MEMORANDUM AND ORDER
Plaintiffs Amy Granat, Corky Lazzarino, the Sierra Access Coalition, the California Off-Road Vehicle Association, and the Counties of Butte and Plumas filed this action against numerous federal defen
BACKGROUND
In 2005, the U.S. Forest Service issued the Travel Management Rule. Travel Management, 70 Fed. Reg. 68,264 (Nov. 9, 2005) (codified at 36 C.F.R. pts. 212, 251, 261, 295). Relevant to the current litigation, that rule requires the Forest Service to designate a system of roads, trails, and areas open to motor vehicle use by vehicle type and time of year. 36 C.F.R. § 212.50(a). “After these roads, trails, and areas are designated, motor vehicle use, including the class of vehicle and time of year, not in accordance with these designations is prohibited....” Id.
Prior to the enactment of the Travel Management Rule, Plumas National Forest contained approximately 4,267 miles of routes that were designated as part of the National Forest Transportation System (“NFTS”): 4,137 miles of National Forest Service roads and 130 miles of National Forest Service motorized trails. PLU-B-000053.
The Forest Service held a series of public workshops and public meetings, as well as solicited public comment, to help determine which of the user-created routes should be added to the NFTS. See PLU-B-000058 to -000059. By April 2007, the Forest Service completed a “first cut” route map, consisting of 220 miles of routes. PLU-B-000058. The Forest Service then held another series of public meetings and workshops, allowing the public to identify routes to be considered for inclusion in the NFTS, leading the Forest Service to expand its consideration to 410 miles of routes. PLU-B-000058, -000081.
In December 2008, the Forest Service released its Draft Environmental Impact Statement (“DEIS”). PLU-B-000649. After another period of public comments, the Forest Service released its Final Environmental Impact Statement (“FEIS”) in August 2010. PLU-B-000039. Those documents considered four action alternatives in detail for potential additions to the NFTS, as well as a no-action alternative. On August 30, 2010, the Forest Service released the Record of Decision, which selected Action Alternative 5 from the evaluated alternatives. PLU-B-000014 to -
On March 18, 2015, Plaintiffs filed the instant suit, challenging the procedures used to implement the resultant Motorized Travel Management Plan. Compl., ECF No. 1. Plaintiffs are individuals who visit Plumas National Forest, as well as organizations that represent visitors to the Forest. Plaintiff Amy Granat has visited the Forest since 2001. Decl. of Amy Granat, ECF No. 31-4, ¶15. She suffers from a disability that limits her ability to walk, and alleges that the Motorized Travel Management Plan drastically reduced her ability to enjoy the Forest by limiting the areas she can reach by motor vehicle. |d. ¶¶ 15-16. Plaintiff Corky Lazzarino also visits Plumas National Forest, and claims that the Motorized Travel Management Plan limits her ability to access parts of the Forest she previously enjoyed. Decl. of Corky Lazzarino, ECF No. 31-5, ¶¶ 9-10. Plaintiff California Off-Road Vehicle Association (“CORVA”) is a non-profit corporation, whose members have been prevented from using user-created routes that were not added to the NFTS for motorized recreation. Decl. of Granat, ¶¶ 2, 7. Plaintiff Sierra Access Coalition is an organization representing its members who previously used routes that were not added to the NFTS. Decl. of Lazzarino, ¶¶ 3, 5.
Plaintiffs also include two governmental bodies: Plumas County and Butte County. Approximately 975,000 acres of the Plumas National Forest are located within Plumas County, while approximately 100,000 acres are located within Butte County. Decl. of Robert Armand Perreault, Jr., ECF No. 31-6, ¶4; Decl. of John Michael Crump, ECF No. 31-3, ¶4. Both claim that the Motorized Travel Management Plan limits the ability of their citizens to access Plu-mas National Forest. Decl. of Perreault, ¶5; Decl. of Crump, ¶5. Plumas County also claims the Motorized Travel Management Plan reduces tourism and thereby harms its citizens who rely on tourism for income, as well as the County’s own tax revenues on that income. Decl. of Per-reault, ¶ 6.
Defendants are the U.S. Department of Agriculture, the U.S. Forest Service (a subdivision of the Department of Agriculture), and various officers of the Department of Agriculture and Forest Service in their official capacities.
PROCEDURAL FRAMEWORK
Congress enacted NEPA in 1969 to protect the environment by requiring certain procedural safeguards before an agency takes action affecting the environment. The NEPA process is designed to “ensure that the agency ... will have detailed information concerning significant environmental impacts; it also guarantees that the relevant information will be made available to the larger [public] audience.” Blue Mountains Biodiversity Project v. Blackwood,
NEPA requires that all federal agencies, including the Forest Service, prepare a “detailed statement” that discusses the environmental- ramifications, and alternatives, to all “major Federal Actions significantly affecting the quality of the human environment.” 42 U.S.C. § 4332(2)(c). An agency must take a “hard look” at the consequences, environmental impacts, and adverse environmental effects of a proposed action within an environmental impact statement (“EIS”), when required. Kleppe v. Sierra Club,
Given its status as a statutory scheme safeguarding procedure rather than substance,
Because NEPA itself contains no provisions allowing a private right of action, see Lujan v. Nat’l Wildlife Fed'n,
Under the APA, the court must determine whether, based on a review of the agency’s administrative record, agency action was “arbitrary and capricious,” outside the scope of the agency’s statutory authority, or otherwise not in accordance with the law. Salmon River Concerned Citizens v. Robertson, 32 F,3d 1346, 1356 (9th Cir. 1994). Review under the APA is “searching and careful.” Ocean Advocates v. U.S. Army Corps of Engineers,
In reviewing an agency’s actions, then, the standard to be employed is decidedly deferential to the agency’s expertise. Salmon River,
STANDARD
Summary judgment is an appropriate procedure in reviewing agency decisions under the dictates of the APA. See, e.g., Nw. Motorcycle Ass’n v. U.S. Dept. of Agric.,
ANALYSIS
Plaintiffs make several challenges to the Motorized Travel Management ' Plan, claiming that Defendants violated NEPA, the Travel Management Rule, or otherwise acted arbitrarily and capriciously. The Court addresses each in turn.
A. Defendants’ “First Cut” Did Not Violate NEPA or the Travel Management Rule
Plaintiffs first challenge Defendants’ so-called “first cut,” claiming that the initial rejection of 697 miles of the unauthorized trails violates NEPA’s “rule of reason” and ignores factors enumerated in the Travel Management Rule. See Pis.’ Resp. & Reply, ECF. No. 38, at ,1—3 (citing Dep’t of Transp. v. Pub. Citizen,
Plaintiffs challenge the sufficiency of the data Defendants used in performing their “first cut.” Pls.’ MSJ, at 12. They complain that “[o]nly 410 of the unclassified miles ... received any on-site environmental impacts review.” Id. Thus, they conclude, “the Forest Service ignored its duties to identify, evaluate, and disclose on-site conditions before determining whether the routes actually met the environmental and recreational criteria of the Travel Management Rule.” Id. at 13. It is unclear, however, what exactly Plaintiffs would deem sufficient. They reject Defendants’ contention that they are “demanding] that every inch of all 1,107 miles of the Plumas National Forest’s non-system routes be analyzed for inclusion in the [NFTS],” and instead object to the fact that Defendants “fail[ed] to verify on-the ground its resource and access analyses for any of the some 700 miles of non-system routes that the project shut down.” Pis.’ Resp. & Reply, at 1-3. Plaintiffs do not, however, provide any suggestion as to how much “on the ground”; verification would have been sufficient, and fail to demonstrate that additional verification would have provided any information relevant to the project. The rule of reason analysis is “a pragmatic judgment whether
Defendants populated their inventory of routes by relying on “previous records,” such as “maintenance plans, maintenance expenditures, existing road and trail atlases, forest maps, etc.” PLU-B-000052. They then made their first cut, “avoiding] routes on private land with no right of way, routes where motorized use would conflict with existing uses, and routes with measurable resource impacts.” PLU-B-000058. Next, Defendants asked the public “to identify which of the routes and areas should become part of the proposed action, the type of use that each would have, and routes to be considered for dispersed recreation access.” Id.
Plaintiffs have identified seventeen routes that they complain did not receive “on the ground” verification, but they do not identify what information would have been discovered by such verification. Pis.’ Resp. & Reply, at 2 n.l. Defendants analyzed all seventeen of those routes, and provided reasons for their exclusion. See PLU-D-012271 to -012273. Plaintiffs have not shown that their requested “on the ground” verification would have discounted the factual bases for those exclusions.
Plaintiffs also contend that “[ejven if [Defendants] had adequately verified [their] data,” the “first cut” did not comport with the Travel Management Rule because it did not consider the enumerated factors contained in that Rule. Pls.’ Resp. & Reply, at 2-3 (citing 36 C.F.R. § 212.55(a)). However, the Travel Management Rule only requires such factors to be considered when “designating National Forest System roads, National Forest System trails, and areas on National Forest System lands for motor vehicle use.” 36 C.F.R. § 212.55(a) (emphasis added). In its “first cut,” Defendants did not designate any routes as part of the NFTS, but instead took a first pass at identifying which routes would be considered for designation. Accordingly, the factors articulated in the Travel Management Rule were inapplicable to the 697 miles of unauthorized routes that did not make the “first cut.” Cf. Klamath-Siskiyou Wildlahds Ctr. v, Graham,
B. Defendants Considered a Reasonable Range of Alternatives
Plaintiffs similarly claim that the Defendants’ “first cut” methodology prevented Defendants from considering a reasonable range of alternatives, as required by NEPA. Pis.’ MSJ, at 16-17. Plaintiffs rely primarily on a document promulgated by the Council on Environmental Quality (“CEQ”), see Pls.’ MSJ, at 17-18, which states: “An appropriate series of alternatives might include dedicating 0, 10, 30, 50, 70, 90 or 100 percent of the Forest to wilderness,” Forty Most Asked Questions Concerning CEQ’s National Environmental Policy Act Regulations, 46 Fed. Reg. 18,026, 18,027 (Mar. 23, 1981) [hereinafter Forty Questions]. By only considering about 33% of the unauthorized routes, the Forest Service did not consider “a reasonable range of alternatives under the CEQ [document].” Pis.’ MSJ, at 18. However, even if the CEQ document is “ ‘entitled to substantial deference’ as an interpretation of NEPA,” Block,
What is considered a reasonable range is determined in light of the purpose and need of the project. See Cent. Sierra Envtl. Res. Ctr. v. U.S. Forest Serv.,
The purpose of a reasonable range of alternatives is to “foster[] informed decision-making and informed public participation.” Headwaters, Inc, v. Bureau of Land Mgmt.,
The range of alternatives fostered informed decision-making and informed public participation, and so Defendants ful
C. The Prohibition of Non-Highway Legal Vehicles from Maintenance Level Three Roads Was Reasonable
Plaintiffs argue that Defendants violated their own procedures in prohibiting Off-Highway Vehicles (“OHVs”) from all Maintenance Level Three roads in the Forest because they “failed to provide data that demonstrates that the Maintenance Level 3. ban is the minimum restriction required to provide for user safety.” Pis.’ MSJ, at 15. Plaintiffs contend that Defendants’ procedures required them “to perform appropriate engineering analyses” before making such a determination. Id. Because agencies must follow their own procedures, they conclude, the prohibition on OHVs from Maintenance Level Three roads was unlawful. Id,; see also Morton v. Ruiz,
None of the documents Plaintiffs cite stand for the proposition that an engineering analysis must be conducted before prohibiting OHVs from Maintenance Level Three roads. They all, in fact, state almost the entirely opposite proposition: Such analyses need to be conducted when allowing OHVs on Maintenance Level Three roads. E.g.j PLU-D-00008356 (“The analysis that supports a decision to allow mixed use on Maintenance Level 3-5 roads must consider the probability and severity of accidents.” (emphasis removed)). Thus, the Forest Service did not act unlawfully because it did not contravene its own procedures.
Plaintiffs also contend that the Forest Service “does not generally prohibit mixed use” on Maintenance Level Three roads, but instead that “such use normally depends on state traffic law.” Pis.’ Resp. & Reply, at 7-8 - (citing 36 C.F.R. § 212.5(a)(1)). Thus, they continue, Defendants’ default position of prohibiting OHVs from such roads derives from their interpretation of state law, and that interpretation deserves no deference. Id. at 8. Plaintiffs, however, ignore a key exception to the relevant regulations. State traffic laws apply only to the extent they are not “in conflict with” the Forest Service’s designations and authority to restrict “use by certain classes of vehicles or types of traffic.” 36 C.F.R. § 212.5(a). Though Defendants may have relied in part on state traffic laws to determine what kinds of vehicles should be allowed on Maintenance Level Three roads, see Defs.’ Opening Br., ECF No. 37-1, at 14, their authority to designate which kinds of vehicles may be used on which kinds of roads does not depend on state law. Plaintiffs have therefore not demonsti’ated that the prohibition of OHVs from all Maintenance Level Three roads is arbitrary or capricious or otherwise unlawful.
D. Defendants Properly Coordinated with Local Governments Under NEPA and the Travel Management Rule
NEPA requires agencies to “cooperate with State and local agencies to
Plaintiffs argue that Defendants violated these requirements by failing to coordinate with Butte and Plumas Counties and by failing to address conflicts with certain of the Counties’ road and transportation plans. Pis.’ MSJ, at 20-21. County roads that lead into the Plumas National Forest allow OHVs, and Plaintiffs claim that the prohibition of such vehicles on Maintenance Level Three roads conflicts with the Counties’ policies. Id. at 23. Plaintiffs also claim that the DEIS and FEIS failed to consider “the connection between Plumas National Forest routes and the road system of the Counties” and “the opportunities for County roads to serve as connectors between Plumas National Forest routes for motorized vehicle use.” Id. Plaintiffs have again failed to show that Defendants did not fulfill their obligations under NEPA or the Travel Management Rule.
First, Plaintiffs claim that Defendants’ engagement with the Counties was no “more than the general public notice and comment afforded all interested parties under the Travel Management Rule and NEPA” Pis.’ Resp. & Reply, at 8. Defendants, however, did not limit the Counties’ participation to the general ability of the general public to participate in the notice and comment process. The record shows that four formal meetings and six informal meetings took place between Defendants and Plumas County officials. PLU-A-000057; see also PLU-E-000058 (list of informal meetings with Plumas County officials). Similarly, Defendants “offered to set up private, individual meetings with two Butte County Supervisors.” Id. Defendants also corresponded with County officials about the project. See, e.g„ PLU-D-007890 (exchanging maps via email).
Second, Plaintiffs complain that Defendants did not “consider the opportunities for County roads to serve as connectors between Plumas National Forest routes for motorized vehicle use.” Pis.’ MSJ, at 23. This, however, is also belied by the record. For example, in response to a comment to the DEIS, Defendants stated that “we will utilize county roads as connectors” and that county roads would appear on the ultimate Motor Vehicle Use Map. PLU-B-001223. Plaintiffs’ objection is therefore more properly characterized as substantive. They object to the Forest Service’s decision to “institute!!] an across-the-board ban on off-road vehicle use on Maintenance Level 3 roads in the Forest, even though the Counties allow off-road vehicle use oh County roads of a similar design, surface type, and maintenance level.” Pis.’ MSJ, at 23. The Forest Service’s ultimate decision, though, does not demonstrate a lack of coordination or a lack of
Finally, Plaintiffs claim insufficient coordination on the basis that the FEIS lacks any description of “the consistency, or conflicts of, the Forest Service’s preferred alternative with local plans, policies, or controls.” Pis.’ MSJ, at 24. Defendants argue that Plaintiffs have failed to identify any inconsistency between the Forest Service’s decisions and the Counties’ plans, and only show that the Counties’ preferences do not align with the Forest Service’s. Defs.’ Opening Br., at 18. Defendants have the better argument. Plaintiffs do not identify any plans or policies that conflict with the Motorized Travel Management Plan. For example, Plaintiffs show that Butte County opposed aspects of the Motorized Travel Management Plan because it “will have a significant negative impact on the area’s transportation and circulation system.” Pis.’ Resp. & Reply, at 9-10 (quoting PLU-A-000321). Merely because the Motorized Travel Management Plan has a “significant negative impact on the area’s transportation and circulation system,” however, does not demonstrate any conflict between the Motorized Travel Management Plan and the County’s policies or plans. Plaintiffs also indicate that Plumas County objected to the elimination of “many routes intersecting the Mr. Hough Road (a Plumas County Road).” Id. at 10 (quoting PLU-A-000151). That Plu-mas County might have preferred that such roads be designated part of the NFTS does not demonstrate a conflict with a County plan or policy that required comment or discussion in the FEIS.
E. Defendants Took the Required “Hard Look” at the Impacts on the Human Environment
Next, Plaintiffs claim that Defendants failed to analyze the Motorized Travel Management Plan’s impact on “the human environment,” that is, its “economic or social ... effects.” Pis.’ MSJ, at 24 (quoting 40 C.F.R. § 1508.14). Specifically, Plaintiffs claim that “[t]he Forest Service failed to take into account the fact that many Forest users cannot access Forest areas ... without first using motorized vehicles to reach those areas,” failed to account for the “impacts that the drastic reduction in motorized vehicle access would have on the ability of the public to access the forest to obtain food and fuel,” and failed to analyze how the Plan “could impact tourism and recreational opportunities in Plumas County.” Id. at 25-26.
Once again, Plaintiffs’ claims are belied by the record. Contrary to Plaintiffs’ assertions, Defendants addressed the public’s ability to cut firewood. See PLU-B-001216 (“It is believed that fuel wood cutting will not be significantly [a]ffected by the reduced amount of access. The public will find sufficient areas to meet their firewood needs.”). The Forest Service also addressed impacts to dispersed recreation. See, e.g., PLU-B-000097 (showing the accessibility of dispersed recreation under the four action alternatives, which ranged from 75 to 92 percent). Finally, the FEIS explicitly analyzed both the economic impact of the Motorized Travel Management Plan as well as its impact on recreational opportunities. See PLU-B-000564 to - 000577.
F. Defendants Adequately Responded to Commends During the Public Comment Period
NEPA requires that an FEIS address comments by the following means, as appropriate:
(1) Modify alternatives including the proposed action.
(2) Develop and evaluate alternatives not previously given serious consideration by the agency.
(3) Supplement, improve, or modify its analyses.
(4) Make factual corrections.
(5) Explain why the comments do not warrant further agency response, citing the sources, authorities, or reasons which support the agency’s position and, if appropriate, indicate those circumstances which would trigger agency reappraisal or further response.
40 C.F.R. § 1503.4. “An agency need only respond to ‘significant comments,’ those which, ‘if adopted, would require a change in the agency’s proposed rule.’” Idaho Farm Bureau Fed’n v. Babbitt,
Plaintiffs contend that Defendants failed to meet these requirements with respect to several comments made during the notice and comment process. Specifically, they contend that Defendants failed to adequately respond to (1) comments “that the Forest Service’s proposed action would have negative impacts on the variety of motorized vehicle riding experiences” in the Forest; (2) several comments made by CORVA; (3) “comments made by Butte County asking the Forest Service to consider non-paved County maintained roads as mixed use roads;” or (4) Plumas County’s comment in opposition to the Forest Service’s decision to prohibit “limited vehicle use near designated routes.” Pis.’ MSJ, at 26-27.
The administrative record, however, shows that all the identified comments were replied to appropriately. First, regarding the alleged failure to address the variety of experiences available for motorized recreation, Defendants responded to the comment directly, determining that “[t]he abundance of System Roads will provide ample opportunity for the motorized user.” PLU-B-001168. The FEIS also addressed the impact of the action alternatives on motorized recreation, specifically concluding that the preferred alternative “would have a beneficial effect on motorized opportunities.” PLU-B-000110; see also PLU-B-000094 (explaining that the FEIS used mileage as “an indicator of the number and types of experiences available for motorcycles, ATVs, and 4WDs in each alternative”).
Second, Defendants responded appropriately to comments made by CORVA. For the most part, Plaintiffs generally object that the Forest Service’s responses simply “acknowledged” CORVA’s comments. See Pis.’ MSJ, at 27. They specifically identify only one comment in which CORVA critiques the amount of input the Forest Service received from the public as “not a statistically significant sample.” PLU-B-001582 to -001583. To this comment, the Forest Service responded: “Comment acknowledged; does not provide new information.” Id. CORVA’s comment was not a “significant comment” that required anything more in response. It essentially only expressed dissatisfaction with the number of people who provided comments and participated in the rule-making process. It did not provide solutions to the perceived problem or provide new information. Therefore, it was not a comment that, “if adopted, would require a change in the agency’s proposed rule.” Idaho Farm Bureau Fed’n,
Third, Defendants adequately responded to Butte County’s request to consider non-paged County maintained roads as mixed use roads. Defendants responded, “[W]e will utilize county roads as connectors.” PLU-B-001223.
Plaintiffs have only identified dissatisfaction with the ultimate decisions made by Defendants in adopting the Motorized Travel Management Plan. All the identified comments received adequate responses as required under NEPA.
, G. NEPA Did Not Require a Supplemental Draft Environmental Imr pact Statement
NEPA requires that agencies prepare supplements to “either draft or final environmental impact statements if ... [t]he agency makes substantial changes in the proposed action” or if “[t]here are significant new circumstances or information.” 40 C.F.R. § 1502.9(c)(1). In either case, the changes must be “relevant to environmental, concerns.” Id. Plaintiffs claim that eight changes that were “presented for the first time in the FEIS” demanded such a supplement:
(1) restrictions on routes according to season of use, (2) implementation of a one-fourth mile buffer for wildlife nests, (3) implementation of a one-half mile buffer for private land “quiet recreation,” (4) the closure of additional roads and trails because the analysis of potential impacts to the California red-legged frog from the continued use of these roads was not completed in a timely manner, (5) 47% of single-track routes in the French Creek area were closed, (6) the Sly Creek area routes were eliminated, (7)'13 National Forest Transportation System routes were eliminated from the map of available routes in the French Creek area, and (8) the Law Enforcement Section (Appendix I) was added.
Pis.’ MSJ, at 28 (citations omitted). Plaintiffs claim that these each were substantial changes to the project. Plaintiffs, however, are incorrect.
Six of Plaintiffs’ objections concern the Forest Service’s decision to either not include or limit use of certain trails when incorporated in the NFTS. Plaintiffs do not demonstrate that the non-inclusion of these trails substantively affected the Motorized Travel Management Plan. Instead, the modifications are all “minor variation[s]’’ that fall “qualitatively within the spectrum of alternatives,” Great Old Broads for Wilderness v. Kimbell,
The remaining two objections are similarly without merit. Plaintiffs imply, without support, that the Forest Service used a new measurement that “play[ed] a key role in the final impact statement’s assessment of the recreational effects of each of the alternatives,” by not defining the term
H. Defendants Were Not Required to Prepare a Cumulative Impacts Statement for Effects Beyond the Borders of the Forest
“NEPA requires that where several actions have a cumulative or synergistic environmental effect, this consequence must be considered in an EIS.” City of Tenakee Springs v. Clough,
CONCLUSION
For the reasons given above, Plaintiffs’ Motion for Summary Judgment, ECF No. 31, is DENIED and Defendants’ Cross-Motion for Summary Judgment, ECF No. 37, is GRANTED. Furthermore, Defendants’ Motion to Strike, ECF No. 36, is GRANTED IN PART and DENIED IN PART. The matter having now been concluded in its entirety, the Clerk of Court is directed to close the file.
IT IS SO ORDERED.
Notes
.Defendants also made a Motion to Strike declarations filed by Plaintiffs in support of their MSJ. ECF No. 36. They argue that the declarations constitute improper attempts to supplement the administrative record. Defs.’ Mem. in Supp. of Mot. to Strike, ECF No. 36-1, at 2. Plaintiffs, for their part, argue that the declarations establish standing to challenge the Defendants’ actions. Pis.' Resp. to Mot. to Strike, ECF No. 39, at 1. The Court acknowledges Plaintiffs' standing argument and disregards the declarations for any other purpose.
. Because oral argument would not have been of material assistance in rendering a decision, the Court ordered this matter submitted on the briefs. E.D. Cal. Local Rule 230(g).
. All citations to the administrative record lodged with the Court are specified following the format used by the parties: “PLU-[volume]-[bates number].”
. The • National Forest Management Act ("NFMA”), 16 U.S.C. §§ 1600-14, provides for substantive, as opposed to procedural protection with regard to actions that affect the environment. Plaintiffs have not alleged any violation of the NFMA through this lawsuit,
. Plaintiffs point to two maps that they claim show the data used by Defendants was inaccurate, see Pis.' Resp. & Reply, at 2, but Plaintiffs do not identify any routes that were eliminated by this supposedly inaccurate data, let alone that on-site analysis would have corrected these supposed inaccuracies.
. Plaintiffs acknowledge that the Travel Management Rule does not define "coordination” and so rely on NFMA's coordination requirements at the time. See Pis.’ Resp. & Reply, at 8-9. As noted above, Plaintiffs have not pleaded an NFMA claim, so the precise terms of the NFMA regulations carry little, if any, weight here. It does not follow that NEPA or the Travel Management Rule incorporates NFMA’s substantive requirements simply because the NFMA regulations contain a section entitled, "Coordination with other public planning efforts.” 36 C.F.R. § 219.7 (1983).