Nope. They could get the ball rolling, but it would require an EA, at best, to determine the projected impact on soils, vegetation, animal life (including breeding and nesting seasons), water sources, erosion potential, and overall cost to the forest. Even if volunteer labor was used to install the course and open the fairways, the original site assessments from engineering, recreation ensuring that all of their boxes are checked, and bringing in soil, fish, botany, and wildlife to make their judgment.
So if they somehow got the District Ranger or Forest Supervisor to approve the preliminary study for the EA, and then submitted the draft EA, then it's open for public comment. Public comment is nearly impossible to manage, because some people have pet issues that they won't let go of, and the FS has to perform their due diligence to address those concerns. Some people object to old roads being maintained for erosion because they don't want roads in the forest, and object to road decommissioning because they're afraid it will spread invasive plants.
You can identify, if you like, all of those terrible environmental transgressions for logging, roads, oil & gas... but all of those have been curtailed hugely in the last 20 years. The Forest I worked for had a budget of 300 million and 325 employees in 1990. Last year, they were down to about 60 permanent and 20 seasonal employees and under 50 million for the budget. Most of that was provided by three logging contracts in a second-growth area of the forest.
Basically, the fear of litigation and increased scrutiny from the public has led to the FS being unable to do anything quickly, so unless the land is leased from the FS for another purpose (such as a ski bowl) that already impacts the land, there is virtually no chance of a DG course going in, except on a compound as an object course. I hate it, but that's the reality.
