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No baseline of visitation to the area is provided to attempt to apply economic analysis of recreational usage. The TPA and COHVCO submit that without the creation of a comparison between current usage and usage after implementation of the EA would be a violation of the Hughes River decision. Similarly, misleading economic assumptions can also defeat the second function of an EIS by skewing the public’s evaluation of a project.” The level of accuracy of the hard look at economic analysis applied by the Court in the Hughes River decision is significant as the Hughes River Court invalidated an EIS based on an error in economic contribution calculations of approximately 32%. The use of inflated economic benefits in this balancing process may result in approval of a project that otherwise would not have been approved because of its adverse environmental effects. NEPA requires agencies to balance a project’s economic benefits against its adverse environmental effects. For an EIS to serve these functions, it is essential that the EIS not be based on misleading economic assumptions.” The Court then discussed the significance of economic analysis in planning as follows: “Misleading economic assumptions can defeat the first function of an EIS by impairing the agency’s consideration of the adverse environmental effects of a proposed project. Second, it ensures that relevant information regarding proposed projects is available to members of the public so that they may play a role in the decision making process. First, it ensures that agencies take a hard look at the environmental effects of proposed projects. Relevant court rulings addressing economic analysis in NEPA have concluded: “an EIS serves two functions. Courts have consistently held agencies to a much tighter level of review of economic analysis when compared to other issues within the agency expertise in the NEPA process as the court makes their own conclusions regarding the accuracy of review without deference to agency findings. The Organizations feel this same standard would similarly apply to this EA.

of 109, Socioeconomic Impacts: The Organizations applaud consideration of the “Socioeconomic Impacts” of the three alternatives, however, the Organizations disagree that “All of the alternatives considered would have little positive or negative affect on the local economies because it would not result in substantial increases or decrease in revenue spent in the local area, or increases or decreases in population, wages, or employment.” The standard of review for economic analysis is a de novo standard as the Courts have consistently substituted their judgment regarding the accuracy of economic analysis.

The TPA and COHVCO are referred to collectively in this correspondence as “The Organizations.” The Organizations generally support the Proposed Action Alternative included in the Environmental Assessment (EA), however we present the following objections to the EA prepared for the Badger Flats Management Project. COHVCO is an environmental organization that advocates and promotes the responsible use and conservation of our public lands and natural resources to preserve their aesthetic and recreational qualities for future generations. COHVCO is a grassroots advocacy organization representing approximately 170,000 registered off-highway vehicle (“OHV”) users in Colorado seeking to represent, assist, educate, and empower all OHV recreationists in the protection and promotion of off-highway motorized recreation throughout Colorado. The TPA acts as an advocate for the sport and takes the necessary action to insure that the USFS and BLM allocate a fair and equitable percentage of public lands access to diverse trail riding opportunities. The TPA is a volunteer organization created to be a viable partner to public lands managers, working with the United States Forest Service (USFS) and the Bureau of Land Management (BLM) to preserve the sport of trail riding.

The following objections are submitted in regards to the Badger Flats Management Project, Environmental Assessment (EA) on behalf of the Trails Preservation Alliance (“TPA”) and the Colorado Off-Highway Vehicle Coalition (“COHVCO”). RE: Objections to the Badger Flats Management Project Environmental Assessment South Park Ranger District, Pike & San Isabel National Forest October 2016 Objections to the Badger Flats Management Project Environmental Assessment