This Comment examines the Supreme Court decision that resolved the split in the circuits over the justiciability of Land and Resource Management Plans, or Forest Plans, which the Forest Service prepares. In Ohio Forestry Ass'n v. Sierra Club, the Court denied the Sierra Club's challenge to the Forest Plan for Wayne National Forest, holding that the issues were not ripe for review absent site-specific, on-the-ground activities. Gregory argues that the Court's decision reflects the continuing use of justiciability doctrines, such as ripeness, to restrict environmental plaintiffs' access to the courts. She maintains that Forest Plans are final agency actions that are binding and cause identifiable injury, thus making them ripe for review. This Comment concludes that insulating Forest Plans from judicial review could eliminate effective and efficient scrutiny of Forest Service actions, contrary to congressional and statutory intent.

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