The Forest Service Decision making and Appeals Reform Act of 1992 requires the Forest Service to establish a notice, comment, and appeals process for "proposed actions of the Forest Service concerning projects and activities implementing land and resource management plans." The regulations that implement the Act provide that certain procedures would not be applied to projects that the Forest Service considered excluded from the requirement to file an environmental impact statement (EIS), such as in the case of salvage-timber sales of 250 acres or less.

1. Given the words of the Court above, how could plaintiff have demonstrated standing?
2. Does this indicate that standing is difficult to obtain?