Can a plaintiff escape the exhaustion requirement when the argument is so obvious that there is no need for a commentator to point them out specifically?

^7. A plaintiff may escape the exhaustion requirement when an argument is so obvious that there is no need for a commentator to point them out specifically in order to preserve its ability to challenge a proposed action. Pub. Citizen, 541 U.S. at 765, 124 S.Ct. 2204. In order for the so obvious standard to apply, the agency must have independent knowledge of the issues that concern petitioners. Barnes v. United States Dep't of Transp., 655 F.3d 1124, 1132 (9th Cir.2011). Plaintiffs have not argued that this exception applies here.