Stop the 94-acre Locke Park land swap with a private camp
Locke Park Land Exchange
U.S. Forest Service· Pike-San Isabel National Forests & Cimarron and Comanche National Grasslands, San Carlos Ranger DistrictU.S. Forest Service project page ↗
Forest ServiceWe track this on the agency’s own system of record, where most on-the-ground decisions live.
This is not a comment period
The comment round on this one is over
What is open now is a pre-decisional objection period. Only individuals and entities that already submitted timely, specific written comments during an earlier public comment opportunity on this project may file an objection (36 CFR 218.5(a)). If you commented, this is your round. If you did not, no filing you send here will be accepted, and the honest thing for us to say is that this door is closed to you rather than to hand you a form.
An organization’s comments count for the organization only. Being a member of a group that commented does not make you eligible; you had to comment in your own name (36 CFR 218.5(c)).
Objections are due October 16, 2026. That date came off the agency’s own legal notice, which is the only source the regulation lets an objector rely on (36 CFR 218.6(c)).
The groups on this fight
4 groups predicted likely to care in Colorado
Predicted likely to care is a guess from footprint in Colorado, by the same match the STAND matchmaker runs, with no link to this decision. Give straight to them; nothing routes through us.
- Center for Biological Diversity
Predicted likely to care · a guess
Works Colorado: led the coalition suit against the Uinta Basin Railway, whose oil trains would run the river corridors below the monument.
- Rocky Mountain Wild
Predicted likely to care · a guess
Works Colorado: joined the formal challenge to the January 2026 replacement lease sale and previously sued BLM over the Roan Plateau leases.
- San Juan Citizens Alliance
Predicted likely to care · a guess
Works Colorado: shaped the 2010 management plan, has fought oil and gas leasing decisions inside the monument for two decades, mobilized against the 2017 monument review, and states it continues to defend CANM.
- WildEarth Guardians
Predicted likely to care · a guess
Works Colorado: named petitioner against the Uinta Basin Railway over habitat destruction in the basin.
Every group above is on STAND for Public Lands, with its court record, its filings and who backs it.
The Forest Service plans to transfer 94.3 acres of national forest to a private camp for 120 acres, relying on a conservation easement the EA itself says may be granted after closing, outside the exchange.
What’s at risk
The exchange disposes of 2.5 acres of wetlands and 25 acres of regulatory floodplain and transfers 13.3 acres of mapped Canada lynx habitat to private ownership. A structure on the Federal parcel has already been found eligible for the National Register of Historic Places, with mitigation still unresolved, and tribal consultation with 25 notified tribes remains open.
If we stay silent
Once complete, 94.3 acres of national forest, including its surface and mineral estate, leave federal ownership permanently and become private land, while the 120-acre non-Federal parcel joins the National Forest System under Forest Plan Management Areas 7A and 9A. The camp can then expand within a 22.19-acre Camp Facilities Zone under a conservation easement the EA says will be granted in a transaction separate from the exchange itself.
Our plain-English read of the official notice ↗. Check it against the agency’s own words below.
By the numbers, from the agency’s own document
- Federal parcel size cut to equalize value
- reduced from 100.73 to 94.3 acres
- Non-Federal parcel acquired in exchange
- approximately 120 acres
- Canada lynx habitat lost on Federal parcel
- 13.3 acres
- Wetlands and floodplain disposed to private ownership
- 2.5 acres wetlands, 25 acres floodplain
- Camp Facilities Zone allowed for future development
- 22.19 acres
EQUALIZATION OF VALUE
Open the document ↗“The Federal parcel was reduced by 6.43 acres resulting in a revised Federal parcel size of 94.3 acres.”
Introduction
Open the document ↗“exchange a Federal parcel (approximately 94.3 acres) for a non-Federal parcel (approximately 120 acres)”
Short-and long-term effects.
Open the document ↗“The NFS will lose approximately 13.3 acres of mapped suitable Canada lynx habitat in the Federal parcel.”
Short-and long-term effects.
Open the document ↗“will dispose of up to 2.5 acres of wetlands and 25 acres of regulatory floodplain on the Federal parcel”
Short-and long-term effects.
Open the document ↗“Anticipated future development within the 22.19-acre Camp Facilities Zone of the Federal parcel”
Each figure is checked word for word against the decision document ↗; open a label to read the sentence it comes from and the document it’s in.
The agency’s case, tested
What the agency argues, and whether its own record backs it
- 1
- Holds up
- 4
- No support given
- 1
- Contradicted by its own record
The Forest Service wants to trade about 94.3 acres of national forest land, used by the Rainbow Trail Lutheran Camp, for a 120-acre private inholding at Locke Park. It says the trade consolidates federal ownership, cuts permit and boundary workload, and protects the inholding's wetlands, cultural sites and wildlife habitat.
“The purpose and need for the Proposed Action is for the Forest Service to acquire non-Federal lands that are of high resource value and serve public objectives.”
Purpose and Need
Each Ask below goes into your letter when you write it with PLAN on this page, matched to what you tell it about how this land reaches you.
Effects
Contradicted by its own record
The exchange won't cause any short- or long-term impacts on cultural resources on either parcel.
The agency relies on a 2023 cultural survey, a 2025 revision and a May 2026 memorandum with testing results, and it commits to a memorandum of agreement setting mitigation before the final decision. But the National Historic Preservation Act section says the State Historic Preservation Officer found the camp eligible for the National Register of Historic Places and that mitigation is needed to resolve adverse effects. That can't be squared with the flat statement that no cultural resource impacts are anticipated.
AskCorrect the cultural resources finding to reflect the adverse effect on the eligible camp, and release the memorandum of agreement's mitigation terms for public review before the final decision.
The agency’s words, the record and the law +Hide the words
The agency says
“No short- or long-term impacts on cultural resources are anticipated on the Federal and non-Federal parcels due to the Proposed Action.”
Degree of Effect
Elsewhere in the same document
“SHPO determined that the RTLC (5CR.878) was eligible for listing on the NRHP and mitigation measures are needed to resolve adverse effects.”
National Historic Preservation Act, Section 106
“The Forest Service will enter into a memorandum of agreement (MOA) with SHPO and other consulting parties to determine appropriate mitigation measures.”
National Historic Preservation Act, Section 106
The law
“shall take into account the effect of the undertaking on any historic property.” National Historic Preservation Act, 54 U.S.C. 306108 ↗
Purpose and need
No support given
Acquiring the 120-acre parcel gives the public more benefit than keeping the 94.3-acre Federal parcel, including better protection of fish, wildlife and riparian habitat.
The agency lists the public interest factors it weighed. It notes the gain of 120 acres against 94.3 acres, the elimination of a private inholding and a reserved road right-of-way. It also cites two cultural resources and a new linear segment on the non-Federal parcel and a beneficial impact on three sensitive plants. But it quantifies wetlands, floodplain and lynx habitat leaving federal ownership without matching figures for wetlands or habitat gained, so the side-by-side weighing isn't fully shown.
AskProvide a side-by-side comparison of wetland, riparian, habitat and cultural resource acreage on each parcel to support the public interest determination.
The agency’s words, the record +Hide the words
The agency says
“To conclude, acquisition and management of the non-federal parcel creates a greater public benefit than would be achieved by retaining ownership of the federal parcel to be exchanged.”
PUBLIC INTEREST DETERMINATION
Elsewhere in the same document
“Additionally, suitable habitat for wildlife and Forest Service sensitive species will be transferred to private ownership.”
Degree of Effect
Effects
No support given
The exchange won't cause short- or long-term impacts on wetlands and floodplains.
The agency says the exchange itself places no fill in wetlands and the easement protects them. But up to 2.5 acres of wetlands and 25 acres of regulatory floodplain go private, development is expected in the 22.19-acre Camp Facilities Zone, and the Clean Water Act section contemplates future wetland impacts there. The document never says how much wetland or floodplain lies inside that zone.
AskMap how much wetland and floodplain falls inside the Camp Facilities Zone and analyze the effects of the camp expansion the decision anticipates.
The agency’s words, the record +Hide the words
The agency says
“No short- or long-term impacts on wetlands and floodplains are anticipated due to the Proposed Action.”
Degree of Effect
Elsewhere in the same document
“The United States will dispose of up to 2.5 acres of wetlands and 25 acres of regulatory floodplain on the Federal parcel in the land exchange.”
Degree of Effect
“If impacts on wetlands were proposed in the Camp Facilities Zone in the future, a Section 404 permit from the U.S. Army Corps of Engineers will be required.”
Clean Water Act
Show 2 more claims +Show fewer
Effects
No support given
Permanent loss of vegetation and wildlife habitat on the Federal parcel, including Canada lynx habitat, will be negligible in the context of the larger forest.
The agency cites U.S. Fish and Wildlife Service concurrence that the project may affect but isn't likely to adversely affect Canada lynx. Its biological evaluation found no trend toward listing for the affected sensitive species. It also says development is confined to the 22.19-acre Camp Facilities Zone and limited by the conservation easement. But it discloses a loss of approximately 13.3 acres of lynx habitat without a forest-wide habitat figure to compare against, and it doesn't say whether the non-Federal parcel adds any lynx habitat.
AskCompare the habitat lost on the Federal parcel with habitat gained on the non-Federal parcel, including lynx habitat acreage, and give the forest-wide figures behind the negligible finding.
The agency’s words, the record and the law +Hide the words
The agency says
“Over the long term and in the context of the larger San Isabel National Forest, permanent loss of vegetation communities and wildlife habitat on the Federal parcel will be negligible (EA pages 28-34).”
Degree of Effect
Elsewhere in the same document
“The NFS will lose approximately 13.3 acres of mapped suitable Canada lynx habitat in the Federal parcel.”
Degree of Effect
“Anticipated future development within the 22.19-acre Camp Facilities Zone of the Federal parcel as a result of the Proposed Action may result in permanent loss of vegetation, including mixed conifer, ponderosa pine, and disturbed upland vegetation communities.”
Degree of Effect
The law
“An agency shall issue an environmental impact statement with respect to a proposed agency action requiring an environmental document that has a reasonably foreseeable significant effect on the quality of the human environment.” National Environmental Policy Act, 42 U.S.C. 4336(b)(1) ↗
Process
No support given
The action is consistent with all federal, state and local environmental laws.
The agency states the exchange is consistent with all laws. But its own record says the State Historic Preservation Officer found the camp eligible for the National Register and that “mitigation measures are needed to resolve adverse effects,” and the memorandum of agreement that would set those measures is still to be signed.
AskSign the historic preservation agreement and publish its mitigation before claiming full legal consistency.
The agency’s words +Hide the words
The agency says
“I find that the Locke Park Land Exchange proposed action is consistent with federal, state, and local laws and requirements imposed for the protection of the environment.”
Effects that would violate Federal, State, or local law protecting the environment
Where its own record backs the agency
Purpose and needThe exchange frees the Forest Service from administering special use permits on both parcels, an efficiency gain.Why it holds +
The exchange conditions require ending both the 30-year camp permit and the road snow removal permit, which directly removes those administrative duties. The record backs the claim.
The agency says
“Relief from administration of special use permits on both parcels provides an efficiency benefit.”
Beneficial and adverse effects
Its own record backs it
“The PSICC Forest Supervisor shall secure termination of the 30-year SUP for camp operations issued to RTLC on July 25, 1997 (SAN302001, as amended).”
Forest Service Conditions of the Land Exchange
“The PSICC Forest Supervisor shall secure termination of the SUP for snow removal and maintenance of NFS Road 274 and NFS Road 343 issued to RTLC on September 4, 2015 (SAN316).”
Forest Service Conditions of the Land Exchange
Read from the agency’s own decision document ↗, all 12 pages. Every quote is checked word for word against it, a claim marked contradicted stands on a quote from the same document, and a second reading argued the agency’s side of every verdict before it was published. The verdicts are our reading; the quotes are the agency’s. A court can set aside agency action it finds “arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law” (5 U.S.C. 706(2)(A) ↗), which is why these gaps are worth putting in the record.
What to say
Make these points, in your own words
- I support this action and urge the agency to advance it.
- 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.
- 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.
- The Beneficial and adverse effects discussion acknowledges short-term noise impacts during construction and long-term impacts from increased traffic tied to camp expansion, but the Effects on public health and safety section then concludes no effects on public health and safety are anticipated at all. Both statements cannot be reconciled as written. The Forest Service should explain why acknowledged construction noise and increased traffic do not count as public health and safety effects, or revise the conclusion.
- 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.
Show every point from the document
- 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.
- 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.
- The EQUALIZATION OF VALUE section states the initial appraisal derived a market value conclusion for the Federal parcel's fee simple interest as though vacant, meaning unencumbered, yet the parcel will be conveyed to RTLC encumbered by a perpetual conservation easement restricting future development. The same section admits the final appraised values were not subject to the CE at all. An unencumbered appraisal does not capture the actual value of what the exchange conveys, calling into question whether the exchange is truly equal in value as required. The Forest Service should obtain and disclose an appraisal reflecting the CE-encumbered value of the Federal parcel.
- The Clean Water Act section states that water use and development of the non-Federal parcel is anticipated to be unchanged, but the document never analyzes anticipated water use changes on the Federal parcel, where RTLC plans facility improvements, a new road segment, and expanded overnight and cookout areas served by a well located approximately 400 feet from Lake Creek. Camp expansion is the very change the exchange is designed to enable, yet its water demand on Lake Creek goes unanalyzed. The Forest Service should analyze anticipated water use increases from Federal parcel camp expansion and any effects on Lake Creek.
- The Selected Alternative (Proposed Action) section states the mineral estate underlying the non-Federal parcel will become Reserved Public Domain and the land will be open to mineral entry, pairing two mineral-status descriptions without explaining how both apply to the same acreage at once. The document does not clarify what mineral development could actually occur on newly acquired land billed elsewhere as protected open space and wildlife habitat. The Forest Service should clarify the actual mineral entry status of the 120-acre parcel and disclose what mineral development it could allow.
- The Alternatives Considered but Not Analyzed in Detail section states that no feasible alternatives consistent with the project's purpose and need were identified during planning, without listing what specific alternatives were considered or the specific reasons each one failed to meet the purpose and need beyond generic categories. Without that detail the public cannot evaluate whether a genuine range of alternatives was considered. The Forest Service should disclose the specific alternatives considered during planning and the specific reasons each was eliminated from detailed analysis.
- Say something only you can say. The law requires the agency to consider and respond to substantive comments, and specifics are what make a comment substantive.
In the agency’s own words
Equal value land exchange of 94 acres of federal land for 120 acres of private land between the US Forest Service and Rainbow Trail Lutheran Camp.
Did the agency answer?
10 issues are on this record. The agency has not published its decision document yet, so each one stays pending until the agency answers.
Issues on the record, awaiting the decision
- PendingThe 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 wi
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, quote verified against the document
- PendingThe 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
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, quote verified against the document
- PendingUnder 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 m
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, quote verified against the document
- PendingThe 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 adm
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, quote verified against the document
- PendingThe 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 discussi
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, quote verified against the document
- PendingThe Beneficial and adverse effects discussion acknowledges short-term noise impacts during construction and long-term impacts from increased traffic tied to camp expansion, but the Effects on public h
The Beneficial and adverse effects discussion acknowledges short-term noise impacts during construction and long-term impacts from increased traffic tied to camp expansion, but the Effects on public health and safety section then concludes no effects on public health and safety are anticipated at all. Both statements cannot be reconciled as written. The Forest Service should explain why acknowledged construction noise and increased traffic do not count as public health and safety effects, or revise the conclusion.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EQUALIZATION OF VALUE section states the initial appraisal derived a market value conclusion for the Federal parcel's fee simple interest as though vacant, meaning unencumbered, yet the parcel wil
The EQUALIZATION OF VALUE section states the initial appraisal derived a market value conclusion for the Federal parcel's fee simple interest as though vacant, meaning unencumbered, yet the parcel will be conveyed to RTLC encumbered by a perpetual conservation easement restricting future development. The same section admits the final appraised values were not subject to the CE at all. An unencumbered appraisal does not capture the actual value of what the exchange conveys, calling into question whether the exchange is truly equal in value as required. The Forest Service should obtain and disclose an appraisal reflecting the CE-encumbered value of the Federal parcel.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe Clean Water Act section states that water use and development of the non-Federal parcel is anticipated to be unchanged, but the document never analyzes anticipated water use changes on the Federal
The Clean Water Act section states that water use and development of the non-Federal parcel is anticipated to be unchanged, but the document never analyzes anticipated water use changes on the Federal parcel, where RTLC plans facility improvements, a new road segment, and expanded overnight and cookout areas served by a well located approximately 400 feet from Lake Creek. Camp expansion is the very change the exchange is designed to enable, yet its water demand on Lake Creek goes unanalyzed. The Forest Service should analyze anticipated water use increases from Federal parcel camp expansion and any effects on Lake Creek.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe Selected Alternative (Proposed Action) section states the mineral estate underlying the non-Federal parcel will become Reserved Public Domain and the land will be open to mineral entry, pairing tw
The Selected Alternative (Proposed Action) section states the mineral estate underlying the non-Federal parcel will become Reserved Public Domain and the land will be open to mineral entry, pairing two mineral-status descriptions without explaining how both apply to the same acreage at once. The document does not clarify what mineral development could actually occur on newly acquired land billed elsewhere as protected open space and wildlife habitat. The Forest Service should clarify the actual mineral entry status of the 120-acre parcel and disclose what mineral development it could allow.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe Alternatives Considered but Not Analyzed in Detail section states that no feasible alternatives consistent with the project's purpose and need were identified during planning, without listing what
The Alternatives Considered but Not Analyzed in Detail section states that no feasible alternatives consistent with the project's purpose and need were identified during planning, without listing what specific alternatives were considered or the specific reasons each one failed to meet the purpose and need beyond generic categories. Without that detail the public cannot evaluate whether a genuine range of alternatives was considered. The Forest Service should disclose the specific alternatives considered during planning and the specific reasons each was eliminated from detailed analysis.
A hole PLAN found in the agency’s own analysis, quote verified against the document
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