Each issue against the decision, unreviewed

• PLAN’s match, not yet checked by a personThe TRIBAL ENGAGEMENT AND CONSULTATION section states that tribal consultation is ongoing and that the Forest Service will remain available to respond to consultation requests, meaning consultation with the 25 tribes notified was not complete when this decision document was drafted, with only two tribal responses on record.

  The TRIBAL ENGAGEMENT AND CONSULTATION section states that tribal consultation is ongoing and that the Forest Service will remain available to respond to consultation requests, meaning consultation with the 25 tribes notified was not complete when this decision document was drafted, with only two tribal responses on record.

  The Forest Service should complete government-to-government consultation and disclose any issues tribes raise before issuing a final decision rather than proceeding while consultation remains open.

  A hole PLAN found in the agency’s own analysis

  “Tribal consultation was completed (EA Agencies and Persons Consulted) and the Forest Service attempted to notify the descendants of the Cotopaxi Jewish Colony; however, no responses were received.”

  The agency’s own words, Locke Park Final EA ↗, Appendix E – Consideration of Comments for the Locke Park Land Exchange Project · PLAN’s match, unchecked, an answer in part

• PLAN’s match, not yet checked by a personThe Short-and long-term effects section states the NFS will lose approximately 13.3 acres of mapped suitable Canada lynx habitat on the Federal parcel, then simply asserts this loss will be negligible in the context of the larger San Isabel National Forest without giving the total lynx habitat acreage on the forest needed to check that comparison.

  The Short-and long-term effects section states the NFS will lose approximately 13.3 acres of mapped suitable Canada lynx habitat on the Federal parcel, then simply asserts this loss will be negligible in the context of the larger San Isabel National Forest without giving the total lynx habitat acreage on the forest needed to check that comparison.

  A conclusory negligible-impact label without the underlying baseline numbers is not a reasoned analysis the public can verify. The Forest Service should disclose the total suitable lynx habitat acreage on the forest and show the calculation behind the negligible-impact determination.

  A hole PLAN found in the agency’s own analysis

  “The Federal and non-Federal parcels do not have dense conifer-hardwood habitat preferred by Canada lynx and this species is not known to occur in the Federal parcel; therefore, it was determined that the proposed action may affect, but is not likely to adversely affect, the Canada lynx.”

  The agency’s own words, Locke Park Final EA ↗, Appendix E – Consideration of Comments for the Locke Park Land Exchange Project · PLAN’s match, unchecked, an answer in part

• PLAN’s match, not yet checked by a personUnder National Historic Preservation Act - Section 106, SHPO has already determined that the RTLC structure on the Federal parcel is eligible for listing on the National Register and that mitigation measures are needed to resolve adverse effects, but the memorandum of agreement spelling out those measures had not been signed when this document was drafted.

  Under National Historic Preservation Act - Section 106, SHPO has already determined that the RTLC structure on the Federal parcel is eligible for listing on the National Register and that mitigation measures are needed to resolve adverse effects, but the memorandum of agreement spelling out those measures had not been signed when this document was drafted.

  A legally required mitigation agreement is being deferred to after the decision is written up rather than informing it. The Forest Service should complete and disclose the signed MOA and its specific mitigation terms before finalizing the decision.

  A hole PLAN found in the agency’s own analysis

  “Section 106 consultation is underway and will be completed before issuance of the Final Decision Notice.”

  The agency’s own words, Locke Park Final EA ↗, Appendix E – Consideration of Comments for the Locke Park Land Exchange Project · PLAN’s match, unchecked

• PLAN’s match, not yet checked by a personThe entire no-significant-impact finding leans on the conservation easement protecting the Federal parcel's wetlands, forested setting and development limits, but the EQUALIZATION OF VALUE section admits the CE grant to Palmer Land Conservancy happens in a transaction that is either after the exchange closes or entirely outside of it, not concurrent with closing as the Introduction and Decision sections claim.

  The entire no-significant-impact finding leans on the conservation easement protecting the Federal parcel's wetlands, forested setting and development limits, but the EQUALIZATION OF VALUE section admits the CE grant to Palmer Land Conservancy happens in a transaction that is either after the exchange closes or entirely outside of it, not concurrent with closing as the Introduction and Decision sections claim.

  If the CE is not a binding condition of the exchange itself, the mitigation the FONSI depends on could be delayed or never finalized. The Forest Service should make the conservation easement a legally binding condition precedent to closing and disclose what protects the parcel's resource values if the CE is never executed.

  A hole PLAN found in the agency’s own analysis

  “A CE will be placed on the Federal parcel concurrent with the closing of the land exchange and held by the Palmer Land Conservancy to ensure that the property's conservation values are protected and that no development occurs outside the Camp Facilities Zone”

  The agency’s own words, Locke Park Final EA ↗, Forest Service Conditions of the Land Exchange · PLAN’s match, unchecked, an answer in part

• PLAN’s match, not yet checked by a personThe EA states the United States will dispose of up to 2.5 acres of wetlands and 25 acres of regulatory floodplain on the Federal parcel by transferring them to private ownership, yet the same discussion concludes no short- or long-term impacts on wetlands and floodplains are anticipated.

  The EA states the United States will dispose of up to 2.5 acres of wetlands and 25 acres of regulatory floodplain on the Federal parcel by transferring them to private ownership, yet the same discussion concludes no short- or long-term impacts on wetlands and floodplains are anticipated.

  Removing federally managed wetlands and floodplain acreage from public ownership is itself a change in protective status that deserves analysis rather than a blanket no-impact conclusion. The Forest Service should explain how disposing of federal wetlands and floodplain acreage produces zero impact or revise the finding.

  A hole PLAN found in the agency’s own analysis

  “The land exchange would comply with Executive Order 11988 and Forest Service policy because the floodplain to be disposed of is protected by other laws and regulations under Custer County's land use regulations, articulated in the county's July 31, 2018, Zoning Resolution.”

  The agency’s own words, Locke Park Final EA ↗, Effects of the Proposed Action Alternative · PLAN’s match, unchecked