Full opinion text
MEMORANDUM OPINION AND ORDER CUMMINGS, District Judge. On this date the Court considered Plaintiffs’ (DMTPHA) Motion for Summary Judgment filed on October 17, 2002, by Davis Mountains Trans-Pecos Heritage Association, et al. (“Plaintiffs”). The United States Air Force, et al. (“Defendants”) filed Defendants’ Response to Plaintiffs’ Motion for Summary Judgment on December 18, 2002. On January 17, 2003, Plaintiffs filed Plaintiffs’ Reply in Support of Its Motion for Summary Judgment. After considering all the relevant arguments and evidence, the Court DENIES Plaintiffs’ Motion for Summary Judgment. On this date the Court concurrently considered Defendants’ Motion to Strike Extra-Record Declarations and Materials Attached to Plaintiffs’ Motion for Summary Judgment filed December 18, 2002. Plaintiffs’ Response and Brief in Opposition to Defendants’ Motion to Strike Extra-Record Declarations and Materials Attached to Plaintiffs’ Motion for Summary Judgment was filed on January 17, 2008. Defendants filed no reply. After considering all the relevant arguments and evidence, the Court GRANTS Defendants’ Motion to Strike Extra-Record Declarations and Materials Attached to Plaintiffs’ Motion for Summary Judgment. On this date the Court concurrently considered Plaintiffs’ Motion and Brief in Support of Motion to Strike Defendants’ Post Hoc Declarations of Bowles, Cormier, Sku-jins, and Fidell filed January 17, 2003. Defendants filed no response. After considering all the relevant arguments and evidence, the Court GRANTS Plaintiffs’ Motion to Strike Defendants’ Post Hoc Declarations of Bowles, Cormier, Skujins, and Fidell. On this date the Court concurrently considered Defendants’ Cross-Motion for Summary Judgment filed December 18, 2002. Plaintiffs’ Response to Defendants’ Cross Motion for Summary Judgment was untimely filed on January 17, 2003. Defendants filed no reply. After considering all the relevant arguments and evidence, the Court GRANTS Defendants’ Cross-Motion for Summary Judgment. I. FACTUAL BACKGROUND A. Parties Plaintiff Davis Mountains Trans-Pecos Heritage Association (individually “DMTPHA”) is a non-profit association incorporated in Texas and is a regional chapter of the Trans Texas Heritage Association. DMTPHA’s principal office is located in Alpine, Brewster County, Texas. The members of DMTPHA represent over 13 million acres of privately owned land in the region. DMTPHA properties include land located in Brewster, Culberson, Hudspeth, Jeff Davis, Pecos, Presidio, and Reeves Counties. These properties are used for ranching, agriculture, personal residences, tourism and hunting operations, commercial cattle operations, and various modes of recreational enjoyment of the land. The properties also include structures of his-torie significance and represent several generations of family holdings. Dale and Susan Toone; Tim and Rexann Leary; Earl and Sylvia Baker; Mark and Ann Daugherty; Dick R. Holland; J.P. Bryan; Jackson B. “Ben” Love, Jr.; and Kaare J. Remme (collectively “Individual Plaintiffs”) are landowners or business operators situated in Brewster, Hudspeth, Pecos, and Reeves Counties in far west Texas. Individual Plaintiffs collectively own and control vast acres of land which are used for, inter alia, ranching, quail hunting, farming, and eco-tourism. In addition, two of the Individual Plaintiffs operate small private aircraft utilizing private takeoff and landing strips on their respective properties to conduct unscheduled overflights of their land. DMTPHA representatives and Individual Plaintiffs participated in the review process of proposals for the Final Environmental Impact Statement (“FEIS”). DMTPHA and Individual Plaintiffs submitted oral and written comments as part of this review process. Defendants include the United States Air Force, the United States Department of Defense, the United States Secretary of the Department of Defense, and various individual United States military personnel sued in their official capacities. B. Final Environmental Impact Statement In January 2000 Defendants made public the FEIS which had been prepared to assist Defendants in determining whether to implement the Realistic Bomber Training Initiative (“RBTI”). Of the four alternatives evaluated by the FEIS to fulfill the purpose of the RBTI, Defendants elected to implement Alternative B. The RBTI’s purpose is to establish a set of linked training assets (1) to permit aircrews from Barksdale Air Force Base (“AFB”) and Dyess AFB to train for various missions while maximizing combat training time; (2) to provide linkage of airspace and other assets that support realistic training of bomber aircrews; and (3) to ensure flexibility and variability in the training of support bomber combat missions. The four RBTI alternatives consisted of Alternative A No Action; Alternative B Instrument Route (IR)-178/Lancer Military Operations Area (MOA), 85 percent existing airspace; Alternative C IR-178/Texon MOA, 80-percent existing airspace; Alternative D IR-153/Mt. Dora MOA, 90 percent existing airspace. Under Alternative A, Defendants’ bombers would continue to use existing airspace and existing Electronic Scoring Sites (“ESS”) at current levels. Alternatives B, C, and D each involve (1) changes in the structure and use of the airspace, including some additional airspace and some eliminated airspace; (2) decommissioning the ESS at both Harrison, Arkansas, and La Junta, Colorado; and (3) construction of ten new electronic threat emitter sites and two ESS. Alternatives B and C he almost wholly in western Texas, while Alternative D is located in northeastern New Mexico. Defendants admit that aircraft noise levels would increase 2-13 decibels (“dB”) in Alternatives B and C airspace and 1-18 dB in Alternative D airspace. The percentage of “highly annoyed” persons could rise under Alternative B, IR-178, by eight percent, and Defendants concede that increases in noise levels from RBTI aircraft could be perceived by some as affecting their quality of life. Defendants also acknowledge that Alternatives B and C would necessitate overflights of two special use land management areas (e.g., state parks, scenic rivers) but point out that Alternative D would necessitate overflights of thirteen such areas. Both Alternatives B and C would cause a potential disturbance of the aplomado [lead-colored] falcon historic range where eleven sightings of aplomado falcons have occurred since 1992, but Mexican spotted owls and bald eagles, both federally listed as threatened or endangered species, are found within Alternative D’s airspace. Defendants admit that the current minimum altitude for segment BC of IR-178 is 400 feet above ground level (“AGL”) and the current minimum altitude for segment AB of IR-178 is 1,000 feet AGL. Defendants admit that the current minimum altitude for segment JK of IR-178 is 200 feet AGL but specifically note that the minimum altitude for segment JK of IR-178 under Alternative B will be raised to 300 feet AGL. Defendants also acknowledge that the minimum altitude for segment IJ of IR-178 under Alternative B will be 300 feet AGL. C. Record of Decision After considering the FEIS and the environmental consequences involved with each of the above alternatives, together with public comments and agency input, Defendants signed the Record of Decision (“ROD”) for the RBTI on March 24, 2000, and elected to implement Alternative B. Defendants assert that they selected Alternative B because the proposed RBTI operational and training assets located within approximately 600 nautical miles of Alternative B’s Barksdale and Dyess AFBs would include the following: 1.A Military Training Route (“MTR”) that (a) offers variable terrain for use in terrain-following and terrain-avoidance training flights; (b) overlies lands capable of supporting electronic threat emitters and ESS that permit flights down to 200 feet AGL; and (c)links to a MOA. 2. A MOA measuring at least 40x80 nautical miles with a floor of 3,000 feet AGL and extending to 18,000 feet above mean sea level (“MSL”) used for avoiding simulated threats and simulated attacks. 3. An Air Traffic Control Assigned Area (“ATCAA”) above the MOA at 18,000 to 40,000 feet MSL to be used for high-altitude training. 4. Availability of, through lease or purchase, a set of five locations (15 acres each) under or near the MTR corridor, and an additional five locations (15 acres each) under or near the MOA, for placing electronic threat emitters that would simulate the variety of realistic threats expected in combat. 5. Two ESS which would be co-located with operations and maintenance centers, one under or near the MTR corridor and the other en route from the AFBs to the MTR and MOA, each to be constructed on leased, purchased, or Air Force-owned property. Defendants’ ROD also confirmed the decommissioning of two existing ESS located in Harrison, Arkansas, and La Junta, Colorado. Defendants contend that these existing sites do not provide the required operational training assets outlined in 1-3 above. Defendants have also presented mitigation measures designed to reduce the potential for adverse effects to citizens and resources, including, but not limited to 1. reevaluating the potential impact of the RBTI on the aplomado falcon habitat; 2. considering construction alternatives in connection with roads, telephone lines, and power lines; 3. restructuring the MOA to measure at least 40x80 nautical miles with a floor of 6,200 feet MSL (raised from the originally established floor of 3,000 feet AGL) and extending to 18,000 feet MSL; 4. raising the floor of segment RS (new AB-AC) of IR-178 from the current 200 feet AGL to 800 feet AGL; raising the floor of segment ST (new AA-AB) of IR-178 from the current 200 feet AGL to 1,200 feet AGL; and raising the floor of IR-178 reentry routes to 6,200 feet MSL; 5. relocating ESS and electronic threat emitter sites to avoid historical sites, homes, large structures, and obvious bodies of water; and 6. limiting the annual sortie operations to pre-RBTI levels of 1,560/year (about 6/day). D. Plaintiffs ’ Claims for Relief Second: Violation of the National Environmental Protection Act (“NEPA”), Failure to Adequately Consider Environmental Impacts Plaintiffs argue that Defendants have failed to adequately consider and evaluate the environmental impacts the proposed RBTI would have on, inter alia, noise levels, human safety and health, livestock, air quality, wildlife and birds, private property takings or property devaluation, local custom and culture of affected communities, access to and safety of the operations of regional charted and uncharted airfields, and ranching, commercial, and recreational activities. Third: Violation of NEPA, Failure to Consider Appropriate No Action Alternative Plaintiffs argue that Defendants failed to adequately consider an appropriate No Action alternative and faded to accurately describe current overflight routes, authorizations, and environmental effects for the Trans-Pecos region and surrounding regions. Fourth: Violation of NEPA, Failure to Prepare Adequate Environmental Documentation for IR-178 Activities Plaintiffs argue that Defendants’ current and ongoing operations within IR-178 are not supported by the requisite environmental documentation necessary under NEPA. Plaintiffs allege that Defendants’ IR-178 documentation is outdated, does not reflect current conditions or impacts, has not been supplemented as required by law, and otherwise does not comply with NEPA requirements. Fifth: Violation of NEPA, Failure to Adequately Respond to Public Comments Plaintiffs complain that Defendants did not adequately or meaningfully respond to numerous public comments received by Defendants and that Defendants failed to identify and incorporate opposing views into the decisionmaking process. Sixth: Violation of NEPA, Inadequate Discussion of Mitigation Measures In violation of NEPA’s “reasonably complete” standard, Plaintiffs contend that Defendants have failed to adequately address mitigation measures with respect to airspace and aircraft operations, land management and land use, wildlife, and cultural and recreational resources. Seventh: Violation of NEPA, Failure to Adequately Consider Cumulative Impacts Plaintiffs complain that Defendants did not consider all cumulative impacts potentially resulting from the effects of the RBTI when added to other past, present, and reasonably foreseeable actions affecting Plaintiffs. Plaintiffs also complain that Defendants have failed to identify or to adequately discuss the impact of past activities in the region so that the aggregate cumulative effect of past, present, and reasonably foreseeable actions may be identified. Eighth: Violation of NEPA, Improper Scope of Environmental Document Plaintiffs complain that Defendants did not adequately analyze the environmental effects of the entire scope of the RBTI in the region, including the recent expansion of the German Luftwaffe operations out of Holloman Air Force Base vis-á-vis the proposed modification and expansion of the RBTI. Rather, Plaintiffs contend that Defendants prepared a separate environmental assessment (“EA”) and a separate environmental impact statement (“EIS”) for each project but failed to consider interrelated, connected, cumulative, or similar actions within the region in a single comprehensive NEPA document. Ninth: Violation of NEPA, Failure to Consider Reasonable Range of Alternatives Plaintiffs contend that Defendants failed to consider a reasonable range of alternatives, including (1) basing U.S. and/or foreign military aircraft at training locations other than Dyess and Barksdale AFBs; (2) utilizing alternative methods for meeting Defendants’ training needs; or (3) utilizing off-shore training routes in the Gulf of Mexico. Tenth: Violation of NEPA and the Noise Control Act (“NCA”), Failure to Address and Implement NCA Policies Plaintiffs allege that Defendants have failed to adequately address the noise impacts of the proposed action in the affected areas, to discuss or address conflicts with federal, state, and local noise requirements, or to adequately mitigate the noise impacts of the proposed RBTI by limiting, reducing, or modifying the RBTI. Eleventh: Violation of NEPA, Commitment of Resources Prior to Final Agency Action Plaintiffs complain that Defendants undertook actions committing Defendants’ resources prior to making a decision based on the FEIS. Plaintiffs complain that Defendants’ premature actions prejudiced the selection of alternatives and failed to use the FEIS as a basis for the decisionmak-ing process. E. Plaintiffs ’ Prayers for Relief Judicial Review /Declaratory Judyment/Remand Plaintiffs seek judicial review and ask this Court to declare (1) Defendants’ FEIS and ROD arbitrary, capricious, and not in accordance with the law; (2) Defendants’ activities on IR-178 to be in violation of NEPA; and (3) Defendants’ implementation of the RBTI to be in violation of the NCA. Plaintiffs ask this Court to remand this matter to Defendants for preparation of NEPA documentation which adequately describes and assesses the complete scope of the effects of the RBTI and which demonstrates complete compliance with the NCA. Injunctive Relief ¡Mandamus Plaintiffs ask this Court to enjoin (1) all military training activities authorized by the FEIS and/or ROD, as well as those currently conducted on IR-178, pending completion of and circulation of documentation complying with NEPA; (2) Defendants’ decision to implement the RBTI unless an FEIS is prepared which addresses the full scope of Defendants’ proposals, including interrelated, connected, cumulative, or similar actions; (3) Defendants’ decision to submit an application to the Federal Aviation Administration (“FAA”) for modification of MTR IR-178 and establishment of the Lancer MOA within New Mexico and west Texas; (4) Defendants’ activities that are in violation of the NCA; and (5) Defendants’ proposed military training operations from taking place in MTR IR-178 and the Lancer MOA to the extent those operations violate the Third Amendment to the United States Constitution. Plaintiffs also ask this Court for issuance of a Writ of Mandamus directing Defendants to comply with the requirements set forth under NEPA and the NCA. Litigation Costs Pursuant to the Equal Access to Justice Act, 28 U.S.C. § 2412, Plaintiffs ask this Court to award to Plaintiffs all costs of litigation, including expert witness fees and attorneys’ fees. F. Defendants ’ Affirmative Answers Defendants affirmatively answer that (1) this Court lacks jurisdiction over all or part of the subject matter of this action; (2) Plaintiffs lack standing to bring all or part of this action; (3) Plaintiffs have not exhausted the administrative remedies available to gain the relief sought in all or part of this action; (4) all or part of Plaintiffs’ First Amended Complaint fails to state a claim upon which relief can be granted; (5) the issues in Plaintiffs’ First Amended Complaint are not ripe for consideration by this or any other court; (6) all or part of Plaintiffs’ First Amended Complaint is barred by the statute of limitations; and (7) all or part of Plaintiffs’ First Amended Complaint is barred by the defense of laches. II. PROCEDURAL BACKGROUND Pleadings Plaintiffs’ Complaint was originally filed in the United States District Court for the Western District of Texas, Pecos Division, on March 29, 2001. Defendants’ Original Answer to Plaintiffs’ Complaint was filed June 7, 2001. An Order Transferring Action from the United States District Court for the Western District of Texas, Pecos Division, to this Court was filed October 22, 2001. Plaintiffs’ First Amended Complaint was filed November 30, 2001, and Defendants’ Answer to Plaintiffs’ First Amended Complaint was filed November 30, 2001. Motion to Dismiss Defendants’ Motion to Dismiss Complaint in Part and Brief in Support Thereof was filed November 30, 2001, and Plaintiffs’ (DMTPHA) Brief in Opposition to Defendants’ Motion to Dismiss Complaint in Part was filed January 4, 2002. Defendants’ Reply to Plaintiffs’ Response to Motion to Dismiss Complaint in Part was filed January 17, 2002. On February 12, 2002, this Court granted in part Defendants’ Motion to Dismiss Complaint in Part and dismissed Plaintiffs’ First Claim for Relief but left undisturbed Plaintiffs’ remaining claims for relief. Administrative Record On November 16, 2001, this Court entered an Agreed Order that the final administrative record (“AR”) which was filed with this Court in the matter of Welch v. United States Air Force, Civil Action No. 5:00-CV-392-C, on June 29, 2001, and comprised of eighteen (18) volumes, 12,904 pages, together with any supplementation as allowed by the Court, shall also serve as the AR in the instant ease. The Agreed Order also allowed Defendants to supplement the AR with Exhibits A through Q. Also filed November 16, 2001, was Plaintiffs’ (DMTPHA) Motion and Brief in Support of Motion to Supplement and to Compel Filing of the Complete Administrative Record. Defendants’ Opposition to Plaintiffs’ Motion to Supplement was filed on December 18, 2001. This Court’s Order granting in part and denying in part Plaintiffs’ (DMTPHA) Motion to Supplement and to Compel Filing of thé Complete Administrative Record was filed April 1, 2002. Defendants’ Notice of Filing Supplemental Materials to Administrative Record and Brief in Support Thereof was filed July 19, 2002. Plaintiffs’ (DMTPHA) Response and Objections to Defendants’ “Notice of Filing Supplemental Materials to Administrative Record and Brief in Support Thereof’ was filed August 8, 2002. Defendants’ Reply to Plaintiffs’ (DMTPHA) Response to Notice of Filing Supplemental Materials to Administrative Record and Brief in Support Thereof was filed August 28, 2002. This Court’s Order overruling Plaintiffs’ Objections to Defendants’ “Notice of Filing Supplemental Materials to Administrative Record” was filed September 11, 2002. Ultimately, the AR and supplements before this Court consisted of twenty-three (23) volumes, 15,950 pages. Summary Judgment Plaintiffs’ (DMTPHA) Motion for Summary Judgment was filed October 17, 2002, and Defendants’ Response to Plaintiffs’ Motion for Summary Judgment was filed December 18, 2002. On January 17, 2003, Plaintiffs filed Plaintiffs’ Reply in Support of Its Motion for Summary Judgment. Defendants’ Motion to Strike Extra-Record Declarations and Materials Attached to Plaintiffs’ Motion for Summary Judgment was filed December 18, 2002. Plaintiffs’ Response and Brief in Opposition to Defendants’ Motion to Strike Extra-Record Declarations and Materials Attached to Plaintiffs’ Motion for Summary Judgment was filed January 17, 2003. Defendants filed no reply. Plaintiffs’ Motion and Brief in Support of Motion to Strike Defendants’ Post Hoc Declarations of Bowles, Cormier, Skujins, and Fidell was filed January 17, 2003. Defendants filed no response. Defendants’ Cross-Motion for Summary Judgment was filed December 18, 2002. Plaintiffs’ Response to Defendants’ Cross Motion for Summary Judgment was untimely filed January 17, 2003. Defendants filed no reply. Oral Arguments This Court’s Order Setting Hearing to entertain oral arguments on January 29, 2003, specifically limited to (1) the appropriate baseline and (2) alternate basing, was filed January 2, 2003. III. STANDARD Ordinarily, summary judgment is appropriate “if the pleadings, depositions, answers to interrogatories, and admissions on file, together with any affidavits, show that there is no genuine issue as to any material fact.” Fed.R.Civ.P. 56(c). However, when reviewing the decision of an administrative agency, “a motion for summary judgment ‘stands in a somewhat unusual light, in that the administrative record provides the complete factual predicate for the court’s review.’ ” Tex.Comm. on Natural Res. v. Van Winkle, 197 F.Supp.2d 586, 595 (N.D.Tex.2002) (quoting Piedmont Envtl. Council v. United States DOT, 159 F.Supp.2d 260, 268 (W.D.Va.2001), aff'd in relevant part by 58 Fed.Appx. 20 (4th Cir.2003) (per curiam)). “Summary judgment is an appropriate procedure for resolving a challenge to a federal agency’s administrative decision when review is based upon the administrative record ..., even though the Court does not employ the standard of review set forth in Rule 56, Fed.R.Civ.P.” Id. (quoting Fund for Animals v. Babbitt, 903 F.Supp. 96, 105 (D.D.C.1995)). In reviewing administrative agency decisions, the district court must determine whether, as a matter of law, evidence in the AR permitted the agency to make the decision it did, and “summary judgment is an appropriate mechanism for deciding the legal question of whether an agency could reasonably have found the facts as it did.” Id. (quoting Sierra Club v. Dombeck, 161 F.Supp.2d 1052, 1064 (D.Ariz.2001)). “Judicial review has the function of determining whether the administrative action is consistent with the law — that and no more.” Girling Health Care, Inc. v. Shalala, 85 F.3d 211, 215 (5th Cir.1996) (citations omitted). The standard for summary judgment on judicial review of agency decisions is not whether there is a genuine issue of material fact but “whether the agency action was arbitrary, capricious, an abuse of discretion, not in accordance with law, or unsupported by substantial evidence on the record taken as a whole.” Envt. Now! v. Espy, 877 F.Supp. 1397, 1421 (E.D.Cal.1994) (citing Good Samaritan Hosp., Corvallis v. Mathews, 609 F.2d 949, 951 (9th Cir.1979)). Thus, the issue is not whether material facts are disputed but whether the agency properly dealt with the facts. Lodge Tower Condo. Ass’n v. Lodge Props., Inc., 880 F.Supp. 1370, 1376-77 (D.Colo.1995). The “court must find that the evidence before the agency provided a rational and ample basis for its decision.” Id. at 1377 (quoting Northwest Motorcycle Ass’n v. United States Dep’t of Agric., 18 F.3d 1468, 1471 (9th Cir.1994)). The narrow scope of the court’s review is to determine whether the agency decision “was based on a consideration of the relevant factors and whether there has been a clear error of judgment,” not to weigh the evidence pro and con. Delta Found., Inc. v. United States, 303 F.3d 551, 563 (5th Cir.2002) (quoting Motor Vehicle Mfrs. Ass’n of the United States, Inc. v. State Farm Mut. Auto. Ins. Co., 463 U.S. 29, 43, 103 S.Ct. 2856, 77 L.Ed.2d 443 (1983)). “Thus, if the agency considers the factors and articulates a rational relationship between the facts found and the choice made, its decision is not arbitrary and capricious.” Id. (quoting Harris v. United States, 19 F.3d 1090, 1096 (5th Cir.1994)). The “agency’s decision need not be ideal, so long as the agency gave at least minimal consideration to relevant facts contained in the record.” Id. (quoting Harris, 19 F.3d at 1096). IV. DISCUSSION Plaintiffs argue that they are entitled to summary judgment because Defendants’ FEIS and ROD are in violation of NEPA and the enforcement regulations promulgated by the Council on Environmental Quality (“CEQ”), as well as Defendants’ own regulations. Plaintiffs complain that the AR before the Court does not support the decisionmaker’s choice of Alternative B, MTR IR-178, or the RBTI as a whole, and Plaintiffs seek judicial review of the final decision to approve the modification and expansion of the existing MTRs and the Lancer MOA. Defendants respond by arguing that Plaintiffs have failed to identify any major federal action involving IR-178 that would significantly affect the environment adversely and that Plaintiffs have failed to meet their burden of establishing that approval of the RBTI was arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with the law. Judicial Review NEPA was enacted to establish a national policy “to promote efforts which will prevent or eliminate damage to the environment and biosphere and stimulate the health and welfare of man; to enrich the understanding of the ecological systems and natural resources important to the Nation; and to establish a[CEQ].” 42 U.S.C. § 4321, et seq. (1994). In order to achieve these substantive goals, NEPA requires compliance with certain procedures before and during the undertaking of any project that affects the environment. See NEPA § 4832. See also Robertson v. Methow Valley Citizens Council, 490 U.S. 332, 350, 109 S.Ct. 1835, 104 L.Ed.2d 351 (1989) (explaining that NEPA’s goals are achieved through “action-forcing” procedures which do not mandate particular results, but “simply prescribe! ] the necessary process”). Thus, “[i]f the adverse environmental effects of the proposed action are adequately identified and evaluated, the agency is not constrained by NEPA from deciding that other values outweigh the environmental costs.” Robertson, 490 U.S. at 350, 109 S.Ct. 1835. Under NEPA, adequate identification and evaluation of the adverse environmental effects of the proposed action require an agency to take a hard look at the environmental consequences of its actions, which includes a detailed EIS on (i) the environmental impact of the proposed action, (ii) any adverse environmental effects which cannot be avoided should the proposal be implemented, (iii) alternatives to the proposed action, (iv) the relationship between local short-term uses of man’s environment and the maintenance and enhancement of long-term productivity, and (v) any irreversible and irretrievable commitments of resources which would be involved in the proposed action should it be implemented. NEPA § 4332(2)(C). See also 40 C.F.R. § 1500, et seq. (2002) (setting forth the CEQ regulations expanding upon the appropriate form and content of an EIS). An EIS is intended to provide decisionmakers “with sufficiently detailed information to aid in determining whether to proceed with the action in light of its environmental consequences and to provide the public with information and an opportunity to participate in the information gathering process.” Northwest Res. Info. Ctr., Inc. v. Nat’l Marine Fisheries Serv., 56 F.3d 1060, 1064 (9th Cir.1995). The EIS “insures the integrity of the agency process by forcing it to face those stubborn, difficult-to-answer objections without ignoring them or sweeping them under the rug and serves as an environmental full disclosure so that the public can weigh a project’s benefits against its environmental costs.” Nat’l Audubon Soc’y v. Hoffman, 132 F.3d 7, 12 (2d Cir.1997) (quoting Sier- m Club v. United States Army Corps of Eng’rs, 772 F.2d 1043, 1049 (2d Cir.1985)) (internal quotations omitted). However, because NEPA does not contain provisions to determine whether agency action complies with NEPA’s necessary processes, compliance with NEPA is reviewed under the APA, 5 U.S.C. § 500, et seq. (1996). See Sierra Club v. Penfold, 857 F.2d 1307, 1315 (9th Cir.1988) (concluding that “NEPA itself authorizes no private right of action, ... [b]ut the APA provides for judicial review of agency action” under § 702 of the APA). Judicial review of agency action under the APA requires a “thorough, probing, in-depth review” of the AR to determine “whether the decision was based on a consideration of the relevant factors and whether there has been a clear error of judgment.” ITT Fed. Servs. Corp. v. United States, 45 Fed.Cl. 174, 184 (Fed.Cl.1999). The APA provides the following scope of judicial review: To the extent necessary to decision and when presented, the reviewing court shall decide all relevant questions of law, interpret constitutional and statutory provisions, and determine the meaning or applicability of the terms of an agency action. The reviewing court shall— (1) compel agency action unlawfully withheld or unreasonably delayed; and (2) hold unlawful and set aside agency action, findings, and conclusions found to be— (A) arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law; (B) contrary to constitutional right, power, privüege, or immunity; (C) in excess of statutory jurisdiction, authority, or limitations, or short of statutory right; (D) without observance of procedure required by law; (E) unsupported by substantial evidence in a case subject to sections 556 and 557 of this title or otherwise reviewed on the record of an agency hearing provided by statute; or (F) unwarranted by the facts to the extent that the facts are subject to trial de novo by the reviewing court. In making the foregoing determinations, the court shall review the whole record or those parts of it cited by a party, and due account shall be taken of the rule of prejudicial error. APA § 706. Because NEPA “exists to ensure a process, not a result,” Mississippi River Basin Alliance v. Westphal, 230 F.3d 170, 175 (5th Cir.2000) (quoting Morongo Band of Mission Indians v. FAA 161 F.3d 569, 575 (9th Cir.1998)), “the variability of this procedural requirement has produced grossly general and conflicting judicial pronouncements.” Trans-Am. Van Serv., Inc. v. United States, 421 F.Supp. 308, 318 (N.D.Tex.1976). Consequently, a number of courts began to expand the definition of the “whole record” before the court, but at the same time candidly recognized the narrow scope of review. Pub. Power Council v. Johnson, 674 F.2d 791, 793 (9th Cir.1982). See also County of Suffolk v. Sec’y of Interior, 562 F.2d 1368, 1384 (2d Cir.1977) (acknowledging the rule of limited record review, then recognizing that the focus of judicial inquiry is not necessarily restricted to the administrative record). Indeed, the United States Supreme Court has long held that expansion of the AR is appropriate when the record submitted fails to explain the basis for the agency’s action, thereby frustrating judicial review. Camp v. Pitts, 411 U.S. 138, 142 — 43, 93 S.Ct. 1241, 36 L.Ed.2d 106 (1973). Thus, the AR may be “supplemented, if necessary, by affidavits, depositions, or other proof of an explanatory nature.” Arkla Exploration Co. v. Tex. Oil & Gas Corp., 734 F.2d 347, 357 (8th Cir.1984). “The new material, however, should be explanatory of the decisionmakers’ action at the time it occurred. No new rationalizations for the agency’s decision should be included.” Sierra Club v. Marsh, 976 F.2d 763, 772-73 (1st Cir.1992). When adverse impacts are set forth in great detail in extra-record written submissions, “the court properly can consider this record in determining whether there exists a rational basis for the [agency] decision.” Exxon Corp. v. Fed. Energy Admin., 398 F.Supp. 865, 874 (D.D.C. 1975). But cf. Smith v. FTC, 403 F.Supp. 1000, 1008 (D.C.Del.1975) (holding that, because the scope of review of agency matters is confined to the administrative record, discovery in the form of depositions from agency officials was improper and irrelevant). A court may also elect to allow extra-record evidence to determine whether an agency’s final action meets the test of rationality under the following circumstances: 1. when agency action is not adequately explained in the record before the court; 2. when the agency failed to consider factors which are relevant to its final decision; 3. when an agency considered evidence which it failed to include in the record; 4. when a case is so complex that a court needs more evidence to enable it to understand the issues clearly; 5. in cases where evidence arising after the agency action shows whether the decision was correct or not; 6. in cases where agencies are sued for a failure to take action; 7. in cases arising under NEPA; and 8. in cases where relief is at issue, especially at the preliminary injunction stage. ITT Fed. Servs. Corp., 45 Fed. Cl. at 185. Thus, an adequate record can sometimes only be determined “by looking outside the [AR] to see what the agency may have ignored.” County of Suffolk, 562 F.2d at 1384. It is well established that “[t]he burden of proving that an agency decision was arbitrary or capricious generally rests with the party seeking to overturn the agency decision.” Van Winkle, 197 F.Supp.2d at 596 (citing Sierra Club v. Marita, 46 F.3d 606, 619 (7th Cir.1995) and N.C. Alliance for Transp. Reform v. United States DOT, 151 F.Supp.2d 661, 679 (M.D.N.C.2001)). See also Sierra Club v. Morton, 510 F.2d 813, 818 (5th Cir.1975) (holding that plaintiffs bear the burden of showing by a preponderance of the evidence that defendants have failed to adhere to the requirements of NEPA). In determining whether an agency’s action was arbitrary or capricious, the court must consider “whether the decision was based on a consideration of the relevant factors and whether there has been a clear error of judg[ ]ment.” Dombeck, 161 F.Supp.2d at 1064 (quoting Marsh v. Or. Natural Res. Council, 490 U.S. 360, 378, 109 S.Ct. 1851, 104 L.Ed.2d 377 (1989)). The agency must examine the relevant data and articulate a satisfactory explanation for its action including a “rational connection between the facts found and the choice made.” Burlington Truck Lines, Inc. v. United States, 371 U.S. 156, 168, 83 S.Ct. 239, 9 L.Ed.2d 207 (1962). However, “the Court is not allowed to substitute its judgment for that of the agency.” Citizens to Preserve Overton Park, Inc. v. Volpe, 401 U.S. 402, 416, 91 S.Ct. 814, 28 L.Ed.2d 136 (1971). It is also well established that a court may not set aside an agency’s action based on the exercise of the agency’s accumulated expertise merely because the court might reach a different result. Simeon Mgmt. Corp. v. FTC, 579 F.2d 1137, 1142 (9th Cir.1978). If the analysis of the relevant documents “requires a high level of technical expertise, [courts] must defer to the informed discretion of the responsible federal agencies.” Or. Natural Res. Council, 490 U.S. at 377, 109 S.Ct. 1851 (internal quotations omitted). Moreover, the Supreme Court will “uphold a decision of less than ideal clarity if the agency’s path may reasonably be discerned.” Bowman Tramp., Inc. v. Ark.-Best Freight Sys., Inc., 419 U.S. 281, 286, 95 S.Ct. 438, 42 L.Ed.2d 447 (1974). The Supreme Court has cited the following nonexclusive examples of circumstances which would normally be considered arbitrary and capricious: (1) the agency relied on factors which Congress had not intended the agency to consider; (2) the agency entirely failed to consider an important aspect of the problem; (3) the agency offered an explanation for its decision that ran counter to the evidence before the agency; or (4) the agency’s decision is so implausible that it could not be ascribed to a difference in view or the product of agency expertise. Motor Vehicle Mfrs. Ass’n, 463 U.S. at 43, 103 S.Ct. 2856. When reviewing challenges brought under APA § 706 regarding an agency’s compliance with NEPA, the Fifth Circuit set forth the following three criteria for determining the adequacy of an EIS: (1) whether the agency in good faith objectively has taken a hard look at the environmental consequences of a proposed action and alternatives; (2) whether the EIS provides detail sufficient to allow those who did not participate in its preparation to understand and consider the pertinent environmental influences involved; and (3) whether the EIS explanation of alternatives is sufficient to permit a reasoned choice among different courses of action. Miss. River Basin Alliance, 230 F.3d at 174. Information satisfying these criteria must be in the EIS and the conclusions upon which the EIS is based must be supported by evidence contained in the AR. Id. at 174-75. “[T]he judicial concern is whether the [EIS] is a good faith, objective, and reasonable presentation of the subject areas mandated by NEPA[] and that the court should not second-guess the experts.” Manygoats v. Kleppe, 558 F.2d 556, 560 (10th Cir.1977). A court “should intervene only when it is clearly determined that the agency’s determinations were irrational or unreasonable.” ITT Fed. Servs. Corp., 45 Fed. Cl. at 184. A. Hard Look Plaintiffs argue that Defendants failed to make available to the decision-maker detañed information concerning significant adverse environmental effects in connection with livestock, wildlife, wake vortices, socioeconomics, and airspace use and management. Without such information, Plaintiffs complain that informed pub-lie participation and rational decisionmak-ing were not possible. Plaintiffs specifically complain that a sufficiently detailed analysis of the RBTI’s adverse effects on livestock and poultry operations was not conducted. Plaintiffs insist that a county-level analysis should have been undertaken by Defendants to consider the potential adverse impacts on livestock and poultry production and reproduction. Plaintiffs also contend that Defendants have failed to adequately consider the potential health and safety problems involving horses and ranch workers living within the RBTI area. In addition, Plaintiffs accuse Defendants of summarily discounting the adverse impacts of the RBTI’s noise levels on the wildlife inhabiting the RBTI area. Plaintiffs complain that Defendants’ reliance on day/night averaging of noise impacts over a twenty-four-hour period (“Ldn”) minimizes the true level and frequency of the individual noise events and, thus, fails to legitimately evaluate the adverse noise effects of the RBTI on the underlying wildlife. Plaintiffs next complain that Defendants failed to seriously consider the adverse impacts of the wake vortex caused by each low-level overflight of the RBTI. Contrary to Defendants’ assertions that “military overflights at 630 miles per hour only 300 feet [AGL] would cause no more than a gentle breeze at the surface,” Plaintiffs claim that windmills, fences, other ranch structures, livestock, and persons have suffered real and severe impacts from the wake turbulence and jet blasts from low-flying aircraft. In any event, Plaintiffs argue that Defendants’ eight-page analysis of the effects of wake vortices was based on an inappropriate methodology not applicable to B-l bombers and, thus, was inadequate. Plaintiffs also argue that Defendants have failed to accurately disclose the socioeconomic and technical costs associated with the RBTI. Plaintiffs complain that although Defendants chose to “trumpet the benefits” of the RBTI, Defendants have not fully disclosed, even on an informal basis, an analysis of the RBTI’s costs. By failing to do so, Plaintiffs argue that Defendants deprived the public and the decisionmaker of essential information integral to NEPA’s decisionmaking process. As to the potential impact on Plaintiffs’ property values, Plaintiffs argue that the RBTI’s overflights will adversely affect the leasehold values for hunting, hiking, bird watching, camping, eco-tourism, and other recreational activities on Plaintiffs’ properties. As a consequence, Plaintiffs assert that Defendants’ RBTI will adversely impact the income stream or consumptive use of the underlying properties owned by Plaintiffs. Plaintiffs further complain that the RBTI’s excessive noise events will negatively implicate the marketability of Plaintiffs’ underlying properties. Indeed, Plaintiffs note that Defendants acknowledge in the AR that “increased aircraft noise does appear to lower property values.” Finally, Plaintiffs charge that Defendants failed to take a hard look at the concomitant aeronautical and airspace management impacts of Alternative B’s Lancer MOA. Specifically, Plaintiffs contend that Defendants did not incorporate into the FEIS the FAA’s July 28, 2000, “Combined Aeronautical Study,” which identified, inter alia, the economic impacts on airports, carriers, fixed base operators, and other civil aviation activities. Plaintiffs complain that Defendants did not consider (1) that many fixed base operators and transient services providers might be forced to other locations because of the airspace complexity resulting from the RBTI; (2) that the Lancer MOA could adversely impact the costs for commercial air carriers operating out of Lubbock International Airport; and (3) that the Lancer MOA could negatively impact the regional economy of the City of Lubbock, Texas. Instead, Plaintiffs contend that Defendants’ FEIS merely notes that under Alternative B the “FAA would need to ensure conflicts between proposed ATCAA and intersecting jet routes are avoided.” Plaintiffs also claim that Defendants failed to make available to the RBTI deci-sionmaker, or the public, an FAA cumulative impact assessment which determined that the RBTI’s creation of the Lancer MOA would have a significant impact on instrument flight rules (“IFR”) operations and would limit the availability of direct routes and altitudes that are currently in use. Plaintiffs argue that Defendants could not have adequately considered appropriate mitigation measures absent the FAA’s critical information on airspace management and the RBTI’s impacts on civil and commercial aviation. Contrary to Plaintiffs’ many assertions, Defendants first respond that the FEIS contains dozens of studies analyzing the potential effects of the RBTI on livestock. Although Defendants acknowledge that the studies included in the AR sometimes reach contradictory conclusions and that injuries to livestock are possible, Defendants argue that the great weight of the studies nevertheless indicates that livestock adapt and habituate to aircraft overflights and that few, if any, negative impacts on livestock production, growth, or reproduction occur. Defendants also point to the numerous studies included in the FEIS which specifically discuss the effects of overflights on various species of wildlife and the great detail and expansive review Defendants devoted to the potential for adverse effects. Although Defendants again acknowledge that the parties’ experts at times expressed conflicting views, Defendants argue that they were entitled to rely on the reasonable opinions of their own qualified experts. With regard to the possible harmful effects of the RBTI’s B-l and B-52 wake vortices, Defendants contend that the FEIS provides a complete narrative description of wing vortex and its effects and, hence, adequately explains why wake vortex is not an issue in the instant matter. Defendants argue that the conclusion stated in the AR that a B-52 flying at 300 feet AGL would generate a surface wind speed of four miles per hour was based on the results of extensive actual test flights performed with B-52s. Based on the FEIS’s illustrative documentation generally depicting the track and lifespan of a typical wake vortex consistent with the B-52 tests conducted, Defendants argue that a B-l would also be expected to produce similar low wind speeds at ground level. Moreover, Defendants note that they have engaged in low-level flight operations for more than fifty years without wake vortex damage to structures becoming a significant issue and, because the RBTI raises the floor of IR-178 from 200 feet AGL to 300 feet AGL, the likelihood that adverse effects would now result from any wing turbulence is further decreased. Defendants also dispute Plaintiffs’ contention that the non-speculative socioeconomic impacts reasonably foreseeable and related to the RBTI were not adequately identified and discussed. Rather, Defendants argue that the AR reflects that the socioeconomic merits and drawbacks of the various RBTI alternatives were fully considered by Defendants. Further, Defendants contend that not only is a formal cost/benefit analysis not required by NEPA, but a cost/benefit analysis was never contemplated by Defendants, because neither the operational considerations nor the environmental consequences of the RBTI lent themselves to the assignment of specific socioeconomic values. Instead, Defendants argue that identifying the merits and drawbacks so as to allow meaningful consideration by the public and the decisionmaker fully discharged Defendants’ duty under NEPA. As to Plaintiffs’ claim that the RBTI could adversely affect property values, Defendants claim that the studies of land values and noise in the vicinity of civil airports, as cited by Plaintiffs, as well as the studies of properties surrounding military installations included in the AR, are inapposite to the arguments made regarding the effects of aircraft noise on property values beneath MTRs and/or MOAs. Rather, Defendants argue that Plaintiffs have offered no demonstrable relationship between the RBTI’s proposed operations (approximately six flights/day over a large land area, many of which are at higher MOA altitudes) and any alleged decrease in Plaintiffs’ land values. Defendants maintain that the decision to limit discussion about the speculative and uncertain effects of jet noise on property values is consistent with NEPA’s requirements. With regard to Plaintiffs’ assertions that the RBTI’s AR and supplementing materials failed to address mitigation measures relevant to the concerns expressed in the FAA’s formal aeronautical study issued post-ROD, Defendants charge Plaintiffs with misapprehending the distinctions between (1) Defendants’ role in fulfilling NEPA’s obligations and (2) the FAA’s role, as a cooperating agency, in commenting on issues within its area of special expertise for the purpose of making an independent decision regarding relevant airspace modifications. In like manner, Defendants argue that Plaintiffs have misunderstood the timing requirements set forth by the CEQ regulations, which provide that Defendants cannot make a decision until ninety days after publication of the notice of the draft EIS (“DEIS”) or until thirty days after publication of the notice of the FEIS. Here, Defendants note that the notice for the DEIS was published on March SO, 1999, and that the notice for the FEIS was published on February 1, 2000. Because the ROD was signed in April, 2000, Defendants argue that the timing requirements under NEPA were fully satisfied; and because the FAA’s independent Formal Aeronautical Study was not issued until July 28, 2000, the study could not have been a part of the RBTI AR before the decisionmaker. Therefore, contrary to Plaintiffs’ assertions, Defendants argue that the FEIS clearly addressed the potential impacts of Alternative B on airspace management, as well as mitigation measures to be taken in response to those impacts found to exist. For each of the reasons expressed above, Defendants assert that information in sufficient detail was placed before the public and the decisionmaker for a reasoned choice of alternatives; thus, Plaintiffs’ arguments must fail. Judicial Determination The Court begins by noting that when NEPA was enacted, Congress did not require agencies to elevate environmental concerns over other appropriate considerations; rather, Congress required only that the agency take a hard look at the environmental consequences before taking a major action. Baltimore Gas & Elec. Co. v. Natural Res. Def. Council, Inc., 462 U.S. 87, 97, 103 S.Ct. 2246, 76 L.Ed.2d 437 (1983). This Court is, of course, mindful of the statutory requirement that the FEIS be a “detailed statement.” NEPA § 4332(2)(C). “However, the Court must also avoid placing extreme or unrealistic burdens on the compiling agency.” Isle of Hope Historical Ass’n, Inc. v. United States Army Corps of Eng’rs, 646 F.2d 215, 220 (5th Cir. Unit B 1981) (citing Morton, 510 F.2d at 819). An EIS “must be concise, clear, and to the point and written in plain language so that the public can easily understand it.” Van Winkle, 197 F.Supp.2d at 600 (citing Marita, 46 F.3d at 619). Compliance is to be judged against a “rule of reason.” Id. “[I]t is entirely unreasonable to think that Congress intended for an impact statement to document every particle of knowledge that an agency might compile in considering the proposed action.” Envtl. Def. Fund, Inc. v. Corps of Eng’rs of United States Army, 492 F.2d 1123, 1136 (5th Cir.1974). In short, this Court must follow a pragmatic standard which requires good faith objectivity but avoids “fly specking.” Lathan v. Brinegar, 506 F.2d 677, 693 (9th Cir.1974). This Court also notes that, although NEPA requires agencies to consider and respond to the comments and concerns expressed by the public and other federal agencies, NEPA does not require that those agencies necessarily agree. 40 C.F.R. § 1503.1. In this case, the AR verifies that Defendants identified possible noise impacts on sensitive areas, including the effects of overflights on beef cattle, dairy cows, sheep, pigs, horses, mink, dogs, chickens, turkeys, migratory birds, predatory birds, and other wildlife within the RBTI area. The AR also indicates that Defendants amply considered the concerns expressed by the public and other agencies; and Defendants candidly acknowledged that adverse impacts were possible but reasonably determined, after considering public and agency comment alike, that any additional impact on these areas would be minimal. Further, the AR indicates that the RBTI adopted specific measures to mitigate possible impacts on sensitive areas, such as raising minimum flying altitudes and minimizing numbers of special use land areas overflown, as well as providing information to the public concerning the claims process if livestock should be injured. In addition, the FEIS reveals that endangered/threatened flora and fauna species lists were obtained by Defendants from, inter alia, the United States Fish and Wildlife Service (“USFWS”), the New Mexico Department of Game and Fish, and the Texas Parks and Wildlife Department. The AR also reveals that Defendants consulted with the USFWS on an ongoing basis concerning actions which overlapped the RBTI area and that various state agencies were consulted in connection with species of specific concern to each state. The FEIS also reflected Defendants’ avowal that “[compliance with the Endangered Species Act for [the] RBTI has been and will continue to be part of the broader consultation effort.” Further, the FEIS sets forth the results of Defendants’ analysis of the impact of aircraft emissions on threatened wildlife for each alternative. The analysis concluded that emissions would produce minimal quantities of criteria pollutants and that ground-level pollutants would be fractions of federal and state standards. Finally, the Court’s holistic review of the AR reveals that Defendants consulted continuously with the USFWS throughout the RBTI NEPA process, including formal comments on the DEIS; a status meeting to discuss the endangered species issues; and numerous telephone conferences, letters, and e-mail communications. While Plaintiffs are certainly entitled to disagree with Defendants’ conclusions, this Court finds that the AR belies Plaintiffs’ allegations that Defendants ignored or otherwise failed to consider the adverse effects on the underlying ranchland, livestock, and wildlife. Indeed, although Plaintiffs disagree with Defendants’ conclusions regarding the information contained in the AR, it is obvious to this Court that Defendants considered the issues raised and thereafter placed before the final decisionmaker adequate information from which to make an informed decision. This Court also notes that Defendants candidly acknowledged the potential of adverse effects to the underlying lifestock and wildlife. NEPA requires nothing more. See Robertson, 490 U.S. at 350, 109 S.Ct. 1835 (concluding that “[i]f the adverse environmental effects of-the proposed action are adequately identified and evaluated, the agency is not constrained by NEPA from deciding that other values outweigh the environmental costs”). As to Plaintiffs’ claims that Defendants inadequately analyzed the safety issues raised during the scoping process regarding the effects of wake vortices generated by the RBTI aircraft, this Court’s review of the AR reveals that Defendants used the results of actual test flights to establish the effects of wake vortices from B-52s flying at 300 feet AGL. In addition, the AR indicates that Defendants both narra-tively and pictorially addressed the issue of wake turbulence. Defendants’ test flights demonstrated that vortex wind speeds at or near the surface would range from approximately 1.7 mph at 6 feet AGL, 2.0 mph at 50 feet AGL, 2.6 mph at 100 feet AGL, and 4.0 mph at 200 feet AGL. Using the Beaufort wind force scale as a benchmark, Defendants demonstrated that the effects of wake vortices at 1-3 mph would move leaves and drift smoke; at 4-7 mph the effects of wake vortices would rustle leaves and cause wind to be felt on the face. Nevertheless, in contrast, Defendants candidly acknowledged that wake turbulence directly behind an aircraft can cause handling difficulties for following aircraft, especially when a smaller aircraft trails a larger aircraft. However, Defendants correctly pointed out that FAA regulations dictate safe following distances and procedures to avoid wake turbulence, both in flight and during landing or takeoff. For each of these reasons, this Court finds that Defendants reasonably concluded that wake turbulence was not expected to significantly affect the safety of people, vehicles, or structures within the RBTI area. This Court also finds that Defendants’ test flights — a series of three tests conducted from 1970 through 1986 — did not constitute a flawed methodology for analyzing the effects of wake turbulence or that Defendants’ discussion of the issue was inadequate. This Court is convinced that Defendants satisfied NEPA’s burden regarding the potential effects of wake vortex and provided detail “sufficient to enable those who did not have a part in [the EIS’s] compilation to understand and consider meaningfully the factors involved.” Envtl. Def Fund, Inc., 492 F.2d at 1136. This Court also finds similarly unavailing Plaintiffs’ assertions that Defendants inadequately analyzed the socioeconomic effects of the RBTI. Although CEQ regulations require agencies to ensure the professional and scientific integrity of environmental information and emphasize the need for multidisciplinary analysis, 40 C.F.R. §§ 1500.1(b) and 1502.24, “economic and social impacts clearly occupy a lesser tier of importance in an EIS than do purely environmental or ecological concerns.” Ass’n Concerned About Tomorrow, Inc. v. Dole, 610 F.Supp. 1101, 1111 (N.D.Tex.1985). Here, Plaintiffs argued that the socioeconomic analysis in the FEIS was inaccurate, incomplete, and in violation of NEPA. However, this Court notes that the AR reveals that Defendants (1) relied on noise impact analyses to measure the impacts of the RBTI on residential and recreational land use; (2) utilized relevant population, housing, employment, and earnings data; and (8) discussed comparative residential valuation data and tourism earnings data in each region of influence. Because NEPA only requires a “reasonably thorough discussion that fosters informed decisionmaking, not a complete evaluation,” Stop H-S Ass’n v. Dole, 740 F.2d 1442, 1462 (9th Cir.1984) (internal quotations omitted), it appears to this Court that Defendants have more than met NEPA’s requirements to discuss the relevant socioeconomic impacts of the RBTI. In addition, the Fifth Circuit has long held that the “[djetermination of economic benefits and costs that are tangential to environmental consequences are within th[e] wide area of agency discretion.” S. La. Envtl. Council, Inc. v. Sand, 629 F.2d 1005, 1011 (5th Cir.1980). NEPA requires, at most, “a narrowly focused, indirect review of the economic assumptions underlying a federal project described in an impact statement.” Id. See also Sierra Club v. Sigler, 695 F.2d 957, 974-75 (5th Cir.1983) (finding that an agency need only consider “important” information relevant to a “significant” effect not based on “unreasonable speculation”); Town of Norfolk v. United States EPA, 761 F.Supp. 867, 887-88 (D.Mass.1991) (holding that the failure to place a dollar value on a possible decrease in property value was not unreasonable); Izaak Walton League of Am. v. Marsh, 655 F.2d 346, 377 (D.C.Cir.1981) (finding that, if adverse environmental impacts are unlikely and the EIS identifies areas of uncertainty, studies are not necessary and the agency has fulfilled its mission under NEPA); Envtl. Defense Fund, Inc. v. Andrus, 619 F.2d 1368, 1375 (10th Cir.1980) (concluding that NEPA does not contemplate detailed discussions of environmental effects which are deemed remote, which are only speculative possibilities, and which cannot be readily ascertained). Here, the Court finds that Defendants adequately identified and discussed all of the non-speculative socioeconomic impacts reasonably foreseeable and related to the RBTI. While the Court is cognizant that neither NEPA nor the CEQ regulations define “cost/benefit analysis,” the Fifth Circuit has concluded that a cost/benefit analysis “varies from a formal analysis in which all costs and benefits are quantified in an identical unit of measurement ... and compared, to an informal analysis where costs and benefits are identified, quantified if possible, and balanced.” Sigler, 695 F.2d at 976-77 n. 15. In fact, a “more informal analysis is preferred “when there are important qualitative considerations.’ ” Id. See also 40 C.F.R. § 1502.23 (providing that “the weighing of the merits and drawbacks of the various alternatives need not be displayed in a monetary cost-benefit analysis and should not be when there are important qualitative considerations”) (emphasis added). Finally, a court must consider “whether the economic considerations, against which the environmental considerations are weighed, were so distorted as to impair fair consideration of those environmental consequences.” S. La. Envtl. Council, Inc., 629 F.2d at 1011. “In other words, the agency is free to take the most environmentally costly course of action or alternative, so long as the environment