Each issue against the decision, unreviewed

• PLAN found no answer, not yet checked by a personTable 7 dismisses climate change effects by noting the line's voltage will not change, as if that settles the question.

  Table 7 dismisses climate change effects by noting the line's voltage will not change, as if that settles the question.

  Unchanged voltage says nothing about the greenhouse gas emissions from two construction seasons of heavy equipment, helicopter flights, up to 20 vehicle trips per pole site, and vegetation removal across 45 miles. The agencies should analyze construction-related emissions directly instead of relying on the unrelated fact that line voltage is unchanged.

  A hole PLAN found in the agency’s own analysis

• PLAN found no answer, not yet checked by a personThe EA's own Section 106 review contradicts itself.

  The EA's own Section 106 review contradicts itself.

  It first states the Class III survey found no adverse effects to historic properties, then two sentences later concludes the project would have adverse effects on National Register-eligible sites, including nine historic properties on BLM land such as the NRHP-listed Hayden Ranch. The document also admits SHPO review 'will be completed prior to project approval,' meaning Section 106 consultation is not finished as the agencies move toward a Finding of No Significant Impact. The agencies should resolve this contradiction, complete SHPO consultation before signing any decision, and explain how acknowledged adverse effects on historic properties square with a finding of no significant impact.

  A hole PLAN found in the agency’s own analysis

• PLAN’s match, not yet checked by a personFor Canada lynx, a threatened species given a 'may affect, not likely to adversely affect' call in Table 14, the EA provides no independent effects analysis in the document the public is being asked to comment on.

  For Canada lynx, a threatened species given a 'may affect, not likely to adversely affect' call in Table 14, the EA provides no independent effects analysis in the document the public is being asked to comment on.

  It simply defers to an unreleased Biological Assessment. The public cannot evaluate the basis for the determination. The agencies should incorporate the lynx analysis directly into the EA or release the Biological Assessment for concurrent public review.

  A hole PLAN found in the agency’s own analysis

  “Canada Lynx was fully analyzed for the project (see DEA pages 42-43). Since the species is protected under the Endangered Species Act, Section 7 consultation with the USFWS was completed. USFWS issued their concurrence letter on May 15, 2026, supporting the project, as proposed, may affect, but is not likely to adversely affect the federally threatened Canada lynx”

  The agency’s own words, Appendix L_CommentResponse ↗ · PLAN’s match, unchecked

• PLAN found no answer, not yet checked by a personTribal consultation letters went out in April 2025 and again in June 2026, but the EA states plainly that no tribes have responded and consultation is still ongoing at the time of publication.

  Tribal consultation letters went out in April 2025 and again in June 2026, but the EA states plainly that no tribes have responded and consultation is still ongoing at the time of publication.

  Moving toward a decision before tribes have had the chance to weigh in skips a legally required step, not just a formality. The agencies should hold the decision until tribal consultation is actually complete and document any tribal input in the final record.

  A hole PLAN found in the agency’s own analysis

• PLAN found no answer, not yet checked by a personThe Water Resources section reports 21.5 acres of temporary wetland and stream impacts for 9254/9257 alone, plus 12.4 more acres for 9255, roughly 34 acres combined, yet the Clean Water Act compliance discussion frames the project almost entirely around a 0.22-acre permanent-impact figure used to qualify for streamlined Nationwide Permit 3 self-certification.

  The Water Resources section reports 21.5 acres of temporary wetland and stream impacts for 9254/9257 alone, plus 12.4 more acres for 9255, roughly 34 acres combined, yet the Clean Water Act compliance discussion frames the project almost entirely around a 0.22-acre permanent-impact figure used to qualify for streamlined Nationwide Permit 3 self-certification.

  A footprint over 150 times larger than the number driving the permitting pathway deserves its own significance discussion. The agencies should analyze the 34 acres of temporary wetland and stream disturbance as a standalone impact rather than letting the much smaller permanent total carry the permitting and significance conclusions.

  A hole PLAN found in the agency’s own analysis