Pike-San Isabel land exchange with Rainbow Trail Lutheran Camp nears final decision
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)).
Do not file on our date. Get it from the notice. The objection clock runs from the day the legal notice was published in the forest’s newspaper of record, and that publication date is the exclusive means of calculating it. Objectors may not rely on a date from any other source (36 CFR 218.6(c)). The agency has to post that notice on the web within four days of publishing it (36 CFR 218.7(d)), so it is on the project page.
For what it is worth, the Forest Service comment portal listed October 16, 2026 for this project when we read it. That is the portal’s own field, not the legal notice, and we have not reconciled the two. We would rather show you where it came from than let it stand in for the law.
The groups on this fight
4 groups work Colorado
By footprint, from the same match the STAND matchmaker runs; none is linked to this decision in our record yet. Give straight to them; nothing routes through us.
- Center for Biological Diversity
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
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
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
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 would gain 120 acres of private inholding by trading away 94.3 acres of National Forest land.
What’s at risk
Only those who submitted written comments during the earlier participation window are eligible to file an objection. The 94.3 acres of federal land transferring to Rainbow Trail Lutheran Camp would carry a conservation easement, while the 120 acres of private inholding would become permanently National Forest System land.
If we stay silent
If approved, the Forest Service permanently adds 120 acres of previously private land to the Pike-San Isabel National Forests, consolidating public ownership in the San Carlos Ranger District.
Our plain-English read of the official notice ↗. Check it against the agency’s own words below.
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 appraisal explicitly excluded the conservation easement when valuing the Federal parcel, meaning the CE was placed on land already conveyed at a higher, unencumbered value. The document states the final appraised values were not subject to the CE and that the CE grant to Palmer Land Conservancy occurs in a subsequent transaction to the exchange. This means the public is giving up 94.3 acres appraised as though fully developable, then immediately encumbering that land with a CE -- a sequencing that inflates the apparent value of the Federal parcel and undermines the equal-value requirement. The agency should prepare a supplemental appraisal that values the Federal parcel subject to the conservation easement, or justify in writing why the unencumbered appraisal satisfies the equal-value mandate of 36 CFR 254.
- Tribal consultation is described as ongoing and unresolved at the time of this decision. The document says tribal consultation is ongoing and the Forest Service will remain available to engage, yet a FONSI has already been issued. SHPO also found the RTLC site eligible for the National Register and stated mitigation measures are needed, with a memorandum of agreement still to be completed. Issuing a draft decision before Section 106 consultation and mitigation are finalized violates the sequencing required by 36 CFR 800. The agency should withhold the final Decision Notice until the MOA is signed and tribal consultation is formally concluded.
- SHPO determined the RTLC property is eligible for the National Register of Historic Places and that mitigation measures are needed to resolve adverse effects, yet the FONSI states no short- or long-term impacts on cultural resources are anticipated. These two statements directly contradict each other. A finding that adverse effects require mitigation is incompatible with a finding of no impact on cultural resources. The agency should either revise the FONSI to accurately characterize the adverse effect finding, or prepare an EIS that fully discloses and analyzes the cultural resource impacts.
- The document acknowledges the United States will dispose of up to 2.5 acres of wetlands and 25 acres of regulatory floodplain on the Federal parcel, yet concludes there are no short- or long-term impacts on wetlands and floodplains. The sole basis offered is that the conservation easement will protect these features, but the CE is held by a private land trust, not the federal government, and the CE was not valued in the appraisal. The agency has not analyzed what happens to those wetlands if the CE is ever violated or extinguished. The agency should analyze the long-term enforceability of the CE as the sole protection for 2.5 acres of wetlands now leaving federal ownership, or prepare an EIS addressing this gap.
Show all 12 points from the document
- The document states the NFS will lose approximately 13.3 acres of mapped suitable Canada lynx habitat on the Federal parcel and that the project may affect, not likely to adversely affect the Canada lynx, yet the FONSI dismisses this as negligible in the context of the larger San Isabel National Forest. No acreage threshold, recovery plan standard, or population-level analysis is cited to support the conclusion that 13.3 acres of mapped lynx habitat leaving federal ownership is negligible. The agency should provide the quantitative basis -- such as the lynx conservation assessment or USFWS concurrence rationale -- for concluding that permanent loss of this mapped habitat does not rise to significance.
- The document states only four comment letters were received during the 30-day comment period for the draft EA, compared to 32 letters during the earlier 45-day scoping period. This sharp drop suggests the draft EA comment period may not have been adequately publicized or may have been too short for meaningful public engagement on a document that was not released until after a lengthy planning process. The agency should explain in the record what outreach specifically targeted the 32 parties who commented during scoping, confirm each was directly notified of the draft EA comment period, and consider whether the 30-day window was sufficient.
- The document states no water rights will be conveyed in the exchange and that no water rights are associated with the non-Federal parcel, yet the well on the Federal parcel sits approximately 400 feet from Lake Creek. The conservation easement restricts transfer of well rights, but once the parcel is private, state water law -- not the CE -- governs well use and administration. The agency has not analyzed whether intensified camp development and increased water use from the well could affect Lake Creek flows or riparian habitat. The agency should analyze the potential hydrologic effects of expanded camp operations on Lake Creek under Colorado water law before issuing a final decision.
- The document states a new road segment will be constructed within the Conservation Zone to access overnight and cookout areas, and that the option is retained to reroute NFS Road 198 within the Conservation Zone, yet the FONSI states long-term impacts may result from increased traffic without quantifying traffic levels, road surface impacts, or dust and noise effects on adjacent NFS lands. No analysis of these construction and traffic impacts on the riparian corridor or on wildlife is provided beyond the word minor. The agency should provide a site-specific analysis of road construction and traffic impacts within the Conservation Zone, including effects on adjacent NFS resources, before issuing a final decision.
- The document states the private road that goes through the non-Federal parcel will not be added to the NFS road system and therefore will not be maintained. This means the public land acquired will have a road infrastructure the agency will not maintain, yet the agency cites increased open and dispersed recreational opportunities such as hunting and backpacking as a public benefit of acquiring this parcel. The agency has not explained how public access will function on a parcel served only by an unmaintained road, or what the liability and safety implications are. The agency should analyze public access feasibility and safety on the non-Federal parcel given the decision not to add or maintain the existing road.
- The document discloses that a third-party NEPA consultant, ERO Resources Corporation, prepared the Biological Assessment, Biological Evaluation, and cultural resource survey -- the core technical documents underlying the FONSI -- yet the Forest Service simultaneously claims it relied upon subject matter experts to analyze the effects. The degree to which Forest Service specialists independently verified ERO's conclusions is not disclosed, raising a question about whether the agency conducted its own independent review as required by NEPA's hard look standard. The agency should disclose in the record the specific steps Forest Service specialists took to independently verify the third-party consultant's biological and cultural resource findings before relying on them for the FONSI.
- 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
- PendingSHPO determined the RTLC property is eligible for the National Register of Historic Places and that mitigation measures are needed to resolve adverse effects, yet the FONSI states no short- or long-te
SHPO determined the RTLC property is eligible for the National Register of Historic Places and that mitigation measures are needed to resolve adverse effects, yet the FONSI states no short- or long-term impacts on cultural resources are anticipated. These two statements directly contradict each other. A finding that adverse effects require mitigation is incompatible with a finding of no impact on cultural resources. The agency should either revise the FONSI to accurately characterize the adverse effect finding, or prepare an EIS that fully discloses and analyzes the cultural resource impacts.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe appraisal explicitly excluded the conservation easement when valuing the Federal parcel, meaning the CE was placed on land already conveyed at a higher, unencumbered value.
The appraisal explicitly excluded the conservation easement when valuing the Federal parcel, meaning the CE was placed on land already conveyed at a higher, unencumbered value. The document states the final appraised values were not subject to the CE and that the CE grant to Palmer Land Conservancy occurs in a subsequent transaction to the exchange. This means the public is giving up 94.3 acres appraised as though fully developable, then immediately encumbering that land with a CE -- a sequencing that inflates the apparent value of the Federal parcel and undermines the equal-value requirement. The agency should prepare a supplemental appraisal that values the Federal parcel subject to the conservation easement, or justify in writing why the unencumbered appraisal satisfies the equal-value mandate of 36 CFR 254.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingTribal consultation is described as ongoing and unresolved at the time of this decision.
Tribal consultation is described as ongoing and unresolved at the time of this decision. The document says tribal consultation is ongoing and the Forest Service will remain available to engage, yet a FONSI has already been issued. SHPO also found the RTLC site eligible for the National Register and stated mitigation measures are needed, with a memorandum of agreement still to be completed. Issuing a draft decision before Section 106 consultation and mitigation are finalized violates the sequencing required by 36 CFR 800. The agency should withhold the final Decision Notice until the MOA is signed and tribal consultation is formally concluded.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe document acknowledges the United States will dispose of up to 2.5 acres of wetlands and 25 acres of regulatory floodplain on the Federal parcel, yet concludes there are no short- or long-term impa
The document acknowledges the United States will dispose of up to 2.5 acres of wetlands and 25 acres of regulatory floodplain on the Federal parcel, yet concludes there are no short- or long-term impacts on wetlands and floodplains. The sole basis offered is that the conservation easement will protect these features, but the CE is held by a private land trust, not the federal government, and the CE was not valued in the appraisal. The agency has not analyzed what happens to those wetlands if the CE is ever violated or extinguished. The agency should analyze the long-term enforceability of the CE as the sole protection for 2.5 acres of wetlands now leaving federal ownership, or prepare an EIS addressing this gap.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe document states the NFS will lose approximately 13.3 acres of mapped suitable Canada lynx habitat on the Federal parcel and that the project may affect, not likely to adversely affect the Canada l
The document states the NFS will lose approximately 13.3 acres of mapped suitable Canada lynx habitat on the Federal parcel and that the project may affect, not likely to adversely affect the Canada lynx, yet the FONSI dismisses this as negligible in the context of the larger San Isabel National Forest. No acreage threshold, recovery plan standard, or population-level analysis is cited to support the conclusion that 13.3 acres of mapped lynx habitat leaving federal ownership is negligible. The agency should provide the quantitative basis -- such as the lynx conservation assessment or USFWS concurrence rationale -- for concluding that permanent loss of this mapped habitat does not rise to significance.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe document states only four comment letters were received during the 30-day comment period for the draft EA, compared to 32 letters during the earlier 45-day scoping period.
The document states only four comment letters were received during the 30-day comment period for the draft EA, compared to 32 letters during the earlier 45-day scoping period. This sharp drop suggests the draft EA comment period may not have been adequately publicized or may have been too short for meaningful public engagement on a document that was not released until after a lengthy planning process. The agency should explain in the record what outreach specifically targeted the 32 parties who commented during scoping, confirm each was directly notified of the draft EA comment period, and consider whether the 30-day window was sufficient.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe document states no water rights will be conveyed in the exchange and that no water rights are associated with the non-Federal parcel, yet the well on the Federal parcel sits approximately 400 feet
The document states no water rights will be conveyed in the exchange and that no water rights are associated with the non-Federal parcel, yet the well on the Federal parcel sits approximately 400 feet from Lake Creek. The conservation easement restricts transfer of well rights, but once the parcel is private, state water law -- not the CE -- governs well use and administration. The agency has not analyzed whether intensified camp development and increased water use from the well could affect Lake Creek flows or riparian habitat. The agency should analyze the potential hydrologic effects of expanded camp operations on Lake Creek under Colorado water law before issuing a final decision.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe document states a new road segment will be constructed within the Conservation Zone to access overnight and cookout areas, and that the option is retained to reroute NFS Road 198 within the Conser
The document states a new road segment will be constructed within the Conservation Zone to access overnight and cookout areas, and that the option is retained to reroute NFS Road 198 within the Conservation Zone, yet the FONSI states long-term impacts may result from increased traffic without quantifying traffic levels, road surface impacts, or dust and noise effects on adjacent NFS lands. No analysis of these construction and traffic impacts on the riparian corridor or on wildlife is provided beyond the word minor. The agency should provide a site-specific analysis of road construction and traffic impacts within the Conservation Zone, including effects on adjacent NFS resources, before issuing a final decision.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe document states the private road that goes through the non-Federal parcel will not be added to the NFS road system and therefore will not be maintained.
The document states the private road that goes through the non-Federal parcel will not be added to the NFS road system and therefore will not be maintained. This means the public land acquired will have a road infrastructure the agency will not maintain, yet the agency cites increased open and dispersed recreational opportunities such as hunting and backpacking as a public benefit of acquiring this parcel. The agency has not explained how public access will function on a parcel served only by an unmaintained road, or what the liability and safety implications are. The agency should analyze public access feasibility and safety on the non-Federal parcel given the decision not to add or maintain the existing road.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe document discloses that a third-party NEPA consultant, ERO Resources Corporation, prepared the Biological Assessment, Biological Evaluation, and cultural resource survey -- the core technical docu
The document discloses that a third-party NEPA consultant, ERO Resources Corporation, prepared the Biological Assessment, Biological Evaluation, and cultural resource survey -- the core technical documents underlying the FONSI -- yet the Forest Service simultaneously claims it relied upon subject matter experts to analyze the effects. The degree to which Forest Service specialists independently verified ERO's conclusions is not disclosed, raising a question about whether the agency conducted its own independent review as required by NEPA's hard look standard. The agency should disclose in the record the specific steps Forest Service specialists took to independently verify the third-party consultant's biological and cultural resource findings before relying on them for the FONSI.
A hole PLAN found in the agency’s own analysis, quote verified against the document
The reporting behind this
From More Than Just ParksAfter more than a decade chasing peak color across America, we built the foliage map we always wanted.
Another foreign mining company wants a piece of America’s public lands. This one comes with millions of gallons of groundwater pumping and radioactive radon.
The administration went looking for a sliver of Yosemite for a private developer and finally convinced the rest of public-lands world that if Yosemite is negotiable, nothing is safe.
More actions that need you
Go deeper, free
See how your members of Congress vote on public lands
Every representative, graded on the votes that decide the fate of parks, forests, and refuges.
Open ↗The mapSee the places under active threat
A live map of the parks, monuments, and wild country in the crosshairs right now.
Open ↗A wrong fact, a dead link, a form that wouldn’t take your letter: one tap and it comes to the people who build PLAN, with this fight attached.
Know an open comment period we are missing, or spotted a wrong deadline? .