Stop NPS from permanently closing five Playalinda beach parking lots to cars
Canaveral National Seashore, Playalinda District Storm Adaptive Management Plan
National Park Service· Canaveral National Seashore, Playalinda Beach DistrictNPS Planning (PEPC) project page ↗
NPS PEPCWe track this on the agency’s own system of record, where most on-the-ground decisions live.
The groups on this fight
4 groups predicted likely to care in Florida
Predicted likely to care is a guess from footprint in Florida, by the same match the STAND matchmaker runs, with no link to this decision. Give straight to them; nothing routes through us.
- Everglades Foundation
Predicted likely to care · a guess
Works Florida: the science and restoration muscle behind Everglades protection.
- Friends of the Everglades
Predicted likely to care · a guess
Works Florida: founded by Marjory Stoneman Douglas to defend the River of Grass.
- National Parks Conservation Association
Predicted likely to care · a guess
Works Florida: sued Interior in 2020 and won the March 2024 ruling ordering the Park Service to propose the regulation for Biscayne's long-promised marine reserve zone.
- National Wildlife Federation
Predicted likely to care · a guess
Works Florida: co-plaintiff defending Gulf park wildlife, from sea turtles to the Rice's whale, in the God Squad suit.
Every group above is on STAND for Public Lands, with its court record, its filings and who backs it.
The plan lets NPS spend repair costs up to 150% of a road or parking lot's total replacement value over 20 years before permanently closing it to vehicles and converting it to a pedestrian trail.
What’s at risk
Vehicle access to Parking Lots 9 through 13 and the road serving them is on the table for permanent closure under the plan's Long-Range Scenario, cutting off drive-in access to part of the park's 24 miles of undeveloped beach. The park hosts 10,000 to 18,000 sea turtle nests a year, and Mosquito Lagoon wetlands depend on sand washover that the plan's own analysis says continued sand clearing and dune nourishment will disrupt. Flood days at the nearby gauge have already roughly quadrupled from about 3 a year to about 12 a year between the last two decades.
If this goes through
The decision launches a 20-year adaptive management framework in which NPS keeps repairing roads and parking lots north of Parking Lot 8 until cumulative repair costs exceed 150% of their total replacement value, at which point they close to public vehicles for good. Near-term construction would disturb up to 6.5 acres around parking lots for drainage work and replace all restrooms and dune crossings at Lots 8 through 13. The plan does not set a special event capacity for the more than 50 rocket launches held in 2026, even though launch frequency is expected to keep increasing.
Our plain-English read of the official notice ↗. Check it against the agency’s own words below.
By the numbers, from the agency’s own document
- Repeat-repair spending allowed before road/lot closes
- Up to 150% of replacement value over 20 years
- Proposed visitor capacity, Parking Lots 1-8
- 2,200 people at one time
- Annual flood days, past decade vs prior decade
- ~12/year (2016-2025) vs ~3/year (2006-2015)
- Shoreline erosion after Hurricanes Ian and Nicole
- -63.3 to -115.5 feet in one season
- Ground disturbed for parking lot drainage work
- Up to 6.5 acres
- Sea turtle nests laid annually in the park
- 10,000 to 18,000 nests per year
Storm Damage Response
Open the document ↗“divestment would be triggered when cumulative costs exceed 150% of the system's total CRV”
Shoreline Dynamics
Open the document ↗“experienced approximately 12 flood days per year on average, compared to the previous decade (meteorological years 2006-2015), which averaged approximately 3 flood days per year”
Shoreline Dynamics
Open the document ↗“shoreline erosion rates between -63.3 feet and -115.5 feet, with an uncertainty of ± 32.8 feet”
Parking Lots
Open the document ↗“These improvements would disturb up to 6.5 acres in scattered patches adjacent to the parking lots along the length of the Playalinda District”
Sea Turtles
Open the document ↗“with up to 10,000 to 18,000 nests being deposited on the 24 miles of undeveloped shoreline each year”
Each figure is checked word for word against the decision document ↗; open a label to read the sentence it comes from and the document it’s in.
The agency’s case, tested
What the agency argues, and whether its own record backs it
- 2
- Hold up
- 5
- No support given
- 1
- Never analyzed
The National Park Service wants to adopt a storm adaptive management plan for the Playalinda District. The plan would update drainage, restrooms, boardwalks and the entrance station, and set repair-cost triggers for permanently closing the road and parking lots north of Parking Lot 8 to public vehicles. The agency says storm-lowered dunes now let overwash flood and bury the road, closing areas for weeks to months.
“The purpose of the plan is to provide resilient strategies for the management of infrastructure and sand for the Playalinda District while continuing to provide meaningful visitor experiences and protecting park resources.”
Purpose of and Need for Action
Alternatives
No support given
Permanently raising or realigning the road, including on a low bridge, was rightly dismissed as economically infeasible.
For the berm option, Appendix B gives a reason besides cost. Filling wetlands would require restoration to offset it, and the National Park Service says it has no qualifying restoration opportunities. The engineered dune analysis also shows that shifting infrastructure westward would disturb about 33 acres and fill about 5 acres of wetlands. The low bridge, though, is dismissed on cost alone, and the document says it may let natural processes continue underneath. No cost estimate is given for either option, or for the repeated repairs and sand clearing under Alternative B, so the economic infeasibility finding can't be checked.
The agency’s words, the record and the law +Hide the words
The agency says
“Both options would require substantial funding; therefore, these alternatives were considered but dismissed as economically infeasible.”
Raise and Realign the Road
Elsewhere in the same document
“Raising the road on a low bridge may also have some wetland impacts, though it may allow for more natural barrier island processes to continue underneath.”
Raise and Realign the Road
The law
“consistent with the provisions of this chapter, study, develop, and describe technically and economically feasible alternatives;” National Environmental Policy Act, 42 U.S.C. 4332(2)(F) ↗
Effects
No support given
Seasonal limits keep sand fencing and construction effects on nesting sea turtles minor enough to support a not-likely-to-adversely-affect finding for four species.
The document says fencing would keep turtles off the overwashed road, where about 30 nesting females and hundreds of hatchlings were rescued in 2025. It also says construction would avoid nesting season, and that an adverse impact under NEPA may differ from an adverse effect under Section 7, which allows insignificant or discountable effects. But it expects fencing to cause false crawls or eggs laid in front of the fence. It never explains why those effects are insignificant or discountable, and its own definition says a mostly beneficial action with some adverse effects is likely to adversely affect a species. The finding is preliminary, pending informal consultation with the U.S. Fish and Wildlife Service.
The agency’s words, the record and the law +Hide the words
The agency says
“However, time-of-year restrictions for sea turtle nesting would be adhered to, minimizing the adverse impacts under NEPA.”
Species-Specific Impacts
Elsewhere in the same document
“In the event the overall effect of the proposed action is beneficial to the listed species but is also likely to cause some adverse effects, then the proposed action is likely to adversely affect the listed species.”
Conclusion (Endangered Species Act, Section 7)
The law
“An agency shall issue an environmental impact statement with respect to a proposed agency action requiring an environmental document that has a reasonably foreseeable significant effect on the quality of the human environment.” National Environmental Policy Act, 42 U.S.C. 4336(b)(1) ↗
Effects
No support given
The storm resilient updates would reduce how often and how long the road and parking lots close.
The document gives reasons for fewer closures. Drainage work and raised restrooms target the standing-water closures at Parking Lots 8, 9 and 10. It says the at-grade crossings at Lots 8 to 13 funnel overwash into parking lots, and that elevated boardwalks would let dunes accrete and better protect the northern road and lots. But the long closures come from overwash on the road between Lots 8 and 9. The document says road clearing would be similar to Alternative A and that the northern road would still overwash. It gives no estimate of closure days avoided.
The agency’s words, the record +Hide the words
The agency says
“However, the storm resilient updates are expected to reduce the frequency and duration of road and parking lot closures, which would be a benefit to the visitor experience over Alternative A.”
Conclusion
Elsewhere in the same document
“The road and parking lots north of Parking Lot 8 would still experience overwash during high-water events under Alternative B, which would lead to similar intermittent visitor conflicts and wait times as described under Alternative A.”
Conclusion
“For instance, cleared ditches would act as an easy pathway for overwash, catching sand and keeping it from spreading more broadly across the landscape and building up the back-barrier area.”
Storm Resilient Updates
Show 2 more claims +Show fewer
Effects
No support given
If northern lots close, the lots at Parking Lot 8 and south would hold the same number of visitors, so access impacts are mitigated.
Appendix E says Parking Lot 8 and south can likely hold a typical day's districtwide visitation. The Alternative A analysis says the southern lots have enough room during northern closures except at very high visitation. The plan would move restrooms south so the total number stays the same. But Table E-1 counts 766 spaces at Lot 8 and south, and Table E-2 counts 328 at Lots 9 to 13. Appendix E concedes launch and peak days may strain desired conditions, and Lots 1 to 6 already fill during some launches. Matching current numbers on those days depends on lot expansion the plan says it may pursue only after further review.
The agency’s words, the record +Hide the words
The agency says
“Adverse impacts on visitor access would be mitigated by accommodating the same number of visitors in the parking areas (including the number of restroom facilities) south of Parking Lot 8.”
Conclusion
Elsewhere in the same document
“Future expansion would require additional environmental compliance and would be based upon the park’s adoption of the proposed visitor capacities and monitoring of the indicators and thresholds.”
Identify Visitor Capacities
“However, during rocket launches and peak visitation days, visitation levels may impact desired conditions for resource protection and experience.”
Identify the Visitor Capacity
Economics
No support given
The 50 percent and 150 percent repair-cost triggers correctly mark when fixing the northern road and lots becomes economically infeasible.
The plan ties closure to repair costs above 50% of current replacement value for one-time damage, or cumulative costs above 150% over the 20-year life of the plan. A footnote says costs would be set using the National Park Service's Parametric Condition Assessment method for modeled deferred maintenance and repair. Still, the document never gives the replacement value or past repair and sand-clearing costs, doesn't explain why those percentages mark economic infeasibility, and doesn't say whether sand clearing counts toward the total.
The agency’s words, the record +Hide the words
The agency says
“Under Alternative B, the NPS would continue to maintain the existing public road and parking lots until/if any future storm-related damages are so severe that it is economically infeasible to repair or replace them (as indicated by the triggers discussed later in this section).”
Alternative B: Storm Adaptive Management Plan (Proposed Action)
Elsewhere in the same document
“For repeated repair projects occurring over the 20-year life of the plan, divestment would be triggered when cumulative costs exceed 150% of the system’s total CRV.”
Storm Damage Response
What the document never analyzes
Not analyzed
Air emissions from construction and demolition
The plan involves heavy equipment for drainage clearing at 13 lots, raising three lots, pavement removal and sand hauling. It only lists idling and fuel practices, with no analysis.
Searched all 96 pages for ‘air quality’, ‘emissions’, ‘greenhouse’. None appear.
Where its own record backs the agency
Purpose and needDunes lowered by recent storms now let repeated overwash flood and bury the northern road and lots, so a long-term management plan is needed.Why it holds +
The document backs the need with its own records. It reports about 12 flood days a year at Trident Pier in 2016 to 2025 versus about 3 the decade before, and 15 flood days from May 2025 to April 2026. It also reports road closures several times a year lasting weeks to months, and Lots 8 to 13 closed for several months after the 2022 hurricanes.
The agency says
“The dunes that lost vegetation in those storms continue to experience repeated overwash during high-water events, causing flooding and sand accumulation on roads and parking lots behind the dunes, prompting the NPS to develop a plan for long-term management of this area.”
Introduction
Its own record backs it
“The past decade (meteorological years 2016-2025) experienced approximately 12 flood days per year on average, compared to the previous decade (meteorological years 2006-2015), which averaged approximately 3 flood days per year.”
Shoreline Dynamics
“The park has needed to close the road in this area several times per year due to overwash, each time lasting weeks to months.”
Visitor Use and Experience
ScienceRemoving northern pavement and ending sand clearing would restore overwash that maintains island volume and builds up lagoon-side wetlands.Why it holds +
The document cites research that roads and dune maintenance reduce washover, and that landward washover keeps island volume and feeds lagoon wetlands. It also reports Mosquito Lagoon water levels rose about 1 foot from 2021 to September 2022, so sediment supply matters. The benefit follows from that reasoning, though its timing depends on when the closure triggers are reached.
The agency says
“Overwash would replenish the back side of the island, maintaining its overall sand volume and raising the vertical profile of existing wetlands to increase their resilience to future coastal hazards such as increased water levels, as described above.”
Conclusion
Its own record backs it
“Landward washover deposition is needed to maintain a barrier island’s volume and to prevent it from shrinking, and road clearing and dune management can reduce washover volume and extent (Eisemann et al. 2025).”
Effects of Alternative A: No Action
“This process typically allows the land on the back side of the island (i.e., the wetlands in Mosquito Lagoon) to be replenished with sand.”
Effects of Alternative A: No Action
Read from the agency’s own decision document ↗, all 96 pages. Every quote is checked word for word against it, a claim marked contradicted stands on a quote from the same document, and a second reading argued the agency’s side of every verdict before it was published. The verdicts are our reading; the quotes are the agency’s. A court can set aside agency action it finds “arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law” (5 U.S.C. 706(2)(A) ↗), which is why these gaps are worth putting in the record.
What to say
What the public could have raised, from the agency’s own document
- I oppose this action as proposed, and I ask the agency to weigh the specific harms below.
- The EA's own Long-Range Scenario (Figure 4) shows the entire road and five parking lots (9-13) permanently closed to vehicles and converted to a pedestrian trail once cost triggers are met. This is not a minor operational tweak; it is the elimination of vehicle beach access to roughly a third of the district's designated parking areas for the rest of the 20-year plan. Deciding a change of this permanence and scale through an EA rather than an EIS skips the more rigorous alternatives and impacts analysis such a decision would otherwise require. NPS should prepare an EIS for the long-range divestment component of the plan, or at minimum explain in the EA why permanent closure of this scale does not require one.
- In Appendix B, the NPS dismisses several alternatives (raised/realigned road, engineered dune) specifically because they would require "substantial funding" or "extraordinary cost," yet nowhere in the EA does the agency disclose the actual projected cost of the proposed Alternative B, including near-term facility replacement and the 150%-of-replacement-value repair ceiling before divestment. Without comparable cost figures for the chosen alternative, the cost-based rejection of other options cannot be evaluated by the public. NPS should disclose dollar estimates for Alternative B's near-term and long-range costs so the cost comparisons used to eliminate other alternatives can be verified.
- The document itself reports that annual flood days at the nearby gauge roughly quadrupled between the two most recent decades, yet the plan's near-term response for the vulnerable area north of Parking Lot 8 is essentially the same sand-clearing and dune-planting approach already used under the No Action alternative, which the EA elsewhere admits is 'not sufficient to prevent high-water events overtopping the dunes.' The plan does not explain why a fourfold increase in flooding frequency does not warrant a more substantial near-term engineering response than continued clearing. NPS should directly analyze whether the accelerating flood trend outpaces the storm-resilient updates proposed and justify why no additional near-term protective measures are warranted.
- The visitor capacities in Table 1 (2,200 people at Parking Lots 1-8, 850 at Lots 9-13) rest on a methodology in which NPS assumed 70% of visitors use the southern lots simply because 70% of parking spaces are located there, not because of measured visitor distribution data. Using parking supply to estimate visitor demand is circular and could mask whether the proposed capacities actually reflect how people use the district today. NPS should base the visitor capacity analysis on actual visitor distribution data, such as lot-specific vehicle counts, rather than an assumption derived from parking-space share, and republish the capacity figures.
Show every point from the document
- The EA dismisses socioeconomic impacts from further analysis with a single unsupported assertion that permanent parking lot closures will not noticeably change visitation, even though the same document describes Playalinda as a beach that 'draws visitors locally and internationally' partly because of rocket launch viewing. No visitor spending data, local business data, or comparable closure case studies are cited to support the no-effect conclusion. NPS should conduct and disclose an actual socioeconomic analysis, including effects on local tourism-dependent businesses, before dismissing this topic from detailed review.
- The EA acknowledges that rocket launch frequency is expected to increase, that more than 50 launches already occurred in 2026, that the park closed for 8 days because of them, and that southern parking lots have reached capacity during some launches, yet the capacity analysis explicitly declines to set a special event capacity for these days. Leaving the highest-demand use of the park unanalyzed in the visitor capacity framework undercuts the plan's claim that it will maintain an uncrowded experience. NPS should analyze and adopt a special event visitor capacity for launch days as part of this plan rather than deferring it indefinitely.
- The EA acknowledges that the proposed horizontal sand fencing may cause federally listed sea turtles to falsely crawl or deposit eggs in front of the fence, yet the plan still reaches a 'may affect, not likely to adversely affect' determination for four turtle species without quantifying how many additional false crawls or lost nests the fencing itself is expected to cause. Section 7 consultation with USFWS is also described as only informal and initiated, not completed, as of the EA's release. NPS should complete formal Section 7 consultation and disclose an estimate of fencing-related false-crawl or nest-loss rates before finalizing the decision.
- The EA dismisses archeological resources from detailed analysis while stating that Section 106 consultation with the State Historic Preservation Office and Tribes is still open and that no comments had been received as of the EA's release. Concluding that 'none of the known sites would be affected' before that consultation is complete puts the cart before the horse on a legally required, separate consultation process. NPS should complete Section 106 consultation and disclose SHPO and Tribal comments before finalizing the EA's conclusion on archeological resources.
- Public engagement on a plan that sets in motion 20 years of management decisions, including permanent closure of northern parking lots, drew only 9 people to the virtual meeting and 3 people to the first in-person meeting, with 44 total comment submissions across the entire scoping period. For a decision of this duration and consequence, this is a thin record on which to base conclusions about public acceptance of proposed changes like boardwalk relocation, restroom reductions, and eventual road divestment. NPS should extend the comment period on this EA and conduct additional outreach specifically targeted at users of the northern parking lots before finalizing the decision.
- Say something only you can say. The law requires the agency to consider and respond to substantive comments, and specifics are what make a comment substantive.
In the agency’s own words
Playalinda District Storm Adaptive Management Plan - Environmental Assessment
Did the agency answer?
9 issues are on this record. The agency has not published its decision document yet, so each one stays pending until the agency answers.
Issues on the record, awaiting the decision
- PendingThe EA's own Long-Range Scenario (Figure 4) shows the entire road and five parking lots (9-13) permanently closed to vehicles and converted to a pedestrian trail once cost triggers are met.
The EA's own Long-Range Scenario (Figure 4) shows the entire road and five parking lots (9-13) permanently closed to vehicles and converted to a pedestrian trail once cost triggers are met. This is not a minor operational tweak; it is the elimination of vehicle beach access to roughly a third of the district's designated parking areas for the rest of the 20-year plan. Deciding a change of this permanence and scale through an EA rather than an EIS skips the more rigorous alternatives and impacts analysis such a decision would otherwise require. NPS should prepare an EIS for the long-range divestment component of the plan, or at minimum explain in the EA why permanent closure of this scale does not require one.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingIn Appendix B, the NPS dismisses several alternatives (raised/realigned road, engineered dune) specifically because they would require "substantial funding" or "extraordinary cost," yet nowhere in the
In Appendix B, the NPS dismisses several alternatives (raised/realigned road, engineered dune) specifically because they would require "substantial funding" or "extraordinary cost," yet nowhere in the EA does the agency disclose the actual projected cost of the proposed Alternative B, including near-term facility replacement and the 150%-of-replacement-value repair ceiling before divestment. Without comparable cost figures for the chosen alternative, the cost-based rejection of other options cannot be evaluated by the public. NPS should disclose dollar estimates for Alternative B's near-term and long-range costs so the cost comparisons used to eliminate other alternatives can be verified.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe document itself reports that annual flood days at the nearby gauge roughly quadrupled between the two most recent decades, yet the plan's near-term response for the vulnerable area north of Parkin
The document itself reports that annual flood days at the nearby gauge roughly quadrupled between the two most recent decades, yet the plan's near-term response for the vulnerable area north of Parking Lot 8 is essentially the same sand-clearing and dune-planting approach already used under the No Action alternative, which the EA elsewhere admits is 'not sufficient to prevent high-water events overtopping the dunes.' The plan does not explain why a fourfold increase in flooding frequency does not warrant a more substantial near-term engineering response than continued clearing. NPS should directly analyze whether the accelerating flood trend outpaces the storm-resilient updates proposed and justify why no additional near-term protective measures are warranted.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe visitor capacities in Table 1 (2,200 people at Parking Lots 1-8, 850 at Lots 9-13) rest on a methodology in which NPS assumed 70% of visitors use the southern lots simply because 70% of parking sp
The visitor capacities in Table 1 (2,200 people at Parking Lots 1-8, 850 at Lots 9-13) rest on a methodology in which NPS assumed 70% of visitors use the southern lots simply because 70% of parking spaces are located there, not because of measured visitor distribution data. Using parking supply to estimate visitor demand is circular and could mask whether the proposed capacities actually reflect how people use the district today. NPS should base the visitor capacity analysis on actual visitor distribution data, such as lot-specific vehicle counts, rather than an assumption derived from parking-space share, and republish the capacity figures.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA dismisses socioeconomic impacts from further analysis with a single unsupported assertion that permanent parking lot closures will not noticeably change visitation, even though the same documen
The EA dismisses socioeconomic impacts from further analysis with a single unsupported assertion that permanent parking lot closures will not noticeably change visitation, even though the same document describes Playalinda as a beach that 'draws visitors locally and internationally' partly because of rocket launch viewing. No visitor spending data, local business data, or comparable closure case studies are cited to support the no-effect conclusion. NPS should conduct and disclose an actual socioeconomic analysis, including effects on local tourism-dependent businesses, before dismissing this topic from detailed review.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA acknowledges that rocket launch frequency is expected to increase, that more than 50 launches already occurred in 2026, that the park closed for 8 days because of them, and that southern parkin
The EA acknowledges that rocket launch frequency is expected to increase, that more than 50 launches already occurred in 2026, that the park closed for 8 days because of them, and that southern parking lots have reached capacity during some launches, yet the capacity analysis explicitly declines to set a special event capacity for these days. Leaving the highest-demand use of the park unanalyzed in the visitor capacity framework undercuts the plan's claim that it will maintain an uncrowded experience. NPS should analyze and adopt a special event visitor capacity for launch days as part of this plan rather than deferring it indefinitely.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA acknowledges that the proposed horizontal sand fencing may cause federally listed sea turtles to falsely crawl or deposit eggs in front of the fence, yet the plan still reaches a 'may affect, n
The EA acknowledges that the proposed horizontal sand fencing may cause federally listed sea turtles to falsely crawl or deposit eggs in front of the fence, yet the plan still reaches a 'may affect, not likely to adversely affect' determination for four turtle species without quantifying how many additional false crawls or lost nests the fencing itself is expected to cause. Section 7 consultation with USFWS is also described as only informal and initiated, not completed, as of the EA's release. NPS should complete formal Section 7 consultation and disclose an estimate of fencing-related false-crawl or nest-loss rates before finalizing the decision.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA dismisses archeological resources from detailed analysis while stating that Section 106 consultation with the State Historic Preservation Office and Tribes is still open and that no comments ha
The EA dismisses archeological resources from detailed analysis while stating that Section 106 consultation with the State Historic Preservation Office and Tribes is still open and that no comments had been received as of the EA's release. Concluding that 'none of the known sites would be affected' before that consultation is complete puts the cart before the horse on a legally required, separate consultation process. NPS should complete Section 106 consultation and disclose SHPO and Tribal comments before finalizing the EA's conclusion on archeological resources.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingPublic engagement on a plan that sets in motion 20 years of management decisions, including permanent closure of northern parking lots, drew only 9 people to the virtual meeting and 3 people to the fi
Public engagement on a plan that sets in motion 20 years of management decisions, including permanent closure of northern parking lots, drew only 9 people to the virtual meeting and 3 people to the first in-person meeting, with 44 total comment submissions across the entire scoping period. For a decision of this duration and consequence, this is a thin record on which to base conclusions about public acceptance of proposed changes like boardwalk relocation, restroom reductions, and eventual road divestment. NPS should extend the comment period on this EA and conduct additional outreach specifically targeted at users of the northern parking lots before finalizing the decision.
A hole PLAN found in the agency’s own analysis, quote verified against the document
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