to-government consultation and any Section 106 undertaking review before the EA is released for comment.

  A hole PLAN found in the agency’s own notice

  “Consultation was initiated in November 2025 with early notification to the following Tribes: Benton Paiute Tribe, Bridgeport Indian Colony, Coleville Paiute Tribe, Mono Lake Kutzadika'a Tribe, Pyramid Lake Paiute Tribe, Reno Sparks Indian Colony, Tuolumne Band of Me-Wuk Indians, Walker River Paiute Tribe, Washoe Tribe of Nevada and California, and Yerington Paiute Tribe.”

  The agency’s own words, Burnt Rock Final EA and Appendices - 20260720_508 ↗, Consultation with Federally Recognized Tribes · PLAN’s match, unchecked