Each issue against the decision, unreviewed

• PLAN’s match, not yet checked by a personThe EA describes a 7.4-to-1 acreage exchange but defers all appraisals until after the NEPA analysis closes.

  The EA describes a 7.4-to-1 acreage exchange but defers all appraisals until after the NEPA analysis closes.

  Section 2.1 states that market value will be determined by appraisals prepared before the Final Decision Notice, meaning the agency's entire environmental review evaluates a proposed action whose equal-value basis — required by FLPMA Section 206 — has never been demonstrated to the public. No value comparison appears anywhere in the document. The agency should complete and publicly disclose all appraisals before the comment period closes and include the equal-value finding in the NEPA record as a prerequisite to selecting any action.

  A hole PLAN found in the agency’s own analysis

  “The exchange will be based on equal market value rather than equal acreage, with values established through appraisals conducted in accordance with federal regulations and professional appraisal standards.”

  The agency’s own words, 20260710_Summary EA _FONSI_Final_remediated ↗, Proposed Action: What are we proposing to do? · PLAN’s match, unchecked, an answer in part

• PLAN found no answer, not yet checked by a personSection 3.5.2 explicitly admits that after the exchange USFS surface management stipulations on the federal parcels will be eliminated, even though the United States retains the federal mineral estate and mining is expected to continue under BLM leases.

  Section 3.5.2 explicitly admits that after the exchange USFS surface management stipulations on the federal parcels will be eliminated, even though the United States retains the federal mineral estate and mining is expected to continue under BLM leases.

  The EA never identifies what specific USFS stipulations currently govern surface disturbance on these parcels, what resource values they protect, or how BLM leasing requirements provide equivalent protection. Stripping the agency's own surface oversight layer without analyzing the resulting gap is an unreasoned conclusion. The agency should catalog every current USFS stipulation on the outgoing parcels and analyze the environmental consequences of each one's removal.

  A hole PLAN found in the agency’s own analysis

• PLAN’s match, not yet checked by a personSection 2.2 dismisses the only alternative to the proposed action — direct purchase of the private parcels — in a single sentence stating that DRRC refuses to sell.

  Section 2.2 dismisses the only alternative to the proposed action — direct purchase of the private parcels — in a single sentence stating that DRRC refuses to sell.

  NEPA requires the agency to independently evaluate alternatives based on their potential to achieve the purpose and need; allowing the proponent's refusal to substitute for independent analysis is not a reasoned basis for elimination. The agency should prepare an EIS that independently evaluates direct purchase of PRV1 and PRV2, including an analysis of whether fee simple acquisition is practicable under USFS land acquisition authority, without deferring to DRRC's stated preference.

  A hole PLAN found in the agency’s own analysis

  “The USFS considered direct purchase of the non-federal lands from DRRC, as required by USFS policy (FSH 5409.13). However, this alternative was eliminated because DRRC will only consider conveying these parcels through a land exchange, making a direct purchase infeasible.”

  The agency’s own words, 20260710_Summary EA _FONSI_Final_remediated ↗, Alternatives to the Proposed Action: Are there other ways to meet the purpose and need? · PLAN’s match, unchecked, an answer in part

• PLAN’s match, not yet checked by a personAppendix B documents in a footnote that designated critical habitat for the federally endangered spectaclecase mussel overlaps with incoming parcel PRV2.

  Appendix B documents in a footnote that designated critical habitat for the federally endangered spectaclecase mussel overlaps with incoming parcel PRV2.

  No analysis of this species or its critical habitat appears anywhere in Section 3.7's effects analysis, and the USFWS Section 7 concurrence letter in Appendix D does not mention the spectaclecase mussel at all. Acquiring federal land within a designated critical habitat area for a listed species is a federal action that triggers formal Section 7 consultation. The agency should initiate and complete formal ESA Section 7 consultation with USFWS specifically addressing spectaclecase mussel critical habitat on PRV2 before issuing a decision.

  A hole PLAN found in the agency’s own analysis

  “The spectaclecase mussel (Cumberlandia monodonta) was evaluated in the EA but not included in the BA. However, it received the same no effect determination as the salamander mussel based on similar habitat considerations and avoidance of instream impacts.”

  The agency’s own words, 20260710_Summary EA _FONSI_Final_remediated ↗, Endangered Species Act · PLAN’s match, unchecked

• PLAN found no answer, not yet checked by a personThe Phase I ESA in Appendix E identifies seven Recognized Environmental Conditions (RECs) involving lead concentrations that exceed USEPA screening levels on federal parcels being conveyed, including lead up to 20,400 mg/kg on FED7 — 25 times the industrial RSL of 800 mg/kg — and lead up to 17,700 mg/kg on FED10.

  The Phase I ESA in Appendix E identifies seven Recognized Environmental Conditions (RECs) involving lead concentrations that exceed USEPA screening levels on federal parcels being conveyed, including lead up to 20,400 mg/kg on FED7 — 25 times the industrial RSL of 800 mg/kg — and lead up to 17,700 mg/kg on FED10.

  Section 3.12.2 disposes of all seven RECs by stating that cleanup would be handled by DRRC after conveyance, with no deed restriction, cleanup covenant, or enforceable remedial schedule described anywhere in the document. The agency should identify and document binding cleanup obligations as express conditions of the exchange deed for all seven REC parcels before any transfer is finalized.

  A hole PLAN found in the agency’s own analysis