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PLANfor Public Lands · the impact record
by More Than Just Parks · figures as of September 25, 2026

The theory of change: issue preservation at scale

Under the Administrative Procedure Act, an agency must consider and respond to substantive comments before finalizing a decision. Identical form letters get bundled and counted once; they preserve nothing. A specific comment citing the record, the environmental assessment’s own section and page, creates the duty to respond and enters the record a later objection or lawsuit stands on. PLAN reads the government’s own documents, marks the holes, and hands the reader the citation. The reader writes the sentence themselves; the handoff goes to the official docket; the comment is filed in the reader’s own name. PLAN never files anything.

The handoff ledger

People sent to official comment systems since launch, July 9, 2026. Anonymous: one event per person per fight and channel; no account, no email, no IP stored.

Agency comment portals (ePlanning, CARA, PEPC)1,340
Regulations.gov comment forms2,340
Official notices (Federal Register and agency pages)170
Agency comment email, prefilled draft16
Printed comment letters for mailing251
Total outbound handoffs4,117

Plus 106 watch signups for fights not yet open for comment (50 confirmed by double opt-in). Zero paid promotion.

Covered systems

Open comment windows ingested daily from five federal systems, including project registers that never reach the Federal Register. Open actions now, by source:

Forest Service project register (SOPA / CARA)22
Federal Register8
National Park Service PEPC7
BLM National NEPA Register (ePlanning)2
Army Corps of Engineers public notices0
Open actions on the board40

Honest edge: Reclamation, FWS refuge planning, and BOEM are incidental Federal Register catches today. Direct coverage is expanding.

The document harvest

39 of 40 open actions carry a read of the underlying EA or EIS, not just the notice327 verified findings on the board

Every finding carries a section-and-page citation to the agency’s own document (live examples, as stored: "Alternatives to the Proposed Action", "Wildlife Species and Habitat", "Soil Productivity", "Consultation with Federally Recognized Tribes"). A verification gate rejects any quoted passage that is not one contiguous verbatim run from the document text; stitched quotes and paraphrases do not publish. The remainder is stated: 0 documents read yielded no finding that survived the gate (those pages stay blurb-only), 0 actions have no public document yet, 0 have one not yet retrievable, 1 arrived since the last harvest pass.

How to check the work

  • The methodology is public: morethanjustparks.com/public-lands-action-network/methodology. Every action links its official source document.
  • Accuracy validators run in CI against the live board: official source link on every action, no first-person factual claims drafted on a reader’s behalf, no template tokens, a known source system on every row. A hard failure blocks.
  • Agency deadline moves are recorded in a drift ledger (13 to date), never silently corrected. Cross-source duplicates resolve to one canonical fight, so nothing is double counted.
Live version: morethanjustparks.com/public-lands-action-network/impactask@morethanjustparks.com