Rulemaking for Colorado Roadless Areas

Revised Draft Environmental Impact Statement

Lead Agency: USDA Forest Service 

Cooperating Agency: State of Colorado 

Responsible Official: Secretary of Agriculture

For Information, contact: Ken Tu, Team Leader

USDA Forest Service

Colorado Roadless Rule 

(303) 275-5156

www.roadless.fs.fed.us

Abstract: 

The U.S. Department of Agriculture, Forest Service, in cooperation with the State of Colorado, 

proposes to promulgate a state-specific rule to manage roadless area values and characteristics 

on National Forest System (NFS) lands in Colorado. The proposal is responsive to a recognized 

need to balance local, State, and national interests in providing management direction for 

roadless areas on NFS lands in Colorado. This environmental impact statement (EIS) analyzes 

and displays expected physical, biological, and social-economic consequences of four

alternatives of the proposed Colorado Roadless Rule. Alternative 1 (2001 Roadless Rule), would

establish a state-specific roadless rule for Colorado that would retain the inventoried roadless 

area boundaries and roadless area management provisions contained in the 2001 Roadless Rule, 

for management of roadless areas on NFS lands in Colorado. Alternative 2 (proposed Colorado 

Roadless Rule), would establish a state-specific roadless rule for Colorado that modifies the 

roadless area boundaries and roadless area management provisions from the existing 2001 

Roadless Rule, primarily to provide for additional management flexibility in roadless areas. 

Additionally alternative 2 designates 562,200 acres of roadless areas as upper tier, which are 

areas receiving a higher level of protection. Alternative 3 (forest plans alternative-no action) 

would not establish a state-specific roadless rule for Colorado but would use management 

direction contained in the land management plans (forest plans) for each of the national forests 

in Colorado. Alternative 4 (provisions of alternative 2 with public proposed upper tier) would 

establish a state-specific roadless rule for Colorado with the same provisions as alternative 2 but 

would include 2,614,200 acres designated as upper tier.

Table of Contents

Rulemaking for Colorado Roadless Areas..................................................................................................1

Revised Draft Environmental Impact Statement........................................................................................1

Summary of the Environmental Impact Statement ....................................................................................1

Document Structure ...................................................................................................................................................1

Background..................................................................................................................................................................1

Purpose of and Need for Action...............................................................................................................................3

Proposed Action .........................................................................................................................................................4

Decision Framework ..................................................................................................................................................7

Public Involvement.....................................................................................................................................................8

Forest Service Public Involvement...............................................................................................................8

State of Colorado Public Involvement.........................................................................................................8

Tribal Consultation.....................................................................................................................................................9

Issues ............................................................................................................................................................................9

Alternatives ...............................................................................................................................................................11

Features Common to All Alternatives.......................................................................................................12

Alternative 1: Provisions of the 2001 Roadless Rule ...............................................................................13

Alternative 2: Proposed Action – Colorado Roadless Rule ....................................................................14

Alternative 3: Forest Plans ..........................................................................................................................16

Alternative 4: Colorado Roadless Rule with Public Proposed Upper Tier Acres ...............................18

Alternatives Considered but Eliminated from Detailed Study..............................................................18

Environmental Consequences.................................................................................................................................19

Chapter 1. Purpose of and Need for Action ..............................................................................................27

Document Structure .................................................................................................................................................27

Background................................................................................................................................................................28

Roadless Area Characteristics.................................................................................................................................29

Changes Between the DEIS and the Revised DEIS ..............................................................................................31

Purpose of and Need for Action.............................................................................................................................33

Proposed Action .......................................................................................................................................................34

Scope and Applicability...........................................................................................................................................35

Scope of the EIS ............................................................................................................................................35

Applicability .................................................................................................................................................35

Decision Framework ................................................................................................................................................36

Public Involvement...................................................................................................................................................37

Forest Service Public Involvement.............................................................................................................37

State of Colorado Public Involvement.......................................................................................................37

Tribal Consultation...................................................................................................................................................38

Issues ..........................................................................................................................................................................38

Chapter 2. Alternatives, Including the Proposed Action..........................................................................41

Introduction...............................................................................................................................................................41

Alternatives Considered but Eliminated from Detailed Study ..........................................................................42

Features Common to All Alternatives ...................................................................................................................43

Federal and State Requirements.................................................................................................................43

Forest Plans ...................................................................................................................................................43

Project Specific Environmental Analysis ..................................................................................................43

Reserved and Outstanding Rights .............................................................................................................43

Existing Land Use Authorizations.............................................................................................................44

Roadless Inventory and Acres in Alternatives .....................................................................................................47
Alternative 1: Provisions of the 2001 Roadless Rule ............................................................................................49

Inventoried Roadless Areas ........................................................................................................................49

Management of Inventoried Roadless Areas ...........................................................................................49

Alternative 2: Colorado Roadless Rule, Proposed Action ..................................................................................51

Colorado Roadless Areas ............................................................................................................................51

Administrative Corrections or Modifications of Colorado Roadless Areas ........................................52

Management of Colorado Roadless Areas................................................................................................53

Tree-cutting, Sale, or Removal ...................................................................................................................53

Roads and Linear Construction Zones ......................................................................................................54

Road Construction and Reconstruction ....................................................................................................54

Linear Construction Zones (LCZs) ............................................................................................................55

Road Construction/Reconstruction and LCZ Considerations ..............................................................56

Alternative 3: No Action – Forest Plan Direction.................................................................................................57

Roadless Areas..............................................................................................................................................57

Management of Inventoried Roadless Areas ...........................................................................................58

Tree-cutting, Sale, or Removal ...................................................................................................................58

Road Construction and Reconstruction ....................................................................................................59

Alternative 4: Colorado Roadless Rule with Public Proposed Upper Tier.......................................................60

Comparison of Alternatives ....................................................................................................................................61

Chapter 3. Affected Environment and Environmental Consequences ....................................................79

Introduction...............................................................................................................................................................79

Analysis Area................................................................................................................................................79

Analysis Framework....................................................................................................................................81

Analysis Assumptions and Projections.....................................................................................................81

Vegetation and Forest Health .................................................................................................................................89

Introduction ..................................................................................................................................................89

Forest Management .....................................................................................................................................90

Forest Health - Insects and Diseases: Affected Environment ................................................................91

Forest Health - Insects and Diseases: Environmental Consequences ...................................................93

Forest Health – Insects and Diseases: Cumulative Effects .....................................................................96

Forest Health – Invasive Species: Affected Environment.......................................................................97

Forest Health – Invasive Species: Environmental Consequences..........................................................98

Forest Health – Invasive Species: Cumulative Effects ..........................................................................101

Fire and Fuels ..........................................................................................................................................................102

Introduction ................................................................................................................................................102

Fuel Treatments ..........................................................................................................................................103

Affected Environment ...............................................................................................................................105

Wildland Urban Interface (Community Protection Zones)..................................................................108

Carbon Storage and Fire............................................................................................................................109

Environmental Consequences ..................................................................................................................109

Cumulative Effects.....................................................................................................................................115

Mineral Resource and Energy Development – Saleable, Locatable, and Leasable........................................117

Introduction ................................................................................................................................................117

Affected Environment ...............................................................................................................................118

Leasable Minerals – Oil and Gas..............................................................................................................125

Leasable Minerals – Geothermal..............................................................................................................126

Saleable Minerals: Environmental Consequences .................................................................................127

Locatable Minerals – All Alternatives: Environmental Consequences...............................................129

Leasable Minerals – Coal: Environmental Consequences ....................................................................129

Leasable Minerals – Oil and Gas: Environmental Consequences........................................................136

Leasable Minerals – Geothermal: Environmental Consequences........................................................146
Cumulative Effects.....................................................................................................................................146

Soil, Water & Air Resources ..................................................................................................................................148

Introduction ................................................................................................................................................148

Soil: Affected Environment.......................................................................................................................148

Soil: Environmental Consequences..........................................................................................................148

Water: Affected Environment...................................................................................................................151

Water: Environmental Consequences .....................................................................................................154

Air: Affected Environment .......................................................................................................................158

Air: Environmental Consequences ..........................................................................................................159

Soil, Water & Air Resources: Cumulative Effects ..................................................................................160

Geological And Paleontological Resources.........................................................................................................162

Geological Resources: Introduction.........................................................................................................162

Geological Resources: Affected Environment........................................................................................162

Paleontological Resources: Introduction.................................................................................................162

Paleontological Resources: Affected Environment................................................................................162

Geological and Paleontological Resources: Environmental Consequences .......................................163

Threatened, Endangered, and Sensitive Plants ..................................................................................................164

Threatened, Endangered, and Sensitive Plants: Affected Environment.............................................164

Threatened, Endangered, and Sensitive Plants: Environmental Consequences ...............................169

Environmental Consequences Summary................................................................................................173

Threatened, Endangered and Sensitive Plants: Cumulative Effects ...................................................173

Aquatic Species and Habitat .................................................................................................................................175

Aquatic Species and Habitat: Affected Environment............................................................................175

Aquatic Species and Habitat: Environmental Consequences ..............................................................180

Aquatic Species and Habitat: Cumulative Effects .................................................................................188

Terrestrial Species and Habitat.............................................................................................................................190

Terrestrial Species and Habitat: Affected Environment .......................................................................190

Terrestrial Species and Habitat: General Environmental Consequences ...........................................199

Terrestrial Species and Habitat: Environmental Consequences ..........................................................204

Terrestrial Species and Habitat: Cumulative Effects .............................................................................216

Scenic Quality..........................................................................................................................................................220

Introduction ................................................................................................................................................220

Scenery: Affected Environment................................................................................................................220

Scenery: Environmental Consequences ..................................................................................................222

Scenery: Cumulative Effects .....................................................................................................................225

Recreation ................................................................................................................................................................226

Dispersed Recreation: Affected Environment........................................................................................226

Dispersed Recreation: Environmental Consequences...........................................................................227

Developed Recreation: Affected Environment ......................................................................................230

Developed Recreation: Environmental Consequences .........................................................................230

Recreation Special Uses (not including Ski Areas): Affected Environment.......................................231

Recreation Special Uses (not including Ski Areas): Environmental Consequences..........................231

Developed Ski Areas: Affected Environment ........................................................................................231

Developed Ski Areas: Environmental Consequences ...........................................................................233

Recreation: Cumulative Effects ................................................................................................................236

Wilderness ...............................................................................................................................................................237

Wilderness: Affected Environment..........................................................................................................237

Wilderness: Environmental Consequences ............................................................................................239

Wilderness: Cumulative Effects ...............................................................................................................240

Recommended Wilderness Areas.........................................................................................................................240

Recommended Wilderness: Affected Environment ..............................................................................240

Recommended Wilderness: Environmental Consequences .................................................................242
Recommended Wilderness: Cumulative Effects....................................................................................242

Other Designated Areas.........................................................................................................................................243

Congressionally Designated Protection Areas – Affected Environment............................................243

Congressionally Designated Protection Areas — Environmental Consequences.............................244

Congressionally Designated Wild & Scenic Rivers – Affected Environment....................................244

Congressionally Designated Wild & Scenic Rivers – Environmental Consequences.......................244

Congressionally Designated Trail, Continental Divide National Scenic Trail – Affected 

Environment ...............................................................................................................................................245

Other Congressionally Designated Trails – Environmental Consequences.......................................245

Administratively Designated Areas – Affected Environment.............................................................245

Administratively Designated Areas - Environmental Consequences ................................................250

Roadless Area Characteristics...............................................................................................................................251

Roadless Area Characteristics: Affected Environment .........................................................................251

Roadless Area Characteristics: Environmental Consequences ............................................................251

Roadless Area Characteristics: Cumulative Effects...............................................................................253

Reference Landscapes ............................................................................................................................................254

Reference Landscapes: Affected Environment ......................................................................................254

Reference Landscapes: Environmental Consequences .........................................................................254

Reference Landscapes: Cumulative Effects ............................................................................................255

Cultural Resources .................................................................................................................................................256

Introduction ................................................................................................................................................256

Cultural Resources: Affected Environment............................................................................................257

Cultural Resources: Environmental Consequences...............................................................................257

Cultural Resources – Cumulative Effects ...............................................................................................259

Lands - Special Use Authorizations .....................................................................................................................260

Introduction ................................................................................................................................................260

Lands Special Use Authorizations: Affected Environment..................................................................260

Lands Special Use Authorizations: Environmental Consequences.....................................................260

Lands Special Use Authorizations: Cumulative Effects .......................................................................265

Livestock Management..........................................................................................................................................266

Livestock Management - Affected Environment...................................................................................266

Livestock Management - Environmental Consequences......................................................................267

Livestock Management - Cumulative Effects.........................................................................................268

Abandoned Mines and Public Safety...................................................................................................................269

Abandoned Mines and Public Safety: Affected Environment .............................................................269

Abandoned Mines and Public Safety: Environmental Consequences ................................................270

Social Values............................................................................................................................................................270

Introduction ................................................................................................................................................270

Social Values: Affected Environment......................................................................................................270

Social Values: Environmental Consequences.........................................................................................280

Social Values: Cumulative Effects............................................................................................................286

Economics ................................................................................................................................................................287

Economics: Affected Environment ..........................................................................................................287

Benefits and Costs ......................................................................................................................................299

Economic Impacts: Environmental Consequences ................................................................................299

Summary of Effects ....................................................................................................................................306

Economics: Cumulative Effects ................................................................................................................316

Other Effects Disclosures .......................................................................................................................................317

Short-Term Uses and Long-Term Productivity .....................................................................................317

Unavoidable Adverse Effects ...................................................................................................................318

Irreversible and Irretrievable Commitments of Resources...................................................................318

Other Required Disclosures......................................................................................................................320
Chapter 4. Preparers and EIS Distribution .............................................................................................321

List of Preparers ......................................................................................................................................................321

Primary Contributors to the EIS...............................................................................................................321

Other Contributors to the EIS...................................................................................................................324

National Forest Coordinators ...................................................................................................................326

Distribution of the Draft Environmental Impact Statement .............................................................................327

Government Agencies and Tribal Governments ...................................................................................327

Chapter 5. References Cited.....................................................................................................................333

Index .........................................................................................................................................................347

Appendices

Appendix A: Comparison of Colorado Roadless Areas with Inventoried Roadless Areas

Appendix B: Forest Plan Management Direction in Roadless Areas; Proposed Action Upper Tier 

Acres

Appendix C: Alternative 4 Upper Tier Acres

Appendix D: Forest Projections in Roadless Areas

Appendix E: Cumulative Effects

Appendix F: Ski Areas Within Roadless Areas

Appendix G: Maps of Demographics in Colorado

Appendix H: Temporary Road Requirements for Alternatives 2 and 4
List of Tables

Table 1. National forest administrative units in Colorado....................................................................................5

Table 2 Comparison of alternatives by environmental consequences ..............................................................20

Table 1-1. National forest administrative units in Colorado .............................................................................36

Table 2-1. Definitions of road and linear construction zone terms. ...................................................................44

Table 2-2. Features Common to All Alternatives .................................................................................................45

Table 2-3. Net change in roadless acreage by forest ............................................................................................48

Table 2-4. Alternative 1, exceptions in which tree-cutting, sale, or removal....................................................49

Table 2-5. Alternative 1, exceptions in which road construction and reconstruction may occur .................50

Table 2-6. CRA Upper Tier Acres and CRA Optional Upper Tier Acres by Forest.........................................52

Table 2-7. Alternative 2, exceptions in which tree-cutting, sale, or removal would be allowed ..................53

Table 2-8. Alternative 2, exceptions in which forest (permanent) road construction and reconstruction 

would be allowed................................................................................................................................................54

Table 2-9. Alternative 2, exceptions in which only temporary road construction and reconstruction would 

be allowed ............................................................................................................................................................55

Table 2-10. Alternative 2, exceptions in which linear construction zones would be allowed........................55

Table 2-11. Alternative 2, additional provisions for managing land uses within CRAs.................................57

Table 2-12. Upper Tier CRAs by Forest designated under Alternative 4 .........................................................61

Table 2-13. Comparison of alternatives .................................................................................................................62

Table 2-14. Comparison of alternatives by environmental consequences ........................................................73

Table 3-1. Provisions that Apply to each Portion of the Analysis Area ............................................................80

Table 3-2. Distribution of average annual tree-cutting, sale or removal projections.......................................83

Table 3-3. Miles of existing authorized roads in roadless areas .........................................................................83

Table 3-4. Distribution of average annual road construction and reconstruction projections ......................85

Table 3-5. Projected Road Construction/Reconstruction in Coal Analysis Area ............................................86

Table 3-6. Distribution of average annual road construction and reconstruction projections for oil and gas 

development ........................................................................................................................................................87

Table 3-7. Average annual road construction and reconstruction miles projected by alternative ................87

Table 3-8. Average annual LCZ miles projected by alternative .........................................................................88

Table 3-9. Forest cover type distribution in the Colorado Roadless Rule analysis area .................................89

Table 3-10. Tree size distribution............................................................................................................................90

Table 3-11. Principal insect and disease damaging agents within roadless areas. ..........................................93

Table 3-12. Fire Regime Types ..............................................................................................................................106

Table 3-13. Fire Regime Classes in 1.5 mile CPZ IRAs and CRAs ...................................................................107

Table 3-14. Condition Class in 1.5 mile CPZ in IRAs/CRAs ............................................................................109

Table 3-15. Potentially Minable Coal Resources by National Forest, IRA and CRA ....................................122

Table 3-16. Projected Road Construction/Reconstruction in Coal Analysis Area .......................................125

Table 3-17. Comparison of estimated projections of oil and gas road miles, road acres, wells, pads, pad 

acres, and production in IRAs and CRAs. .....................................................................................................126

Table 3-18. Summary of Effects for Coal Resources, GMUG National Forest................................................135

Table 3-19. Acres leased in IRAs as of September 2009 .....................................................................................137

Table 3-20. Acres leased in CRAs as of September 2009 ...................................................................................139

Table 3-21. Acres leased and acres available for leasing under forest plans and oil and gas leasing 

availability decisions as of September 2009...................................................................................................142

Table 3-22. Roadless areas with lands available for leasing in areas with low potential for development as 

of September 2009 .............................................................................................................................................144

Table 3-23. Streams and impaired streams in Colorado....................................................................................152

Table 3-24. Streams in Colorado and impaired streams in roadless areas......................................................152

Table 3-25. Status of Total Maximum Daily Loads for Impaired Waterbodies in Roadless Areas .............153

Table 3-26. Class 1 Area Visibility ........................................................................................................................159
Table 3-27. Occurrence of threatened and endangered plant species within roadless areas ......................165

Table 3-28. List and distribution of sensitive species by habitat groups within roadless areas...................167

Table 3-29. Relative risk to rare plants under each alternative due to projected activities and associated 

threats from weed invasion or fragmentation...............................................................................................173

Table 3-30. Threatened, endangered or sensitive fish species that occur or are likely to occur in roadless 

areas in Colorado...............................................................................................................................................177

Table 3-31. Federally listed fish found downstream of the roadless areas in Colorado that could be 

influenced by upstream activities on NFS land ............................................................................................178

Table 3-32 Aquatic management indicator species for national forests in Colorado ....................................179

Table 3-33. Change in stream miles in roadless areas between the IRA and CRA boundaries ...................180

Table 3-34. Occurrence of threatened and endangered species or their habitat within roadless areas ......192

Table 3-35. Sensitive animal species associated with roadless areas in Colorado .........................................193

Table 3-36. Terrestrial management indicator species, their population and habitat trend in Colorado, and 

reason for selection............................................................................................................................................196

Table 3-37. Scenic Integrity Objectives and Visual Quality Objectives ...........................................................221

Table 3-38. Colorado ski areas on National Forest System lands.....................................................................232

Table 3-39. Permitted ski area acreage in the IRAs prior to date of Rule........................................................234

Table 3-40. Ski area acreage in the IRAs but not included in CRAs ................................................................235

Table 3-41. Existing Wilderness Areas in Colorado ..........................................................................................238

Table 3-42. Acres of Recommended Wilderness ................................................................................................241

Table 3-43. Congressionally Designated Protection Areas in Colorado..........................................................243

Table 3-44. Research natural areas within roadless areas .................................................................................246

Table 3-45. Research natural area forest plan direction.....................................................................................246

Table 3-46. Special interest areas within roadless areas ....................................................................................248

Table 3-47. Special interest area forest plan direction........................................................................................249

Table 3-48. Rangeland and Livestock Management Acres ...............................................................................266

Table 3-49. Colorado counties with IRA and CRA acres...................................................................................271

Table 3-50. Environmental justice statistics for roadless area counties in Colorado .....................................275

Table 3-51. Examples of forest values ..................................................................................................................278

Table 3-52. Forest value/interest categories used for Colorado roadless area analysis ...............................279

Table 3-53. Value of Production, Employment, and Labor Income in the Colorado Economy...................288

Table 3-54. Colorado Counties by Economic Impact Model Area ...................................................................292

Table 3-55. Value of Production, Employment, and Labor Income in the Energy Roadless Model Area..294

Table 3-56. Comparison of the Energy Roadless model area with other roadless model areas ..................294

Table 3-57. Comparison of the Mineral Industry in roadless model areas .....................................................295

Table 3-58. Estimated Non-agricultural Single-Family Residences and Valuation within 500 Meters of 

Forested Public Lands in Counties with Inventoried Roadless Areas .......................................................297

Table 3-59. Average Annual Economic Impacts by Alternative for Energy Mineral Activity in the Energy 

Roadless Model Area, 2010-2024 ....................................................................................................................301

Table 3-60. Alternative 1 – Average Annual Federal Mineral Lease Production, Payments, and Related 

Tax Revenues from Roadless Areas, 2010-2024 ............................................................................................303

Table 3-61. Alternatives 2 and 4 – Average Annual Federal Mineral Lease Production, Payments, and 

Related Tax Revenues from Roadless Areas, 2010-2024 .............................................................................304

Table 3-62. Alternative 3 – Average Annual Federal Mineral Lease Production, Payments, and Related 

Tax Revenues from Roadless Areas, 2010-2024 ............................................................................................305

Table 3-63a. Potential Fuel Treatment Acres in the Community Protection Zone within 0.5 and 1.5 miles of

At-Risk Communities, Totals by County, acres rounded to nearest 100 ...................................................309

Table 3-63b. Potential Fuel Treatment Acres in the Community Protection Zone within 0.5 and 1.5 miles 

of At-Risk Communities Compared with Alternative 3, Totals by County, acres rounded to nearest 100 

acres.....................................................................................................................................................................310

Table 3-64a. Share of Total NFS Lands in the Community Protection Zone where Potential Exists for Fuel 

Treatment by County........................................................................................................................................312
Table 3-64b. Change in Share of Total NFS Lands in the Community Protection Zone where Potential1

Exists for Fuel Treatment Compared with Alternative 3 by County .........................................................313

List of Figures

Figure 1. Inventoried roadless areas in Colorado ..................................................................................................2

Figure 2. Alternative 2 Proposed Colorado roadless areas with Upper Tier Acres ..........................................6

Figure 3. Alternative 4 Proposed Colorado roadless areas with Upper Tier Acres ..........................................7

Figure 3-1. Colorado estimated population from 1900 to 2000 and projected for 2010 to 2030 ...................272

Figure 3-2. Colorado population by age, estimated for 1990 and 2000, projected for 2010 to 2030.............273

Figure 3-3. Colorado population by racial group estimated for 2000 to 2005 and projected 

for 2010 to 2030 ..................................................................................................................................................274

Figure 3-4. Colorado economic impact model areas..........................................................................................293
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Summary—1

SUMMARY OF THE ENVIRONMENTAL IMPACT STATEMENT

DOCUMENT STRUCTURE

The Forest Service has prepared an environmental impact statement (EIS) in compliance with 

the National Environmental Policy Act (NEPA) and other relevant federal laws and regulations. 

The EIS discloses the potential environmental consequences that may result from the proposed

action and alternatives. This summary presents the pertinent information from the full EIS in 

abbreviated form.

Supporting documents for the EIS may be found in the EIS record, located at the Forest 

Service‘s Rocky Mountain Regional Office, 740 Simms Street, Lakewood, CO. Some supporting 

documents, and the full EIS, are also available on the Web at www.roadless.fs.fed.us/colorado.

BACKGROUND

The Forest Service administers approximately 14,520,000 acres of publicly-owned lands in 

Colorado distributed among eight national forests and two national grasslands. These national 

forests and grasslands are characterized by a diverse array of landscapes, ecosystems, natural 

resources, and land use activities. Management of each national forest and grassland is 

governed by a land and resource management plan (forest plan), along with numerous land 

management laws, regulations, policies, and agency directives. Laws and regulations take 

precedence over management direction in the forest plans where conflicts in management 

direction exist. 

In January 2001, a Roadless Area Conservation Rule (2001 Roadless Rule) was adopted into 

regulation at 36 CFR 294, following completion of a final EIS (USDA Forest Service 2000a). The 

2001 Roadless Rule applied to national forests nationwide. It provided overarching protections 

for 58.5 million acres1 of inventoried roadless areas (IRAs) (about 30 percent of NFS lands in the 

country) by prohibiting road construction and reconstruction and timber harvest in IRAs except 

under certain exceptional circumstances. The intent of the 2001 Roadless Rule was ―to provide 

lasting protection for IRAs within the context of multiple-use management‖ (USDA Forest 

Service 2000a). 

 

1 Approximately 9.3 million acres of roadless areas in Alaska’s Tongass National Forest were exempted from the 

2001 Roadless Rule. 
Rulemaking for Colorado Roadless Areas DEIS

2—Summary

Figure 1. Inventoried roadless areas in Colorado

The 2001 Roadless Rule identified approximately 4,433,000 acres, or about 31 percent, of the 

National Forest System (NFS) lands in Colorado as IRAs. For this EIS, private land and 

congressionally designated land was removed from the inventory. Management of 

congressionally designated land is governed by laws that supersede any roadless area rule2. 

Figure 1 displays the IRAs that are evaluated in this EIS, and are common to alternatives 1 and 

3. There are 4,243,600 acres within the IRAs for these two alternatives. Maps are available in the 

full EIS and on the Web at www.roadless.fs.fed.us/colorado. 

Roadless area characteristics, as defined in the 2001 Roadless Rule preamble (66 FR 3244) and 

referred to in the proposed Colorado Roadless Rule, are summarized as follows: high quality or 

undisturbed soil, water, or air; sources of public drinking water; diversity of plant and animal 

communities; habitat for threatened, endangered, proposed, candidate, and sensitive species, 

and for those species dependent on large, undisturbed areas of land; primitive, semi-primitive

motorized, and semi-primitive non-motorized classes of dispersed recreation; reference 

landscapes; natural-appearing landscapes with high scenic quality; traditional cultural 

 

2 Congressionally designated areas include such lands as Wilderness, Wild and Scenic Rivers, and Protection Areas 

(described in EIS Appendix A, Table A-1)
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Summary—3

properties and sacred sites; and, other locally identified unique characteristics. 

In May 2005 Colorado enacted Senate Bill 05-243 (C.R.S. § 36-7-302) directing formation of a 13-

person bipartisan taskforce to make recommendations to the Governor regarding the 

appropriate management of roadless areas on the national forests in Colorado. In November 

2006, Colorado Governor Bill Owens petitioned the Secretary of Agriculture to undertake statespecific roadless rulemaking for Colorado. The State‘s petition was considered for rulemaking 

by the Secretary of Agriculture in accordance with the Administrative Procedures Act, section 

553(e) of the U.S. Code of Federal Regulations (CFR) and the Department of Agriculture‘s 

rulemaking procedures at 7 CFR §1.28. In April 2007, newly-elected Governor Ritter 

resubmitted the petition with minor modifications (Colorado Office of the Governor 2007). In

June 2007, the State and the U.S. Forest Service presented the petition with modifications to the 

Department‘s Roadless Area Conservation National Advisory Committee (RACNAC). The 

RACNAC provided recommendations on the State petition to the Secretary of Agriculture 

(USDA RACNAC 2007a). In August 2007, the Secretary of Agriculture accepted the State‘s 

petition and directed the Forest Service to work in cooperation with the State of Colorado to 

initiate rulemaking (USDA RACNAC 2007b).

The Forest Service published a proposed rule to establish direction for conserving roadless areas 

on NFS land in Colorado on July 25, 2008 (73 FR 43544). Throughout the process, the United 

States Department of Agriculture (USDA), State, and Forest Service repeatedly heard public 

comment requesting a reduction in the scope of the proposed exceptions for tree-cutting, sale or 

removal and road construction and reconstruction. Based on these public comments, the State 

requested the USDA to postpone further rulemaking efforts until the State considered revision

of its petition.

The State held a comment period from August 3 to October 3, 2009. The State received 

approximately 22,000 comments, with most being form letters. The result was a revised petition

submitted to the Secretary of Agriculture on April 6, 2010. Based on the petition, the State and 

the Forest Service developed regulatory language for a proposed Colorado Roadless Rule that 

would govern management of roadless areas on NFS lands in Colorado. Because of the changes 

in the boundaries of the Colorado Roadless Areas (CRAs) and the number of changes in the 

proposed rule, the Secretary of Agriculture initiated a public comment period on the revised 

proposed rule and this EIS. 

PURPOSE OF AND NEED FOR ACTION

The Department, the Forest Service, and the State of Colorado agree there is a need to provide 

management direction for the conservation of roadless area values and characteristics within 

roadless areas in Colorado. In the petition, the State of Colorado has indicated that there is a 

need to develop state-specific regulations for the management of Colorado‘s roadless areas for 

the following reasons:

1. Roadless areas are important because they are, among other things, sources of drinking 

water, important fish and wildlife habitat, semi-primitive or primitive recreation areas, 

and naturally appearing landscapes. There is a need to provide for the preservation of 

roadless area characteristics. 

2. As recognized in the 2001 Roadless Rule, tree-cutting, sale or removal, and road 
Rulemaking for Colorado Roadless Areas DEIS

4—Summary

construction/reconstruction have the greatest likelihood of altering and fragmenting 

landscapes, resulting in immediate, long-term loss of roadless area values and 

characteristics and there is a need to generally prohibit these activities in roadless areas. 

Since the 2001 Roadless Rule was promulgated, some have argued that linear 

construction zones (LCZs) also need to be restricted. 

3. In addition to the concerns articulated in the 2001 Rule, there is a need to accommodate 

State-specific situations and concerns in Colorado‘s roadless areas. These include the 

following: 

a. reducing the risk of wildfire to communities and municipal water supply 

systems

b. permitting exploration and development of coal resources in the North Fork 

coal mining area

c. permitting of construction and maintenance of water conveyance structures

d. permitting access to current and future electrical power lines

e. accommodating existing permitted or allocated ski areas. 

4. There is a need to ensure that Colorado roadless areas are accurately mapped.

PROPOSED ACTION 

The Department, in cooperation with the State of Colorado, proposes to promulgate a statespecific rule to manage roadless areas and conserve roadless area characteristics on NFS lands 

in Colorado. 

The Colorado Roadless Rule would establish a system of Colorado Roadless Areas (CRAs) with 

protections for management of these areas replacing the Inventoried Roadless Areas (IRAs) for 

National Forest land in Colorado. CRAs would be identified on a set of maps maintained at the 

Forest Service national headquarters office, including records of adjustments to such maps 

pursuant to the final Colorado Roadless Rule. The CRAs upper tier acres, which are a subset of 

CRAs receiving a higher level of protection, would be identified on the same set of maps.

The proposed Colorado Roadless Rule would use the most accurate mapping information and 

adjust roadless area boundaries by: 

a. correcting mapping errors that primarily resulted from improvements in 

inventory data and mapping technology;

b. excluding private land; 

c. excluding land substantially altered by roads and timber harvest activities; 

d. excluding ski areas under permit or allocated in forest plans to ski area 

development; 

e. excluding congressionally designated lands such as wilderness and other 

designations that take legal precedence over roadless area regulations; and 

f. including unroaded areas outside IRAs that contain roadless area characteristics. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Summary—5

The CRAs would encompass approximately 4.19 million acres of NFS land in Colorado, 

distributed among 363 separate roadless areas (Appendix A). The proposed Colorado Roadless 

Rule provides for future adjustments to be made to CRA boundaries (Map Packet, Map 3), 

subject to a public review and comment, and applicable NEPA or rulemaking requirements. 

The Forest Service national headquarters office would maintain the official map of CRAs, which 

would be readily available to the public.

The Colorado Roadless Rule includes a management strategy for activities and land uses within 

CRAs that are tailored to meet the unique circumstances present in Colorado. Road construction 

and reconstruction, tree-cutting, sale or removal and linear construction zones are prohibited 

within the CRAs with limited exceptions. Chapter 2 describes the proposed rule in greater 

detail, along with other alternatives considered in this analysis.

Table 1. National forest administrative units in Colorado and associated forest plan approval date

National forests in Colorado Date of approved forest plan

Arapaho-Roosevelt National Forests 1997

Grand Mesa, Uncompahgre, and Gunnison National Forests 1983

Manti-La Sal National Forest 3

1986

Routt National Forest 1998

Pike-San Isabel National Forests 1984

Rio Grande National Forest 1996

San Juan National Forest 1983 

(Revision in progress; draft revised plan 2007)

White River National Forest 2002

The proposed Colorado Roadless Rule establishes boundaries for Colorado roadless areas 

(CRAs) and associated provisions for managing those areas. The rule maintains many of the 

2001 Roadless Rule prohibitions on road construction and reconstruction and tree-cutting 

activities in roadless areas; however, there are some important differences. The proposed rule 

differs from the 2001 Rule primarily by adding an upper tier with more restrictions than the 

2001 Rule, by adding additional requirements to exceptions found in the 2001 Rule, and by 

providing a limited set of exceptions that are not found in the 2001 Rule.

As requested by the Governor‘s petition, the proposed Colorado Roadless Rule adjusts roadless 

area boundaries by: (a) adjusting some roadless area boundaries to correct mapping errors that 

primarily resulted from improvements in inventory data and mapping technology; (b) not 

including acres substantially altered by existing roads and past timber harvest activities; (c) not 

including ski areas currently under permit or allocated to ski area management areas adjoining 

operating ski areas in forest plans; (d) not including congressionally designated lands such as 

wilderness that take legal precedence over roadless area regulations; (e) including in CRAs 

some additional unroaded acreages that are outside IRAs. 

The proposed CRAs encompass approximately 4.186 million acres, or about 29 percent, of NFS

land in Colorado, distributed among 363 separate roadless areas (Figure 2). The scope of the 

proposed action is primarily limited to tree-cutting, road construction and reconstruction, and 

the use of linear construction zones within roadless areas. Portions of the CRAs are designated 

 

3 Only 27,000 acres of the 1.4 million-acres of the Manti-La Sal National Forest occur in Colorado; the rest are in 

Utah and not subject to the EIS. 
Rulemaking for Colorado Roadless Areas DEIS

6—Summary

as upper tier acres with fewer exceptions to the prohibitions. The proposed rule would not 

affect land use permits, contracts, or other legal instruments issued prior to the effective date of 

a rule. The scope of the proposed rule is programmatic in nature and intended to guide future 

actions proposed to occur within CRAs. This proposal does not authorize the implementation of 

any ground-disturbing activities, but rather it describes circumstances under which certain 

activities may be allowed or restricted within roadless areas in the future. Where conflicting 

management direction exists between forest plans and a Colorado Roadless Rule provision, the 

more restrictive direction would prevail. 

Alternative 4 has the same CRA boundaries as alternative 2 and the same rule provisions. The 

difference is there are more acres within the CRAs that are designated as upper tier acres where 

there are fewer exceptions to the prohibitions (Figure 3).

Figure 2. Alternative 2 Proposed Colorado roadless areas with Upper Tier Acres
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Summary—7

Figure 3. Alternative 4 Proposed Colorado roadless areas with Upper Tier Acres

DECISION FRAMEWORK

The Secretary of Agriculture or a delegated designee will decide whether to promulgate the 

Colorado Roadless Rule as proposed or one of the other alternatives analyzed in this EIS. 

Promulgation of a rule involves establishing regulations, which would be issued under Title 36 

of the Code of Federal Regulations (CFR) Part 294. The decision to be made involves a choice 

among the four alternatives analyzed in detail in this EIS, which means determining whether to: 

1. Promulgate a state-specific rule to manage IRAs in Colorado pursuant to the provisions 

contained in the 2001 Roadless Rule (alternative 1); or

2. Promulgate a state-specific rule to manage Colorado‘s CRAs based on the State‘s 

petition (alternative 2) with portions of the CRAs identified as CRA upper tier acres; or

3. Take no action. No state-specific roadless rule would be promulgated. IRAs in Colorado 

would be managed in accordance with the forest plans in the eight national forests 

(alternative 3); or 

4. Promulgate a state-specific rule to manage Colorado‘s CRAs based on the State‘s 

petition with portions of or entire CRAs identified as CRA upper tier acres different 
Rulemaking for Colorado Roadless Areas DEIS

8—Summary

from those identified under alternative 2 (alternative 4); or

5. Some combination of the provisions and inventories in the above four alternatives. 

PUBLIC INVOLVEMENT

The Forest Service and the State of Colorado have solicited public involvement and comments 

on the development of a Colorado Roadless Rule. Below is a description of the public 

involvement efforts of the Forest Service and the State of Colorado.

Forest Service Public Involvement

The Forest Service, to date, has solicited public involvement in the following ways:

On December 27, 2007, the Forest Service published a notice of intent in the Federal 

Register to prepare an EIS on roadless area conservation on NFS lands in Colorado (Fed. 

Reg. Vol. 72 No. 246, 72982). The Forest Service solicited comments from interested 

parties from December 27, 2007 through February 25, 2008. Approximately 88,000 

comments were received.

On July 25, 2008, the Forest Service published a proposed rule to establish state-specific 

management direction for conserving roadless areas in Colorado (73 FR 43544). A notice 

of availability for the DEIS was published in the Federal Register (73 FR 44991) and legal 

notice in the newspaper of record on August 1, 2008. The availability of the regulatory 

risk assessment for the proposed rule was published in the Federal Register on September 

18, 2008 (73 FR 54125). All comment periods closed on October 23, 2008. In total, 

approximately 106,000 comments were received.

The RACNAC held open public meetings in Washington, DC in June of 2007 and 

January, July and November of 2008. In addition a meeting was held in Salt Lake City, 

Utah in October of 2008. Public comments were accepted at these meetings, which 

helped the RACNAC develop their December 5, 2009 recommendations to the Secretary 

of Agriculture.

The Forest Service consulted with all potentially affected tribes regarding the proposed 

rule from October 2007 through October 2008. Tribal consultation on this proposed 

Colorado Roadless Rule is ongoing.

State of Colorado Public Involvement

In their petition process, the State of Colorado has, to date, solicited public involvement in the 

following ways:

Senate Bill 05–243, signed into Colorado law on June 8, 2005, created and identified a 13-

member bipartisan task force to make recommendations to the Governor regarding 

inventoried roadless areas on NFS lands in Colorado. The task force held nine public 

meetings throughout the State, held six deliberative meetings that were open to the 

public, and reviewed and considered over 40,000 public comments.

The State of Colorado held a comment period from August 3 to October 3, 2009 on a 

State modified version of the July 2008 proposed Colorado Roadless Rule.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Summary—9

TRIBAL CONSULTATION

There are two resident tribes in Colorado – Ute Mountain Ute and Southern Ute – who retain 

some of their traditional land base as reservations. These two tribes retain specific hunting

rights and other aboriginal rights throughout their traditional territory including portions of the 

roadless areas in Colorado. Over a dozen other tribes located outside Colorado maintain tribal 

interests, including aboriginal and ceded territories, and inherent aboriginal rights within 

Colorado. In 1874, Congress approved an agreement between the United States and certain Ute 

Indians in Colorado, known as the "Brunot Agreement". Under this agreement, the Utes ceded 

certain land to the United States but reserved a right to hunt on those lands. These lands are 

predominately on the San Juan National Forest.

The Forest Service has ongoing consultation with all the potentially-affected tribes. Tribal 

consultation was initiated in October 2007 and no reply letters were received during the scoping

period. However, tribal concerns that surfaced during other consultations are discussed in the 

EIS. Consultation with interested or affected tribes will continue throughout the analysis and 

decision-making process. 

ISSUES

The NEPA implementing regulations at 40 CFR §1501.2 requires federal agencies to develop 

and evaluate alternatives to recommended courses of action in any proposal that involves 

unresolved conflict concerning alternative uses of available resources. Public involvement was 

used to identify points of disagreement about the proposed Colorado Roadless Rule and to 

identify issues to use as a basis for developing and evaluating alternatives.

Comments that support the purpose of and need for the proposed action are not listed here as 

issues but are evaluated in this EIS as to how well each alternative addresses the purpose and 

need (refer to Purpose and Need section for details). For example, the alternatives are evaluated 

for the degree to which they meet the stated purpose and the need to conserve roadless area 

characteristics within the context of Colorado specific situations and concerns. 

NEPA regulations require the agency to identify and eliminate from detailed study those issues 

that are not significant or that have been covered by prior environmental review, to narrow the 

scope of the analysis. Reasons for eliminating issues from detailed study include when the 

issues are:

General opinions or position statements not specific to the proposed action 

Addressed by other laws, regulations, or policies 

Not relevant to the potential effects of the proposed action, or otherwise outside the 

scope of this analysis. 

The following issues were eliminated from detailed study in this EIS because they are outside

the scope of the decision to be made by the Secretary of Agriculture on the proposed Colorado 

Roadless Rule relative to other alternatives analyzed in this EIS (refer to sections on Decision 

Framework and Scope and Applicability of the Rule):

National Park Service management issues
Rulemaking for Colorado Roadless Areas DEIS

10—Summary

General conditions of public lands

Conditions of roads and facilities on national forests

Political motivations or integrity of government officials

Public participation processes or procedures

Funding priorities and government expenditures 

Alternative energy on national forests

Wilderness protection or recommendations for wilderness designation

Motorized vehicle use and routes or other travel management topics

Access associated with livestock grazing permits and allotment management

How the proposed Colorado Rule may set a precedent for management of roadless areas 

in other states. 

The following issues were carried through the analysis process to evaluate differences in the 

consequences among the alternatives.

Issue—Potential effects to opportunities for community wildfire protection. Prohibiting road 

construction or reconstruction and tree-cutting, sale or removal can influence the effectiveness 

of efforts to reduce wildfire impacts to communities and water supply systems.

Issue – Potential loss of roadless area characteristics. The exceptions, in which road 

construction or reconstruction, use of LCZs, tree-cutting, sale or removal, and some other 

activities may occur in roadless areas under the proposed Colorado Roadless Rule, may result 

in a loss of roadless area characteristics. 

Issue – Potential loss of opportunities to explore for and develop oil and gas resources. 

Prohibiting road construction or reconstruction to access oil and gas basins in roadless areas 

that have not been leased prior to the effective date of rulemaking may result in a loss of 

opportunities to explore for and develop oil and gas resources in those areas.

Issue – Potential reduction in native species diversity. The exceptions, under which road 

construction or reconstruction, use of LCZs, tree-cutting, sale or removal, and some other 

activities may occur in roadless areas under the Colorado Roadless Rule, may affect populations 

of wildlife, fish, and plants, including the potential for:

An increase in the prevalence of invasive plants, animals, and other organisms that can 

out-compete and dominate diverse native plant and animal communities.

A loss or reduction of wildlife or fish habitat or population viability, resulting from 

reductions in unfragmented interior habitat, migration corridor connections, and 

security and quality of habitat for some ―at risk‖ species or important game species.

A loss or reduction of threatened, endangered, or sensitive plant species habitat or 

populations.

Issue – Potential loss of opportunities to explore for and develop coal resources outside the 

North Fork coal area. Prohibiting construction/reconstruction of roads to access coal reserves 

in areas that have not been leased (prior to the effective date of rulemaking) and/or are located 

outside the North Fork coal mining area may result in a loss of opportunities to explore for and 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Summary—11

develop coal resources in those areas.

Issue - Potential reduction in soil and water quality. Wildfire effects can also reduce soil and 

water quality. The effects of wildlife could potentially be reduced by fuels treatments. On the 

other hand, the exceptions in which road construction or reconstruction, the use of LCZs, and 

tree-cutting, sale or removal may occur in roadless areas under the proposed rule may result in 

a decline in soil or water quality, including the potential for:

Accelerated soil erosion or other soil impacts that can affect long-term productivity.

Increases in stream sedimentation that can affect water quality and water uses off-site 

and downstream from the roadless areas.

Issue - Potential reduction in semi-primitive recreation and related values. The exceptions in 

which road construction or reconstruction, use of LCZs, tree-cutting, sale or removal, and some 

other activities may occur in roadless areas under the proposed Colorado Roadless Rule may 

result in a reduction in semi-primitive recreation opportunities away from the sights and 

sounds of human activities and built environments, including the potential for:

A reduction in opportunities for solitude

A reduction in scenic quality

Reductions in scientific and heritage benefits that might be derived from preserving the 

undeveloped nature of roadless areas for future generations

Issue – Potential loss of opportunity to feasibly transport oil and gas resources using 

pipelines. Prohibiting oil and gas pipelines from going through roadless areas from lands 

outside roadless areas may result in a loss of opportunity to feasibly extract and transport oil 

and gas resources. 

ALTERNATIVES

Alternative 1: Provisions of the 2001 Roadless Area Conservation Rule (2001 Roadless 

Rule). This alternative establishes a state-specific roadless rule for Colorado that retains 

IRA boundaries and roadless area management provisions for management of roadless 

areas on NFS land in Colorado contained in the 2001 Roadless Rule. If a decision is made 

to select this alternative, it would not revoke, suspend, or modify any permit, contract or 

other legal instrument authorizing the occupancy and use of NFS lands issued before the 

effective date of the final Rule. 

Alternative 2: Proposed Action, Colorado Roadless Rule. This alternative establishes a 

state-specific roadless rule for Colorado. It modifies Alternative 2 from the DEIS based 

on public comments and the revised petition submitted by the State of Colorado. It is 

based on the provisions of the 2001 Roadless Rule, but provides prohibitions and 

specific exceptions relevant to the State of Colorado. There are 562,200 acres identified as 

CRA upper tier under this alternative. Upper tier acres have fewer exceptions to the 

prohibitions than the other CRA acres. If a decision is made to select this alternative, it 

would not revoke, suspend, or modify any permit, contract or other legal instrument 

authorizing the occupancy and use of NFS lands issued before the date of the final Rule. 
Rulemaking for Colorado Roadless Areas DEIS

12—Summary

Alternative 3: No Action, Forest Plan Direction. This alternative does not establish a 

state-specific roadless rule for Colorado and all lands in the IRAs and CRAs would be 

managed according to forest plan direction. The boundaries of the roadless areas shown 

in this alternative for information purposes are those in the most recent forest plans and 

are the same IRAs as those in alternative 1.

Alternative 4: Colorado Roadless Rule with Public Proposed Upper Tier. This 

alternative establishes a state-specific roadless rule for Colorado. This alternative 

provides the same prohibitions and exceptions as alternative 2. The difference is that 

2,614,200 acres are identified as CRAs upper tier acres in this alternative (over 2 million 

more acres in upper tier than alternative 2). If a decision is made to select this 

alternative, it would not revoke, suspend, or modify any permit, contract or other legal 

instrument authorizing the occupancy and use of NFS lands issued before the date of the 

final Rule.

Features Common to All Alternatives

The following features apply equally to all alternatives and are not repeated in the alternative 

descriptions. 

Federal and State Requirements. Management of NFS lands in Colorado are governed 

by a variety of federal statutes, regulations, executive orders, and the Forest Service 

Directive System. In addition, some State and local laws and regulations apply on NFS 

lands within the State. All alternatives in this analysis assume that these governing 

authorities are not affected.4

Forest Plans. The National Forest Management Act (NFMA) and its implementing 

regulations at 36 CFR 219 obligate the Forest Service to develop, amend, or revise forest 

plans. Direction set forth in forest plans for the national forests in Colorado would 

continue to govern project and activity decision-making on NFS lands, including 

roadless areas except where the direction contained in the chosen alternative is more 

restrictive.

Project Specific Environmental Analysis. All future proposals for road construction 

and reconstruction, tree-cutting and removal, and other activities that are permissible 

under any alternative must undergo appropriate environmental analysis and decisionmaking processes pursuant to NEPA and its implementing regulations.

Reserved and Outstanding Rights. Under all alternatives, the exercise of outstanding 

rights for access, occupancy, and use of NFS lands within designated roadless areas 

would not be affected. These include those that exist by law, treaty rights or other 

authority. 

Existing Land Use Authorizations. All of the alternatives allow for the continuation, 

transfer, or renewal of valid and existing land use authorizations (in permits, contracts, 

and other written instruments) for activities in roadless areas, for those authorizations 

that exist at the time the applicable roadless rule becomes effective. For clarification, 

 

4 One example of a federal statute is the General Mining Law of 1872, which would allow for road construction and 

use within roadless areas as needed for the exploration and development of valid claims of locatable (“hard rock”) 

minerals. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Summary—13

―existing‖ authorizations under the alternatives that establish a state-specific roadless 

rule for Colorado (alternatives 1, 2 and 4) would be those that currently exist or are 

issued prior to adoption of the final rule. Most land use authorizations are discretionary 

and authorized by the Secretary of Agriculture or his designated Forest Service official. 

Examples include but are not limited to the following land uses: 

o Use of existing roads and trails, including motorized travel on roads and trails

o Livestock grazing

o Recreational activities, including but not limited to hunting, fishing, hiking, 

camping, mountain biking, and skiing.

Management of congressionally designated areas is governed by legislated direction that 

overrides rulemaking direction for management of roadless areas. Therefore, for the purposes 

of this analysis, 185,000 acres of congressionally designated areas are not included in roadless 

areas under any alternative.

All alternatives identify specific areas to be managed as roadless areas. For purposes of this 

analysis, alternatives 1 and 3 have the same IRA boundaries. Alternatives 2 and 4 propose 

modifications of those roadless area boundaries and are referred to as CRAs. The area analyzed 

for environmental effects is the same for all alternatives. Analysis for each alternative considers 

both those areas within each alternative‘s roadless inventory and managed as roadless 

according to that alternative; and those areas outside each alternative‘s roadless inventory that 

is managed according to each respective forest plan. Under alternative 3, all areas are managed 

according to the forest plan.

Alternative 1: Provisions of the 2001 Roadless Rule 

This alternative establishes a state-specific roadless rule for Colorado that retains IRA 

boundaries5 and roadless area management provisions contained in the 2001 Roadless Rule for 

management of roadless areas on NFS land in Colorado. The newly identified roadless acres 

(409,500) are not within the IRAs and would be managed according to forest plan direction 

under this alternative. 

Alternative 1 would allow roads to be constructed or reconstructed in roadless areas under 

certain circumstances, such as those needed for: 

Protect public health and safety

Emergency environmental response under the Comprehensive Environmental 

Response, Compensation, and Liability Act (CERCLA)

Reserved and outstanding rights, existing land use authorizations

Road-related resource damage

Certain federal highway projects

Road traffic safety

 

5 Congressionally designated acres as well as mapping errors associated with private lands and Wilderness have 

been eliminated from the IRA boundaries; 4.24 million acres in IRAs.
Rulemaking for Colorado Roadless Areas DEIS

14—Summary

Reasonable access to leaseable minerals in existing lease areas.

Alternative 1 allows tree-cutting, sale, or removal in IRAs under certain conditions, such as:

To maintain or improve threatened, endangered, proposed, or sensitive species habitat

To maintain or restore the characteristics of ecosystem composition and structure, such 

as to reduce the risk of uncharacteristic wildfire effects

Where it is incidental to the implementation of a management activity not otherwise 

prohibited by this subpart

Where needed for personal or administrative uses provided for in 36 CFR Part 223- Sale 

and Disposal of National Forest System Timber

Within portions of IRAs where roadless area characteristics have been substantially 

altered by the construction of a NFS road and subsequent timber harvest.

Alternative 2: Proposed Action – Colorado Roadless Rule

Under alternative 2, the Colorado Roadless Rule, approximately 4.19 million acres of NFS lands 

in Colorado would be identified as CRAs. The Colorado Roadless Rule establishes general 

prohibitions on road construction and reconstruction, LCZs, and tree-cutting, sale or removal 

within CRAs, while permitting those activities under certain exceptions to address State and 

local land management needs. Under this alternative, substantially altered acres within the 

IRAs have been removed from the CRA inventory and would be managed following forest plan

direction. An additional 409,500 roadless acres were added to the inventory. 

This alternative designates 562,200 acres as CRA upper tier acres6 . These areas were identified 

in forest plans, or during forest plan revision processes, as areas where tree-cutting and road 

building restrictions would be appropriate. 

Alternative 2 generally prohibits the cutting, sale, or removal of trees within CRAs with limited 

exceptions. The Responsible Official must first determine the activity is consistent with the 

applicable forest plan, and one or more of the roadless area characteristics would be maintained 

or improved over the long-term (except for where tree-cutting is incidental or for personal or 

administrative uses). Tree-cutting is allowed in the upper tier only for the following two 

exceptions:

Purposes incidental to management activities that are not otherwise prohibited by this 

proposed Rule; 

Personal or administrative use, as provided for in 36 CFR 223- Sale and Disposal of 

National Forest System Timber.

For the standard tier acres (CRA acres not designated as upper tier acres, also referred to as 

―non-upper tier acres‖), the above exceptions apply as do these:

The Regional Forester determines tree-cutting is needed to reduce the wildfire hazard to 

an at-risk community or municipal water supply system when within the first 1⁄2 mile of 

 

6 Colorado Roadless Areas upper tier acres refer to areas identified in a set of maps maintained at the national 

headquarters office of the Forest Service, including records regarding any adjustments or modifications to such 

maps. Further detail on the upper tier acres are found in Appendix Table B-8.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Summary—15

the community protection zone or within the next one-mile of the community protection 

zone where proposed projects are within an area identified in a Community Wildfire 

Protection Plan (CWPP). Projects would focus on small diameter trees to create fuel

breaks that modify fire behavior while retaining large trees to the maximum extent 

practical as appropriate to the forest type;

The Regional Forester determines tree-cutting is needed outside of the community 

protection zone where there is a significant risk that a wildland fire disturbance event 

could adversely affect a municipal water supply system or the maintenance of the 

system. Projects would focus on cutting and removing generally small diameter trees to 

create fuel breaks that modify fire behavior while retaining large trees to the maximum 

extent practical as appropriate to the forest type;

Tree-cutting is needed to maintain or restore the characteristics of ecosystem

composition, structure and processes; or

To improve threatened, endangered, proposed, or sensitive species habitat in 

coordination with the Colorado Department of Natural Resources including the 

Colorado Division of Wildlife.

Roads may only be constructed in CRAs if the responsible official determines that certain 

limited circumstances exist. Before allowing road construction, the official must consider a noroad option and a temporary road option. All temporary roads constructed in CRAs would be 

decommissioned and the affected landscape restored when the road is no longer needed. 

Within a native cutthroat trout catchment or identified recovery watershed, the responsible 

official must determine that road construction would not diminish, over the long-term, 

conditions in the water influence zone and in the native cutthroat habitat.

The exceptions in alternative 2 that would allow roads to be constructed or reconstructed in 

CRAs are those needed to:

Exercise reserved and outstanding rights, or as provided for in statute and treaty; this is 

the only exception for road construction applicable to the upper tier acres within the 

CRAs;

Repair road-related resource damage;

Improve road traffic safety; or

The Regional Forester determines a road is needed for the construction, reconstruction, 

or maintenance of water conveyance structures operated pursuant to a pre-existing 

water court decree.

The exceptions in alternative 2 that would allow temporary roads to be constructed or 

reconstructed in CRAs are:

For public health and safety;

When the Regional Forester determines a temporary road is needed to facilitate treecutting, sale or removal to reduce the wildfire hazard to an at-risk community or 

municipal water supply system within the first one-half mile of a community protection 

zone;

When the Regional Forester determines a temporary road is needed to facilitate tree-
Rulemaking for Colorado Roadless Areas DEIS

16—Summary

cutting to maintain or restore the characteristics of ecosystem composition, structure and 

processes within the first one-half mile of the community protection zone;

For exploration or development of an existing oil and gas lease that otherwise does not 

prohibit road construction or reconstruction; or

For coal exploration and coal-related activities in the 20,000 acre North Fork coal mining 

area. 

Roads constructed in CRAs under all circumstances would be closed to public motorized use. 

Those roads may be used for authorized or administrative purposes, including emergencies and 

law enforcement purposes.

Alternative 2 generally prohibits the use of linear construction zones within CRAs. Exceptions 

to the prohibitions are when the Regional Forester determines motorized access without a linear 

construction zone is not technically feasible; that within a native cutthroat trout catchment or 

identified recovery watershed, a linear construction zone would not diminish, over the longterm, conditions in the water influence zone and in the native cutthroat habitat; a linear 

construction zone is consistent with the applicable land management plan direction; and one of 

the following exceptions applies: 

The construction, reconstruction, or maintenance of water conveyance structures 

operated pursuant to a pre-existing water court decree

The construction, reconstruction, or maintenance of existing or future authorized 

electrical power lines or telecommunication lines, if there is no opportunity for the lines 

to be implemented outside a CRA without causing substantially greater environmental 

damage. 

Where the Regional Forester determines a linear construction zone is needed to allow for 

the construction or reconstruction of a pipeline associated with an oil and gas lease that 

allows surface use within a CRA or the construction or reconstruction of a pipeline 

needed to connect to existing infrastructure within a CRA from outside a CRA where 

such a connection would cause substantially less environmental damage than alternative 

routes. The construction of pipelines for the purposes of transporting oil or natural gas 

through a CRA where the source(s) and destination(s) of the pipeline are located 

exclusively outside of a CRA shall not be authorized.

Alternative 3: Forest Plans 

Alternative 3 does not establish a state-specific roadless rule for Colorado and all lands would 

be managed according to direction in the forest plans for the eight national forests in Colorado. 

This alternative serves as the required baseline (per regulations at 40 CFR 1502.14) for 

comparison of alternatives. This alternative displays roadless areas in each forest plan or its 

associated records of decision which currently coincide with the 2001 Roadless Rule IRAs as 

described in alternative 1. As with alternative 1, the roadless areas under alternative 3 cover 

4.24 million acres. 

Forest plan direction that applies to the management of all lands within the IRAs and the CRAs 

includes forest plan goals (desired conditions), objectives, forest-wide standards and guidelines, 

management area standards and guidelines, and descriptions of suitable uses. In each forest 

plan, roadless areas overlap a number of different land management allocations.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Summary—17

Forest plans may be updated through an amendment or revision process to reflect changed 

conditions or specific public or management needs. The revision process includes a review and 

update of the roadless area inventory of potential wilderness areas for evaluation as 

recommended wilderness. In addition, project-level amendments to forest plans may be made 

to make a specific project consistent with the forest plan. Subsequent forest plan amendments 

and revisions may result in changes to roadless area boundaries or management direction. In 

the past few years, the trend has been to allocate more roadless areas to management 

prescriptions that conserve roadless area characteristics.

Alternative 3 follows forest plan direction regarding road construction and reconstruction and 

applicable Forest Service directives and regulations. The directives and regulations discourage 

construction of new permanent roads and require responsible officials to minimize the miles of 

permanent roads to those determined to be necessary. Furthermore, the directives encourage 

use of temporary roads when needed for single-use projects and authorizations. 

Alternative 3 differs from the other three alternatives in that it does not include a general 

prohibition on road construction or reconstruction in the roadless areas. Road construction in 

these roadless areas is prohibited or limited only where there is specific forest plan direction. 

Forest plan direction for road construction and reconstruction generally falls into one of four 

categories: 

Road construction is prohibited except where needed for reserved and outstanding 

rights or other exemptions mandated by law, regulation, or policy 

Road construction is generally restricted based on a desired condition or a guideline; 

not a mandatory restriction 

Road construction is limited under certain circumstances, such as those related to the 

purpose for the road, road density standards, or protection of natural resources

Road construction is allowed for any multiple-use management need, where consistent 

with law, regulation, or policy.

Appendix B of the EIS contains more details about road construction and tree-cutting 

permissions and prohibitions under forest plan direction for each national forest. A map of 

Alternative 3 in the EIS map packet shows how forest plan direction applies to each IRA. 

Further details on how forest plan direction applies to the IRAs are contained in the EIS record. 

Under alternative 3, there is no general prohibition on tree-cutting, sale, or removal within the 

IRAs. Tree-cutting, sale, or removal would be allowed in IRAs anywhere those activities are not 

specifically prohibited or limited by forest-wide or management area direction in the applicable 

forest plan. 

Like road construction and reconstruction, forest plan direction for tree-cutting, sale or removal 

generally falls into one of four categories: 

Tree-cutting, sale, or removal is prohibited except where needed for reserved and 

outstanding rights, or for other exemptions mandated by law, regulation, or policy

Tree-cutting, sale, or removal is generally restricted based on desired conditions or 

guidelines; non-mandatory direction

Tree-cutting, sale, or removal is limited to certain circumstances, such as those related 
Rulemaking for Colorado Roadless Areas DEIS

18—Summary

to the purpose of the activity or protection of natural resources

Tree-cutting, sale, or removal is allowed as needed to meet multiple-use management 

purposes. 

Although management direction in the forest plans regarding tree-cutting differs by national 

forest, some direction is common among plans. Common to all forest plans, tree-cutting for 

non-timber purposes such as hazardous fuel reduction or wildlife habitat improvement may 

occur on NFS lands that are considered unsuitable for timber production. Also common to all 

forest plans, tree-cutting for timber production purposes is limited to NFS land identified as 

suitable for timber production. 

Forest Service planning regulations allow forest plans to be amended or revised such that the 

permissions or prohibitions on road construction or tree-cutting are subject to change over time. 

These changes in forest plan direction may occur as long-term programmatic amendments or 

shorter-term project-specific amendments, or as forest plan revisions. 

Alternative 4: Colorado Roadless Rule with Public Proposed Upper 

Tier Acres

Alternative 4 has the same general prohibitions on tree-cutting, sale or removal, road 

construction and reconstruction, and LCZs within CRAs, while permitting those activities 

under the same exceptions as alternative 2. Identical to alternative 2, substantially altered acres 

within the IRAs have been removed from the CRA inventory and would be managed following 

forest plan direction, and 409,500 roadless acres have been added to the inventory.

The only difference between alternative 4 and alternative 2 is that alternative 4 designates 

2,614,200 acres as CRA upper tier acres.7 Under this alternative, roads would be allowed on a 

portion of the CRA upper tier acres that contain existing oil and gas leases. 

Alternatives Considered but Eliminated from Detailed Study

Federal agencies are required by the National Environmental Policy Act (NEPA) regulations to 

explore and evaluate all reasonable alternatives to a proposed action and to briefly discuss the 

reasons for eliminating any alternatives that were not developed in detail (40 CFR 1502.14). 

Three alternatives were submitted in response to information from scoping and comments on 

the DEIS and were considered and eliminated from detailed study. Below is a description of 

each of the three alternatives and the reasons why the alternative was eliminated from detailed 

study:

An alternative that provides the roadless area conservation provisions from alternative 

1, together with the CRA boundaries from alternative 2. 

This alternative is similar to alternative 1. The provisions of the 2001 Roadless Rule do allow for 

updating of the Inventoried Roadless Area maps8. This alternative is within the range of the 

 

7 Further details on the CRA upper tier acres in Alternative 4 are found in Appendix C and Map 6 in the map 

packet.

8

In §294.11 Definitions for Inventoried Roadless Area is: “Areas identified in a set of inventoried roadless area 

maps, contained in Forest Service Roadless Area Conservation, Final Environmental Impact Statement, Volume 2, 

dated November 2000, which are held at the National headquarters office of the Forest Service, or any subsequent 

update or revision of those maps.”
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Summary—19

alternatives and could be selected as alternative 1 modified because it falls within the range of 

the alternatives analyzed in this EIS and to eliminate redundancy in the analysis.

An alternative that allows for more commercial use such as increased timber harvesting. 

Alternative 3 allows for increased levels of commercial use. Another alternative that allows for 

increased levels of commercial use compared to alternative 2, but less than alternative 3, while 

meeting the purpose and need of protecting roadless area characteristics would not result in 

differences that can be meaningfully analyzed.

An alternative that offers reduced road densities, creation of new roadless areas, and 

more protective management than any of the alternatives analyzed in the DEIS. 

Reducing road densities is outside the scope of this rule-making and decision framework and is 

best decided during travel management analysis. In addition, alternatives 2 and 4 allow for 

additions to CRAs, if needed. Alternatives 2 and 4, in response to public comments, have 

identified CRAs or portions of CRAs that are proposed to be managed as upper tier acres. On 

upper tier acres, more limited exceptions to the tree-cutting and road construction prohibitions 

are allowed. Additional protections would not meet the purpose and need to accommodate 

state-specific situations and concerns.

ENVIRONMENTAL CONSEQUENCES

This section compares the estimated environmental consequences of each alternative in 

summary form (Table 2). These environmental consequences are described in detail in chapter 3 

of the full EIS, and are summarized at the end of chapter 2 of the full EIS. The comparison table 

focuses on the key differences among the alternatives and the most likely consequences. 

Comparisons are based on the purpose and need for the proposed Colorado Roadless Rule as 

well as the issues associated with this proposed action, as previously described. Because the 

proposed rulemaking and its alternatives are broad, programmatic, and do not involve any 

proposed site-specific actions, the consequences are appropriately broad and qualitative rather 

than quantitative.
Rulemaking for Colorado Roadless Areas DEIS

20—Summary

Table 2. Comparison of alternatives by environmental consequences (refer to chapter 3 for details)9

Issue or Affected Resource

Alternative 1

Provisions of the 2001 

Roadless Rule

Alternative 2

Proposed Action

Colorado Roadless Rule

Alternative 3

No Action

Forest Plans

Alternative 4 

Colorado Roadless Rule

Fire and Fuels 1,800 acres in the analysis 

area have projected treecutting activities to reduce 

hazardous fuels each year 

(900 acres within IRAs).

Least flexibility to conduct 

hazardous fuel reduction and 

reduce fire risk to 

communities and municipal 

water supply systems.

5,900 acres in the analysis 

area have projected treecutting activities to reduce 

hazardous fuels each year 

(5,300 acres within CRAs).

Medium flexibility to conduct 

hazardous fuel reduction and 

reduce fire risk to 

communities and municipal 

water supply systems.

Unable to conduct hazardous 

fuels reduction on 12% of 0.5 

mile CPZ and 13% of 1.5 mile 

CPZ due to upper tier acre 

prohibitions.

13,100 acres in the analysis 

area have projected treecutting activities to reduce 

hazardous fuels each year.

Greatest flexibility to conduct 

hazardous fuel reduction and 

reduce fire risk to 

communities and municipal 

water supply systems.

2,200 acres in the analysis 

area have projected treecutting activities to reduce 

hazardous fuels each year 

(1,600 acres within CRAs).

Within the CRAs that are not 

upper tier acres, the flexibility 

to conduct hazardous fuel

reduction and reduce fire risk 

to communities and municipal 

water supply systems is 

identical to alternative 2.

Unable to conduct hazardous 

fuels reduction on 48% of 0.5 

mile CPZ and 52% of 1.5 mile 

CPZ due to upper tier acre 

prohibitions.

Ecosystem Composition, 

Structure and Processes

500 acres per year in the 

analysis area have projected 

tree-cutting activities (300 

acres within IRAs) for forest 

health purposes.

Fewest opportunities to 

maintain and restore 

ecosystem characteristics, 

including resilience to insect 

and disease outbreaks and 

climate induced stressors.

1,000 acres per year in the 

analysis area have projected 

tree-cutting activities for forest 

health purpose (400 acres

within CRAs).

More opportunities than 

alternatives 1 and 4, but fewer 

opportunities than alternative 

3 to maintain and restore 

ecosystem characteristics, 

including resilience to insect 

and disease outbreaks and 

climate induced stressors.

Unable to treat upper tier

acres.

3,500 acres per year within 

the analysis area have 

projected tree-cutting 

activities for forest health

purposes.

Greatest opportunities to

maintain and restore 

ecosystem characteristics, 

including resilience to insect 

and disease outbreaks and 

climate induced stressors.

800 acres per year in the 

analysis area have projected 

tree-cutting activities for forest 

health purposes (200 acres

within CRAs).

More opportunities to 

maintain and restore 

ecosystem characteristics, 

including resilience to insect 

and disease outbreaks and 

climate induced stressors

than alternative 1 but less 

than alternative 3 and 

alternative 2 due to upper tier

acres.

 

9

The analysis area is all acres within either the IRAs or the CRAs, or acres that are common between the two and are within both the IRAs and the CRAs. This 

totals 4,653,100 acres. Table 3-1 explains this in more detail. 
Summary of the Environmental Impact Statement

Summary—21

Issue or Affected Resource

Alternative 1

Provisions of the 2001 

Roadless Rule

Alternative 2

Proposed Action

Colorado Roadless Rule

Alternative 3

No Action

Forest Plans

Alternative 4 

Colorado Roadless Rule

Aquatic Species and Habitat Least risk for adverse impacts 

on aquatic species.

Site specific design criteria 

and mitigation measures are 

expected to minimize risk.

More risk than alternatives 1 

and 4, less than alternative 3 

for adverse impacts on 

aquatic species. 

Site specific design criteria 

and mitigation measures are 

expected to minimize risk.

Greatest risk of adverse 

impacts on aquatic species.

Site specific design criteria 

and mitigation measures are 

expected to minimize risk.

Less risk for adverse impacts 

on aquatic species than 

alternatives 2 and 3; greater 

risk than alternative 1. 

Site specific design criteria 

and mitigation measures are 

expected to minimize risk.

Threatened Endangered or 

Sensitive Plants

No adverse impacts to 

threatened or endangered 

plants because no road 

construction or tree-cutting, 

sale or removal is projected to 

occur where threatened or 

endangered plants exist.

Least risk to adverse impacts 

to sensitive plants

Site specific design criteria 

and mitigation measures are 

expected to minimize risk.

No adverse impacts to 

threatened or endangered 

plants because no road 

construction or tree-cutting, 

sale or removal is projected to 

occur where threatened or 

endangered plants exist.

More risk of adverse impacts 

to sensitive plants than 

alternatives 1 or 4; less than 

alternative 3.

Site specific design criteria 

and mitigation measures are 

expected to minimize risk.

No adverse impacts to 

threatened or endangered 

plants because no road 

construction or tree-cutting, 

sale or removal is projected to 

occur where threatened or 

endangered plants exist.

Greatest risk of adverse 

impacts to sensitive plants.

Site specific design criteria 

and mitigation measures are 

expected to minimize risk.

No adverse impacts to 

threatened or endangered 

plants because no road 

construction or tree-cutting, 

sale or removal is projected to 

occur where threatened or 

endangered plants exist.

More risk of adverse impacts 

to sensitive plants than 

alternative 1; less than 

alternatives 2 or 3.

Site specific design criteria 

and mitigation measures are 

expected to minimize risk.
Rulemaking for Colorado Roadless Areas DEIS

22—Summary

Issue or Affected Resource

Alternative 1

Provisions of the 2001 

Roadless Rule

Alternative 2

Proposed Action

Colorado Roadless Rule

Alternative 3

No Action

Forest Plans

Alternative 4 

Colorado Roadless Rule

Economics Average annual jobs 

associated with –

Oil/gas drilling = 489 jobs

Oil/gas production = 360 jobs

Coal production = 1,033 jobs

Average annual labor income

associated with –

Oil/gas drilling = $25.3 million

Oil/gas production =$ 24.6 

million

Coal production = $75.2 

million

Average annual value of 

production associated w/ –

Oil/gas drilling = $156.9 

million

Oil/gas production = $269.4 

million

Coal production = $305.9 

million 

Average annual jobs 

associated with –

Oil/gas drilling = 489 jobs

Oil/gas production = 360 jobs

Coal production = 1,912 jobs

Average annual labor income

associated with –

Oil/gas drilling = $25.3 million

Oil/gas production =$ 24.6 

million

Coal production = $139.1 

million

Average annual value of 

production associated w/ –

Oil/gas drilling = $156.9 

million

Oil/gas production = $269.4 

million

Coal production = $566.2 

million 

Average annual jobs 

associated with –

Oil/gas drilling = 553 jobs

Oil/gas production = 406 jobs

Coal production = 1,912 jobs

Average annual labor income

associated with –

Oil/gas drilling = $28.6 million

Oil/gas production =$ 27.8 

million

Coal production = $139.1 

million

Average annual value of 

production associated w/ –

Oil/gas drilling = $177.6 

million

Oil/gas production = $303.9 

million

Coal production = $566.2 

million

Average annual jobs 

associated with –

Oil/gas drilling = 489 jobs

Oil/gas production = 360 jobs

Coal production = 1,912 jobs

Average annual labor income

associated with –

Oil/gas drilling = $25.3 million

Oil/gas production =$ 24.6 

million

Coal production = $139.1 

million

Average annual value of 

production associated w/ –

Oil/gas drilling = $156.9 

million

Oil/gas production = $269.4 

million

Coal production = $566.2 

million

No difference expected between alternatives at the State level in recreation, tourism, or wood products due to the lack of project 

specific data needed for analysis, and the ability to substitute sites and resources at the larger, State-wide scale.

Soils No major difference among alternatives related to the risk of soil impacts. Alternatives 1 and 4 would have the least risk of 

adverse effects, and alternative 2 would have a slightly higher risk, followed by alternative 3. However, these differences are 

insignificant because they would be small in magnitude and spread over a wide geographic area. Most of the potential effects 

would be mitigated by site-specific mitigation measures. The risk of post-fire soil erosion may be higher under alternative 1 and 

lowest under alternative 3 as a result of projected levels of fuel treatments. 
Summary of the Environmental Impact Statement

Summary—23

Issue or Affected Resource

Alternative 1

Provisions of the 2001 

Roadless Rule

Alternative 2

Proposed Action

Colorado Roadless Rule

Alternative 3

No Action

Forest Plans

Alternative 4 

Colorado Roadless Rule

Developed Ski Areas Least opportunities for ski 

area development and 

expansion.

6,600 acres within the IRA 

boundaries and under permit 

prior to the effective date of 

rulemaking would allow for 

road construction and treecutting, sale or removal.

Forest Plan allocations for ski 

areas outside of existing 

permit areas (1,700 acres) 

would prohibit road 

construction.

Greater opportunity for ski 

area development and 

expansion.

Forest Plan allocations for ski 

areas outside of existing 

permit areas (1,700 acres) 

would allow road construction 

and tree-cutting more than 

alternative 1.

Forest plans can be amended 

or revised to expand ski area

allocations beyond the current 

allocation.

Same as alternative 2.

Scenic Quality Least risk to scenic

resources.

More risk to scenic resources

than alternatives 1 and 4.

Upper tier acres same as 

alternative 1.

Greatest risk to scenic

resources.

Same as alternative 2 within 

CRA boundaries that are not 

upper tier; upper tier areas 

same as alternative 1.

Social Values No disproportionate negative 

impact on minority or lowincome groups as defined in 

the Bureau of the Census' 

Current Population Reports.

Preference towards 

preservation of nondevelopment social values.

No disproportionate negative 

impact on minority or lowincome groups as defined in 

the Bureau of the Census' 

Current Population Reports.

Slightly less than alternative 1 

preference towards nondevelopment social values.

No disproportionate negative 

impact on minority or lowincome groups as defined in 

the Bureau of the Census' 

Current Population Reports.

Less preference towards nondevelopment social values

than alternatives 1, 2, and 4.

Same as alternative 2.

Terrestrial Species and 

Habitat

Least risk to terrestrial

species and habitat.

Site specific design criteria 

and mitigation measures are 

expected to minimize risk.

More risk than alternative 1 

and 4 to terrestrial species 

and habitat.

Tree-cutting to improve 

habitat for TEPS species 

prohibited in upper tier acres.

Site specific design criteria 

and mitigation measures are 

expected to minimize risk.

Greatest risk to terrestrial

species and habitat.

Site specific design criteria 

and mitigation measures are 

expected to minimize risk.

More risk than alternative 1 to 

terrestrial species and habitat.

Tree-cutting to improve 

habitat for TEPS species 

prohibited in upper tier acres.

Site specific design criteria 

and mitigation measures are 

expected to minimize risk.
Rulemaking for Colorado Roadless Areas DEIS

24—Summary

Issue or Affected Resource

Alternative 1

Provisions of the 2001 

Roadless Rule

Alternative 2

Proposed Action

Colorado Roadless Rule

Alternative 3

No Action

Forest Plans

Alternative 4 

Colorado Roadless Rule

Recreation Settings Likely to retain the greatest 

proportion of acreage in 

primitive or semi-primitive

settings

The substantially altered

portion of the IRA inventory 

would continue to be 

inconsistent with primitive or 

semi-primitive settings.

The newly identified roadless 

acres (409,500 acres) where 

road construction and treecutting, sale or removal is 

projected to occur that are not 

within the IRAs could shift to 

less primitive settings. 

Likely to retain a high 

proportion of acreage in 

primitive or semi-primitive

settings. However, some 

areas where road 

construction and tree-cutting, 

sale or removal is projected to 

occur could shift to less 

primitive settings.

The exclusion of the 

substantially altered acreage 

and inclusion of new roadless 

acres would create a more 

homogeneous primitive or 

semi-primitive recreation 

setting.

Least likely to retain a high 

proportion of acreage in 

primitive or semi-primitive

settings; especially where 

road construction and treecutting, sale or removal is 

projected to occur.

Same as alternative 2.

Lands-Special Use 

Authorizations

Special use authorizations 

issued prior to the effective 

date of rulemaking would be 

unaffected.

Future special use 

authorizations in IRAs would 

generally prohibit road 

construction.

There would be no prohibition 

on the use of LCZs for future 

electrical power lines or 

telecommunication lines, 

water conveyance structures 

and oil and gas pipelines from 

sources outside of IRAs.

Special use authorizations 

issued prior to the effective 

date of rulemaking would be 

unaffected.

Future special use 

authorizations in CRAs would 

generally prohibit road 

construction.

Limited exceptions for the use

of LCZ for future electrical 

power lines or 

telecommunication lines, 

water conveyance structures 

and oil and gas pipelines from 

sources outside of CRAs.

Current and future special use 

authorizations would 

generally allow for road 

construction; except where 

prohibited under forest plans.

There would be no prohibition 

on the use of LCZs for future 

electrical power lines or 

telecommunication lines, 

water conveyance structures 

or oil and gas pipelines.

Same as alternative 2.
Summary of the Environmental Impact Statement

Summary—25

Issue or Affected Resource

Alternative 1

Provisions of the 2001 

Roadless Rule

Alternative 2

Proposed Action

Colorado Roadless Rule

Alternative 3

No Action

Forest Plans

Alternative 4 

Colorado Roadless Rule

Invasive Plants Least risk of spread of 

invasive plants because this 

alternative has the least 

projections of road 

construction or tree-cutting, 

sale or removal.

Site specific design criteria 

and mitigation measures are 

expected to minimize risk.

Slightly higher risk than 

alternatives 1 and 4 for the 

spread of invasive plants 

because this alternative has a 

higher projection of road 

construction or tree-cutting, 

sale or removal.

Site specific design criteria 

and mitigation measures are 

expected to minimize risk.

Greatest risk of the spread of 

invasive plants because this 

alternative has the highest 

projections for road 

construction or tree-cutting, 

sale or removal.

Site specific design criteria 

and mitigation measures are 

expected to minimize risk.

Slightly higher risk than 

alternative 1 but less than 

alternative 2 for the spread of 

invasive plants because this 

alternative has a higher 

projection of road construction 

or tree-cutting, sale or 

removal.

Site specific design criteria 

and mitigation measures are 

expected to minimize risk.

Cultural Resources Least risk of damage to 

cultural resources because 

this alternative has the least 

projections for tree-cutting, 

sale or removal.

Site specific design criteria 

and mitigation measures are 

expected to minimize risk.

Slightly higher risk of damage 

to cultural resources than 

alternative 1 because this 

alternative has a high 

projection of tree-cutting, sale 

or removal and road 

construction.

Site specific design criteria 

and mitigation measures are 

expected to minimize risk.

Highest risk of damage to 

cultural resources because 

this alternative has the 

highest projection of treecutting, sale or removal and 

road construction.

Site specific design criteria 

and mitigation measures are 

expected to minimize risk.

Less risk than alternative 2

due to more acres in the 

upper tier.

Site specific design criteria 

and mitigation measures are 

expected to minimize risk.

Roadless Area 

Characteristics

Minimal effect to roadless 

area characteristics because 

there is little projected activity 

to occur.

No consideration or regulatory 

protection of roadless area 

characteristics on 409,500 

acres outside of IRA 

boundaries.

Minimal effect to roadless 

area characteristics because 

there is little projected activity

to occur.

Consideration and protection 

of roadless area 

characteristics on 409,500 

acres within CRA boundaries.

More effect to roadless area 

characteristics because there 

is an increase in projected 

activities to occur compared 

to the other alternatives. 

Some risk of adverse effects 

to roadless area 

characteristics because there 

are no regulatory prohibitions 

on road construction, use of 

linear construction zones or 

tree-cutting, sale or removal

on any of the analysis area. 

Minimal effect to roadless 

area characteristics because 

there is little projected activity 

to occur.

Consideration and protection 

of roadless area 

characteristics on 409,500 

acres within CRA boundaries.

Air Resources Differences in effects on air quality do not substantially differ between the alternatives. Atmospheric emissions within the analysis 

area are not expected to increase to a level that would be likely to exceed State or federal air quality standards.
Rulemaking for Colorado Roadless Areas DEIS

26—Summary

Issue or Affected Resource

Alternative 1

Provisions of the 2001 

Roadless Rule

Alternative 2

Proposed Action

Colorado Roadless Rule

Alternative 3

No Action

Forest Plans

Alternative 4 

Colorado Roadless Rule

Administratively and 

Congressionally Designated 

Areas

There are no differences between the alternatives to administratively or congressionally designated areas because none of the 

alternatives project tree-cutting, sale or removal or road construction in administratively designated areas and tree-cutting, sale or 

removal or road construction is prohibited in congressionally designated areas.

Wilderness Alternatives 1 and 2 have a low likelihood of affecting 

wilderness characteristics because tree-cutting, sale or 

removal and road construction are prohibited in Wilderness 

areas and projected activities within roadless areas are not 

expected to occur adjacent to Wilderness area boundaries.

Higher risk of adverse effect 

to wilderness areas because 

of the high projections for 

tree-cutting, sale or removal 

and road construction and a 

higher likelihood that these 

activities could occur adjacent 

to Wilderness boundaries.

Same as alternatives 1 and 2.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 1. Purpose and Need for Action—27

CHAPTER 1. PURPOSE OF AND NEED FOR ACTION 

The Forest Service has prepared this environmental impact statement (EIS) in compliance with 

the National Environmental Policy Act (NEPA) and other relevant federal laws and regulations. 

This EIS discloses the potential environmental consequences that may result from the proposed 

action and alternatives. 

DOCUMENT STRUCTURE

This EIS document is organized into five chapters followed by appendices and related 

documentation: 

Chapter 1 – Purpose of and Need for Action. Chapter 1 presents the background 

information about the proposed action, the purpose of and need for the proposed action, 

and a summary of the proposed action. This chapter also summarizes how the Forest 

Service informed and involved the public, and presents the issues related to the 

proposed action. 

Chapter 2 – Alternatives, Including the Proposed Action. Chapter 2 provides a detailed 

description of the proposed rulemaking action and alternatives to the proposal, 

including the no-action alternative. This chapter ends with two summary tables: one 

displays the features of alternatives considered in detail, and the other shows the 

environmental consequences associated with each alternative, based on the detailed 

descriptions in chapter 3.

Chapter 3 – Affected Environment and Environmental Consequences. Chapter 3 

describes the resources that may be affected by the proposed action or alternatives, 

followed by the potential environmental consequences that could result from each 

alternative. It is organized by biological, physical, social, and economic topics.

Chapter 4 – Preparers and EIS Distribution. Chapter 4 provides a list of preparers and a 

list of agencies, organizations, and persons to whom copies of the statement are sent.

Chapter 5 - References Cited. References Cited contains an alphabetized list of 

references used in the preparation of this EIS. 

Appendices. The appendices provide additional detailed information to support the 

analyses presented in this EIS. 

Index. The index provides page numbers for finding key topics in the EIS.

Supporting documents for this EIS may be found in the EIS record, located at the Forest 

Service‘s Rocky Mountain Regional Office, 740 Simms Street, Lakewood, CO. Some supporting 

documents, including Colorado Roadless Area profiles and national forest maps showing 

roadless area locations, are available on the Web at www.roadless.fs.fed.us/colorado.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

28—Chapter 1. Purpose and Need for Action

BACKGROUND

The Forest Service administers approximately 14,520,000 acres of publicly owned lands in 

Colorado, which are distributed among eight national forests and two national grasslands. 

These national forests and grasslands are characterized by a diverse array of landscapes, 

ecosystems, natural resources, and land use activities. Management of each national forest and 

grassland is directed by a Forest plan, along with numerous land management laws, 

regulations, policies, and agency directives. Laws and regulations take precedence over 

management direction in the forest plans, if conflicts in management direction exist. 

In January 2001, a Roadless Area Conservation Rule (2001 Roadless Rule) was adopted into 

regulations at 36 CFR §294. The 2001 Roadless Rule identified approximately 4.43 million acres, 

or about 31 percent, of the National Forest System (NFS) lands in Colorado, as ―inventoried 

roadless areas‖ (IRAs), based on the existing inventories of roadless areas (Maps are available 

on the Web at www.roadless.fs.fed.us/colorado). At the time the IRAs were inventoried (for 

dates of the inventories, see Table 2-3) they were generally undeveloped areas and typically 

5,000 acres or greater in size, but could be smaller if adjacent to congressionally designated

wilderness. As shown on the table, the inventories were conducted in 1979 on four forests (at 

present, over 30 years ago). The other four forest inventories were finalized in 1996, 1997, 1998 

and 2002, when those forests completed their forest plan revision and closer to the 

promulgation of the 2001 Rule. The 2001 Roadless Rule applied to national forests nationwide. 

It provided specific protections for 58.5 million acres10 of IRAs (about 30 percent of NFS lands in 

the country), by prohibiting road construction and reconstruction and timber harvest in IRAs 

except under certain exceptions. The intent of the 2001 Roadless Rule was ―to provide lasting 

protection for IRAs within the context of multiple-use management‖ (Fed.Reg.Vol.66, No.9, 

3243-3273). 

Since its promulgation, the 2001 Roadless Rule has continued to be the subject of litigation. In 

response to a court ruling the State Petitions Rule was promulgated in May, 2005; wherein 

governors had until November 13, 2006 to petition the Secretary of Agriculture to propose 

changes to management requirements for IRAs within their states. Ongoing uncertainty about 

the future of the 2001 Roadless Rule was a key factor that influenced Colorado Governor Bill 

Owens in 2005 to initiate an effort to develop a state-specific petition to conserve roadless areas 

in Colorado. To this end, in May 2005, Colorado enacted Senate Bill 05-243 (C.R.S. § 36-7-302), 

which directed formation of a 13-person bipartisan taskforce to make recommendations to the 

Governor regarding the appropriate management of roadless areas on the national forests in 

Colorado. 

The State‘s roadless taskforce conducted a comprehensive public participation process, which 

included holding nine public meetings; one in the State Capitol and others in eight locations 

across Colorado. The taskforce received and evaluated more than 40,000 public comments for 

development of a petition to the Secretary of Agriculture for rulemaking on management of 

IRAs in Colorado.

On September 20, 2006 the United States District Court for the Northern District of California 

set aside the 2005 State Petition Rule and reinstated the 2001 Roadless Rule. In November 2006, 

 

10 Approximately 9.3 million acres of roadless areas in Alaska’s Tongass National Forest were exempted from the 

2001 Roadless Rule. Therefore, the 2001 Roadless Rule applied to 49.2 million acres of NFS land. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 1. Purpose and Need for Action—29

Colorado Governor Bill Owens used the taskforce‘s recommendations as the basis for 

petitioning the Secretary of Agriculture to undertake state-specific roadless rulemaking for 

Colorado. The State‘s petition was considered for rulemaking by the Secretary of Agriculture in 

accordance with the Administrative Procedures Act, section 553(e) and the Department of 

Agriculture‘s (Department) rulemaking procedures at 7 CFR §1.28. 

After Governor Bill Owens submitted the State‘s petition to the Department, Bill Ritter, Jr. was 

elected Governor of Colorado. In April 2007, Governor Ritter resubmitted the petition with 

minor modifications. The State‘s petition requested the rulemaking process: (1) update roadless 

area boundaries to include additional roadless areas; (2) exclude congressionally-designated 

lands and private lands; and (3) exclude roadless acres that have been substantially altered. 

In June 2007, the State and the Forest Service presented this petition to the Department‘s 

Roadless Area Conservation National Advisory Committee (RACNAC). Based on the advisory 

committee‘s review and report (USDA RACNAC 2007a), the Secretary of Agriculture accepted 

the State‘s petition in August 2007. The Secretary of Agriculture directed the Forest Service to 

work in cooperation with the State of Colorado to initiate rulemaking . The Forest Service 

published a proposed rule and Draft Environmental Impact Statement (DEIS) to establish 

direction for conserving roadless areas on NFS land in Colorado on July 25, 2008 (73 FR 43544). 

In response to the proposed rule and DEIS, the United States Department of Agriculture 

(Department), State, and Forest Service repeatedly heard public comment requesting a 

reduction in the scope of the proposed exceptions for tree-cutting, sale or removal and road 

construction/reconstruction. Based on the public comments, the State asked the USDA to 

postpone further rulemaking efforts until the State considered revision of its petition.

The State revised the proposed rule, posted the rule on the internet, and held a comment period 

from August 3 to October 3, 2009. The State received approximately 22,000 comments, most 

being form letters. The result was a revised petition submitted to the Secretary of Agriculture on 

April 6, 2010. Based on the April 6, 2010 petition, the State and the Forest Service developed 

regulatory language for a proposed Colorado Roadless Rule (the proposed Rule) that would 

govern management of roadless areas on NFS lands in Colorado. Because of the changes in the 

boundaries of the Colorado Roadless Areas (CRAs) and the number of changes in the proposed 

rule, the Secretary of Agriculture has initiated another public comment period on the revised 

proposed rule and this EIS. 

ROADLESS AREA CHARACTERISTICS

Nine roadless area characteristics were identified in the 2001 Roadless Rule preamble (66 FR 

3245). They are resources or features that are often present in or characterize roadless areas. 

These nine roadless area characteristics are described for Colorado as follows: 

High quality or undisturbed soil, water, or air. These three key resources are the 

foundation upon which other resource values and outputs depend. Healthy watersheds 

provide clean water for domestic, agricultural, and industrial uses; help maintain 

abundant and healthy fish and wildlife populations; and are the basis for many forms of 

outdoor recreation.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

30—Chapter 1. Purpose and Need for Action

Sources of public drinking water. National forests contain watersheds that are 

important sources of public drinking water. Careful management of these watersheds is 

crucial in maintaining the flow of clean water to a growing population.

Diversity of plant and animal communities. Roadless areas are more likely than roaded 

areas to support greater ecosystem health, including a diversity of native and desired 

non-native plant and animal communities due to the absence of disturbances caused by 

roads and accompanying activities. Roadless areas also may conserve native biodiversity

by serving as a bulwark against the spread of nonnative invasive species.

Habitat for threatened, endangered, proposed, candidate, and sensitive species, and 

for those species dependent on large, undisturbed areas of land. Roadless areas 

function as biological strongholds and refuges for many species, including terrestrial

and aquatic plant and animal species. Many of the nation‘s species currently listed as

threatened, endangered, or proposed for listing under the Endangered Species Act, and 

those listed by the Forest Service as sensitive, have habitat within roadless areas.

Primitive, semi-primitive non-motorized, and semi-primitive motorized classes of 

dispersed recreation. These recreation classes of dispersed recreation opportunities 

often provide outstanding opportunities for hiking, camping, wildlife viewing, hunting, 

fishing, and cross-country skiing. Although areas with these recreation opportunities 

may have many wilderness-like attributes, they often allow the use of mountain bikes 

and other mechanized and motorized means of travel, in contrast to designated 

wilderness areas. Primitive, semi-primitive non-motorized, and semi-primitive 

motorized areas can also take pressure off heavily used wilderness areas by providing 

additional solitude and quiet, and dispersed recreation opportunities.

Reference landscapes. The body of knowledge about the effects of management 

activities over long periods of time and on large landscapes is very limited. Reference 

landscapes can provide comparison areas for evaluation and monitoring. These areas 

provide a natural setting that may be useful as a comparison to study the effects of more 

intensely managed areas.

Natural-appearing landscapes with high scenic quality. High quality scenery, 

especially scenery with natural-appearing landscapes, is a primary reason that people 

choose to recreate. Quality scenery contributes directly to real estate values in 

neighboring communities and residential areas.

Traditional cultural properties and sacred sites. Roadless areas may contain traditional 

cultural properties and sacred sites. Traditional cultural properties are places, sites, 

structures, districts, or objects that are historically significant in the beliefs, customs, and 

practices of a community. Sacred sites are places that are determined sacred by virtue of 

their established religious significance to or ceremonial use by a Native American

religion. Federal agencies are to accommodate access to and ceremonial use of Native 

American sacred sites by Native American religious practitioners, and are to avoid 

adversely affecting traditional cultural properties and sacred sites when practicable. 

Other locally identified unique characteristics. Roadless areas may offer unique 

characteristics that are not covered by the other categories. Examples include 

uncommon geological formations, which are valued for their scientific and scenic

qualities, or unique wetland complexes. Unique social, cultural, or historical 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 1. Purpose and Need for Action—31

characteristics may also be dependent on the roadless character of the landscape. 

Examples include places for local events, areas prized for collection of non-timber forest 

products, exceptional hunting and fishing opportunities.

CHANGES BETWEEN THE DEIS AND THE REVISED DEIS

Since the release of the initial DEIS in July 2008, court actions, changes to the State‘s petition, 

and updated inventories have led to revisions of the alternatives, language of the proposed 

Rule, and changes in the RDEIS. These changes are described below.

The No Action Alternative has changed from Alternative 1 to Alternative 3

In the DEIS, the Forest Service considered ―no action‖ to mean that the 2001 Roadless Rule 

would remain in effect for IRAs in Colorado. In August 2008, after the DEIS was released, the 

Wyoming District Court set aside and enjoined the 2001 Roadless Rule. Colorado is under the 

Wyoming Court‘s ruling, thus the consequences of taking no action has changed. In the revised 

DEIS the ―no action‖ means that IRAs in Colorado would be managed according to direction set 

forth in the applicable forest plan (alternative 3). 

Effective Date of Alternative 1

Because the 2001 Roadless Rule was set aside and enjoined, if this alternative is selected, it 

would become Colorado‘s state-specific roadless rule. Therefore the provisions would take 

effect when the Colorado‘s rule becomes effective and it would not revoke, suspend, or modify 

any permit, contract, or other legal instrument authorizing the occupancy and use of NFS land 

issued prior to the Colorado rule‘s effective date. 

Alternative 2 (Proposed Action)

Between the DEIS and the revised DEIS, the State of Colorado revised their petition for 

rulemaking. This has resulted in changes to the language of the proposed Rule.

Total area of roadless has increased. There is a net increase of approximately 155,000 

acres to be managed as CRAs under alternative 2. The increase resulted from work with 

the Colorado Division of Wildlife as well as public comments received on the DEIS. In 

2009, the Omnibus Public Lands Act was signed into law and enlarged the Indian Peaks 

Wilderness by 1,000 acres; thus removing 1,000 acres from the Indian Peaks Adjacent 

Area Roadless Area. 

This proposed Rule has identified Colorado Roadless upper tier and provides maps and 

management direction for these acres. This proposed Rule identifies ―Colorado Roadless 

Areas upper tier acres‖ which are specific portions of or entire CRAs. In the upper tier 

acres, tree-cutting, sale or removal is prohibited unless it is needed incidental to the 

implementation of a management activity not otherwise prohibited by the rule; or is 

needed and appropriate for personal or administrative use. Road construction or road 

reconstruction is prohibited in upper tier acres unless it is needed pursuant to reserved 

or outstanding rights or as provided for by statute or treaty. Alternative 2 identifies 

562,200 upper tier acres, and alternative 4 identifies 2,614,200 acres. 

Alternative 4 has been added. Alternative 4 has the same prohibitions and exceptions as 

alternative 2. The difference between alternative 2 and 4 is the number of upper tier
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

32—Chapter 1. Purpose and Need for Action

acres identified within the CRAs. This alternative proposes 2,614,200 acres as upper tier, 

based on areas recommended by the public. The Department specifically asks for public 

comment on these acres. 

The proposed rule restricts temporary roads for fuels treatment to within 1⁄2 mile from a 

community boundary and changes tree-cutting requirements. The proposed rule uses 

the term Community Protection Zone (CPZ) instead of Wildland Urban Interface (WUI). 

A CPZ is based on the definition of a WUI in the Healthy Forest Restoration Act 

(HFRA), but is specifically defined in this proposed rule as an area one-half mile from 

the boundary of an at-risk community or an area within one and one-half miles from the 

boundary of an at-risk community where any land has a sustained steep slope that 

creates the potential for wildfire behavior endangering the at-risk community; or has a 

geographic feature that aids in creating an effective fire break, such as a river or a ridge 

top; or where the trees are in condition class 3. 

Within the CPZ, tree-cutting, sale or removal is allowed to reduce the wildfire hazard to 

an at-risk community or municipal water supply system. Tree-cutting outside of the 

CPZ is allowed to reduce the wildfire threat to a municipal water supply system only. In 

both instances, projects would focus on small-diameter trees to create strategic fuel

breaks while retaining large trees to the maximum extent practicable as appropriate to 

the forest type. In the initial proposed rule, a temporary road could be constructed in the 

full area of the CPZ, a maximum of 1.5 miles from the community boundary. In this 

proposed rule, a temporary road can only be constructed within the first 1⁄2 mile of the 

CPZ to facilitate the projects. 

The proposed rule elevates two of the tree-cutting exceptions to a determination by the 

Regional Forester. The two exceptions are: tree-cutting to reduce the wildfire hazard to 

an at-risk community or municipal water supply system within a community protection 

zone, and tree-cutting outside the community protection zone where there is a 

significant risk that a wildland fire disturbance event could adversely affect a municipal 

water supply system or the maintenance of that system. The July 2008 proposed Rule 

did not elevate the determination for tree-cutting, sale, or removal to the Regional 

Forester for any exception.

Tree-cutting, sale or removal in Colorado Roadless Areas must maintain or improve, 

over the long-term, one or more roadless area characteristics. The July 2008 proposed 

Rule did not require that tree-cutting, sale, or removal maintain or improve roadless 

area characteristics except when the tree-cutting was for the management or 

improvement of wildlife or plant species habitat. This proposed Rule expands the 

requirements to maintain or improve roadless area characteristics for all but two of the 

tree-cutting exceptions. This finding is not required in these two exceptions: (1) where 

tree-cutting, sale or removal is incidental to the implementation of a management 

activity not otherwise prohibited; or (2) where tree-cutting is needed or appropriate for 

personal or administrative use.

Tree-cutting and road construction exceptions have been added for maintenance and 

restoration characteristics of ecosystem composition, structure and processes. 

Temporary road construction for this purpose is only allowed within 1⁄2 mile of at risk 

communities, and requires Regional Forester determination. In the upper tier, no treecutting or road construction for these purposes is allowed. Included in this exception is 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 1. Purpose and Need for Action—33

the ability to treat insect and disease outbreaks to maintain and restore characteristics of 

ecosystem composition, structure and processes. The specific exception for prevention 

and suppression of insect and disease outbreaks has been removed.

Linear Construction Zones (LCZs) and linear facilities have been defined and addressed.

The July 2008 proposed Rule did not address linear facilities or LCZs. A linear facility 

includes pipelines, electrical power lines, telecommunications lines, ditches and canals. 

An LCZ is a temporary linear area of surface disturbance over 50-inches wide that is 

used for motorized transport by vehicles or construction equipment to install a linear 

facility. It is not used as a motor vehicle route and is not engineered to road 

specifications. The proposed Rule generally prohibits the construction of LCZs. There 

are three exceptions to the prohibition requiring Regional Forester determination: 1) to 

allow for the construction, reconstruction, or maintenance of an authorized water 

conveyance structure which is operated pursuant to a pre-existing water court decree; 2) 

to allow for the construction, reconstruction, or maintenance of existing or future 

authorized electrical power lines or telecommunication lines only if there is no 

opportunity for the project to be implemented outside of a CRA without causing 

substantially greater environmental damage; and 3) to allow the construction or 

reconstruction of an oil and gas pipeline that originates outside a CRA and connects to 

infrastructure within a CRA and the Regional Forester determines such a connection 

would cause substantially less environmental damage than alternative routes. 

Road construction in support of water conveyance structures, including reservoirs, is 

limited. The July 2008 proposed Rule allowed for road construction for any existing or 

future authorized water conveyance structure. The proposed Rule limits road 

construction to only those water conveyance structures that have a pre-existing water 

court decree as of the effective date of the rule.

The area covered by the North Fork coal mining exception has been reduced. The North 

Fork coal mining area previously included approximately 9,000 acres of the Currant 

Creek CRA. Current Creek remains in the CRA acreage but not in the North Fork coal 

mining area. 

Any road construction or LCZ construction must not diminish, over the long-term,

existing native cutthroat trout habitat. The July 2008 proposed Rule did not specifically 

address native cutthroat trout. This proposed Rule prohibits road or LCZ construction 

unless the responsible official determines that within a native cutthroat trout catchment

or identified recovery watershed, road construction or an LCZ would not diminish, over 

the long-term, conditions in the water influence zone and in the native cutthroat habitat.

The term ―long-term temporary road‖ has been eliminated from the Colorado Roadless 

Rule. Roads constructed pursuant to existing oil and gas leases that allow road 

construction and roads constructed pursuant to existing coal leases and future coal 

leases within the North Fork coal mining area would be temporary roads.

PURPOSE OF AND NEED FOR ACTION

The Department, the Forest Service, and the State of Colorado agree there is a need to provide 

management direction for the conservation of roadless area values and characteristics within 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

34—Chapter 1. Purpose and Need for Action

roadless areas in Colorado. In the petition, the State of Colorado has indicated that there is a 

need to develop state-specific regulations for the management of Colorado‘s roadless areas for 

the following reasons:

1. Roadless areas are important because they are, among other things, sources of drinking 

water, important fish and wildlife habitat, semi-primitive or primitive recreation areas, 

and naturally appearing landscapes. There is a need to provide for the preservation of 

roadless area characteristics. 

2. As recognized in the 2001 Roadless Rule, tree-cutting, sale or removal and road 

construction/reconstruction have the greatest likelihood of altering and fragmenting 

landscapes, resulting in immediate, long-term loss of roadless area values and 

characteristics and there is a need to generally prohibit these activities in roadless areas. 

Since the 2001 Roadless Rule was promulgated, some have argued that linear 

construction zones also need to be restricted. 

3. In addition to the concerns articulated in the 2001 Rule, there is a need to accommodate 

state-specific situations and concerns in Colorado‘s roadless areas. These include the 

following: 

a. reducing the risk of wildfire to communities and municipal water supply systems; 

b. permitting exploration and development of coal resources in the North Fork Coal 

Mining Area;

c. permitting of construction and maintenance of water conveyance structures;

d. permitting access to current and future electrical power lines; and

e. accommodating existing permitted or allocated ski areas. 

4. There is a need to ensure that Colorado roadless areas are accurately mapped.

PROPOSED ACTION

The Department, in cooperation with the State of Colorado, proposes to promulgate a statespecific rule to manage roadless areas and conserve roadless area characteristics on NFS lands 

in Colorado. 

The Colorado Roadless Rule would establish a system of Colorado Roadless Areas (CRAs) with 

protections for management of these areas replacing the Inventoried Roadless Areas (IRAs) for 

national forest land in Colorado. CRAs would be identified on a set of maps maintained at the 

Forest Service national headquarters office, including records of adjustments to such maps 

pursuant to the final Colorado Roadless Rule. The CRAs upper tier acres would be identified on 

the same set of maps.

The proposed Rule would use the most accurate mapping information and adjust roadless area 

boundaries by: 

correcting mapping errors that primarily resulted from improvements in inventory data 

and mapping technology;

excluding private land; 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 1. Purpose and Need for Action—35

excluding land substantially altered by roads and timber harvest activities; 

excluding ski areas under permit or allocated in forest plans to ski area development; 

excluding congressionally designated lands such as wilderness and other designations 

that take legal precedence over roadless area regulations; and 

including unroaded areas outside IRAs that contain roadless area characteristics. 

The CRAs would encompass approximately 4.19 million acres of NFS land in Colorado, 

distributed among 363 separate roadless areas (Appendix A). The proposed Rule provides for 

future adjustments to be made to CRA boundaries (Map Packet, Map 3), subject to a public 

review and comment, and applicable NEPA or rulemaking requirements. The Forest Service 

national headquarters office would maintain the official map of CRAs, which would be readily 

available to the public.

The Colorado Roadless Rule includes a management strategy for activities and land uses within 

CRAs that are tailored to meet the unique circumstances present in Colorado. Road construction 

and reconstruction, tree-cutting, sale or removal and linear construction zones are prohibited 

within the CRAs with limited exceptions. Chapter 2 describes the proposed rule in greater 

detail, along with other alternatives considered in this analysis.

SCOPE AND APPLICABILITY

Scope of the EIS

The scope of this EIS consists of the range of actions, alternatives, and impacts that are 

considered relevant to the proposed action. The proposed action is geographically limited to 

proposed CRAs and existing IRAs (referred to as the analysis area) within the State of Colorado. 

See chapter 3 for a further discussion of the analysis area. The proposed action is primarily 

focused on the prohibitions and exceptions for road construction and reconstruction, the use of 

linear construction zones and tree-cutting, sale or removal activities within roadless areas. The 

proposed Rule would not suspend, revoke, or modify land use permits, contracts, or other legal 

instruments issued prior to the effective date of the rule.

The Colorado Roadless Rule is programmatic and is intended to guide future development of 

site specific actions within CRAs. The Colorado Roadless Rule would not authorize the 

implementation of any ground-disturbing activities, but rather it describes exceptions under 

which certain activities may be allowed or restricted within roadless areas. Before authorizing a 

land use activity in roadless areas, the Forest Service must complete a more detailed and sitespecific environmental analysis pursuant to the NEPA and its implementing regulations. When 

a specific project or activity is proposed on NFS land, site-specific effects are analyzed and after 

considering that analysis, decisions are made regarding if, how, where, and when the specific 

activities may occur.

Applicability

The lands subject to this rulemaking are NFS lands in Colorado that contain roadless areas 

under any of the alternatives. There are eight national forest administrative units in Colorado 

that are subject to this rulemaking EIS. Table 1-1 lists the eight national forests in Colorado to 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

36—Chapter 1. Purpose and Need for Action

which this EIS applies. The table provides information about each national forest administrative 

unit and the date of its last approved forest plan.

Table 1-1. National forest administrative units in Colorado and associated forest plan approval 

date

National forests in Colorado Date of approved forest plan

Arapaho-Roosevelt National Forests 1997

Grand Mesa, Uncompahgre, and Gunnison National Forests 1983

Manti-La Sal National Forest 1986

Routt National Forest 1998

Pike-San Isabel National Forests 1984

Rio Grande National Forest 1996

San Juan National Forest 1983 

(Revision in progress; draft revised plan 2007)

White River National Forest 2002

The proposed Rule, like other regulations, would work in conjunction with forest plan

direction. Thus, road or LCZ construction, reconstruction and/or tree-cutting, sale or removal 

would be prohibited in roadless areas unless they meet specific exceptions described in the 

Colorado Roadless Rule. However, for the exception to apply, the activities must still comply 

with applicable standards identified in forest land management plans. 

DECISION FRAMEWORK

The Secretary of Agriculture or a delegated designee will decide whether to promulgate the 

Colorado Roadless Rule as proposed or one of the other alternatives analyzed in this EIS. 

Promulgation of a rule involves establishing regulations, which would be issued under Title 36 

of the Code of Federal Regulations (CFR) Part 294. The decision to be made involves a choice 

among the four alternatives analyzed in detail in this EIS, which means determining whether to: 

1. Promulgate a state-specific rule to manage IRAs in Colorado pursuant to the provisions 

contained in the 2001 Roadless Rule (alternative 1); or

2. Promulgate a state-specific rule to manage Colorado‘s CRAs based on the State‘s 

petition (alternative 2) with portions of the CRAs identified as CRA upper tier acres; or

3. Take no action. No state-specific roadless rule would be promulgated. IRAs in Colorado 

would be managed in accordance with the forest plans in the eight national forests 

(alternative 3); or 

4. Promulgate a state-specific rule to manage Colorado‘s CRAs based on the State‘s 

petition with portions of or entire CRAs identified as CRA upper tier acres different 

from those identified under alternative 2 (alternative 4); or

5. Some combination of the provisions and inventories in the above four alternatives. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 1. Purpose and Need for Action—37

PUBLIC INVOLVEMENT

The Forest Service and the State of Colorado have solicited public involvement and comments 

on the development of a Colorado Roadless Rule. Below is a description of the public 

involvement efforts of the Forest Service and the State of Colorado.

Forest Service Public Involvement

The Forest Service, to date, has solicited public involvement in the following ways:

On December 27, 2007, the Forest Service published a notice of intent in the Federal 

Register to prepare an EIS on roadless area conservation on NFS lands in Colorado (Fed. 

Reg. Vol. 72 No. 246, 72982). The Forest Service also solicited comments from interested 

parties on the notice of intent from December 27, 2007 through February 25, 2008. 

Approximately 88,000 comments were received.

On July 25, 2008, the Forest Service published a proposed rule to establish state-specific 

management direction for conserving roadless areas in Colorado (73 FR 43544). A notice 

of availability for the DEIS was published in the Federal Register (73 FR 44991) and legal 

notice in the newspaper of record on August 1, 2008. The availability of the regulatory 

risk assessment for the proposed rule was published in the Federal Register on September 

18, 2008 (73 FR 54125). All comment periods closed on October 23, 2008. In total, 

approximately 106,000 comments were received.

The RACNAC held open public meetings in Washington, DC in June of 2007 and 

January, July and November of 2008. In addition a meeting was held in Salt Lake City, 

Utah in October of 2008. Public comments were accepted at these meetings, which 

helped the RACNAC develop their December 5, 2009 recommendations to the Secretary 

of Agriculture.

The Forest Service consulted with all potentially affected tribes regarding the proposed 

rule from October 2007 through October 2008. Tribal consultation on this proposed 

Colorado Roadless Rule is ongoing.

State of Colorado Public Involvement

In their petition process, the State of Colorado has, to date, solicited public involvement in the 

following ways:

Senate Bill 05–243, signed into Colorado law on June 8, 2005, created and identified a 13-

member bipartisan task force to make recommendations to the Governor regarding 

inventoried roadless areas on NFS lands in Colorado. The task force held nine public 

meetings throughout the State, held six deliberative meetings that were open to the 

public, and reviewed and considered over 40,000 public comments.

The State of Colorado held a comment period from August 3 to October 3, 2009 on a 

State modified version of the July 2008 proposed Rule.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

38—Chapter 1. Purpose and Need for Action

TRIBAL CONSULTATION

There are two resident tribes in Colorado – Ute Mountain Ute and Southern Ute – who retain 

some of their traditional land base as reservations. These two tribes retain specific hunting

rights and other aboriginal rights throughout their traditional territory including portions of the 

roadless areas in Colorado. Over a dozen other tribes located outside Colorado maintain tribal 

interests, including aboriginal and ceded territories, and inherent aboriginal rights within 

Colorado. In 1874, Congress approved an agreement between the United States and certain Ute 

Indians in Colorado, known as the "Brunot Agreement". Under this agreement, the Utes ceded 

certain land to the United States but reserved a right to hunt on those lands. These lands are 

predominately on the San Juan National Forest.

The Forest Service has ongoing consultation with all the potentially-affected tribes. Tribal 

consultation was initiated in October 2007 and no reply letters were received during the scoping

period. However, tribal concerns that surfaced during other consultations are discussed in the 

EIS. Consultation with interested or affected tribes will continue throughout the analysis and 

decision-making process. 

ISSUES

The NEPA implementing regulations at 40 CFR §1501.2 requires federal agencies to develop 

and evaluate alternatives to recommended courses of action in any proposal that involves 

unresolved conflict concerning alternative uses of available resources. Public involvement was 

used to identify points of disagreement about the proposed Rule and to identify issues to use as 

a basis for developing and evaluating alternatives.

Comments that support the purpose of and need for the proposed action are not listed here as 

issues but are evaluated in this EIS as to how well each alternative addresses the purpose and 

need (refer to Purpose and Need section for details). For example, the alternatives are evaluated 

for the degree to which they meet the stated purpose and the need to conserve roadless area 

characteristics within the context of Colorado specific situations and concerns. 

NEPA regulations require the agency to identify and eliminate from detailed study those issues 

that are not significant or that have been covered by prior environmental review, to narrow the 

scope of the analysis. Reasons for eliminating issues from detailed study include when the 

issues are:

General opinions or position statements not specific to the proposed action 

Addressed by other laws, regulations, or policies 

Not relevant to the potential effects of the proposed action, or otherwise outside the 

scope of this analysis. 

The following issues were eliminated from detailed study in this EIS because they are outside 

the scope of the decision to be made by the Secretary of Agriculture on the proposed Rule 

relative to other alternatives analyzed in this EIS (refer to sections on Decision Framework and 

Scope and Applicability of the Rule):

National Park Service management issues
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 1. Purpose and Need for Action—39

General conditions of public lands

Conditions of roads and facilities on national forests

Political motivations or integrity of government officials

Public participation processes or procedures

Funding priorities and government expenditures 

Alternative energy on national forests

Wilderness protection or recommendations for wilderness designation

Motorized vehicle use and routes or other travel management topics

Access associated with livestock grazing permits and allotment management

How the proposed Colorado Rule may set a precedent for management of roadless areas 

in other states.

The following issues were carried through the analysis process to evaluate differences in the 

consequences among the alternatives.

Issue—Potential effects to opportunities for community wildfire protection. Prohibiting road 

construction or reconstruction and tree-cutting, sale or removal can influence the effectiveness 

of efforts to reduce wildfire impacts to communities and water supply systems.

Issue – Potential loss of roadless area characteristics. The exceptions, in which road 

construction or reconstruction, use of LCZs, tree-cutting, sale or removal, and some other 

activities may occur in roadless areas under the proposed Rule, may result in a loss of roadless 

area characteristics. 

Issue – Potential loss of opportunities to explore for and develop oil and gas resources. 

Prohibiting road construction or reconstruction to access oil and gas basins in roadless areas 

that have not been leased prior to the effective date of rulemaking may result in a loss of 

opportunities to explore for and develop oil and gas resources in those areas.

Issue – Potential reduction in native species diversity. The exceptions, under which road 

construction or reconstruction, use of LCZs, tree-cutting, sale or removal, and some other 

activities may occur in roadless areas under the Colorado Roadless Rule, may affect populations 

of wildlife, fish, and plants, including the potential for:

An increase in the prevalence of invasive plants, animals, and other organisms that can 

out-compete and dominate diverse native plant and animal communities.

A loss or reduction of wildlife or fish habitat or population viability, resulting from 

reductions in unfragmented interior habitat, migration corridor connections, and 

security and quality of habitat for some ―at risk‖ species or important game species.

A loss or reduction of threatened, endangered, or sensitive plant species habitat or 

populations.

Issue – Potential loss of opportunities to explore for and develop coal resources outside the 

North Fork coal area. Prohibiting construction/reconstruction of roads to access coal reserves 

in areas that have not been leased (prior to the effective date of rulemaking) and/or are located 

outside the North Fork coal mining area may result in a loss of opportunities to explore for and 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

40—Chapter 1. Purpose and Need for Action

develop coal resources in those areas.

Issue - Potential reduction in soil and water quality. Wildfire effects can also reduce soil and 

water quality. The effects of wildlife could potentially be reduced by fuels treatments. On the 

other hand, the exceptions in which road construction or reconstruction, the use of LCZs, and 

tree-cutting, sale or removal may occur in roadless areas under the proposed rule may result in 

a decline in soil or water quality, including the potential for:

Accelerated soil erosion or other soil impacts that can affect long-term productivity.

Increases in stream sedimentation that can affect water quality and water uses off-site 

and downstream from the roadless areas.

Issue - Potential reduction in semi-primitive recreation and related values. The exceptions in 

which road construction or reconstruction, use of LCZs, tree-cutting, sale or removal, and some 

other activities may occur in roadless areas under the proposed Rule may result in a reduction 

in semi-primitive recreation opportunities away from the sights and sounds of human activities 

and built environments, including the potential for:

A reduction in opportunities for solitude.

A reduction in scenic quality.

Reductions in scientific and heritage benefits that might be derived from preserving the 

undeveloped nature of roadless areas for future generations.

Issue – Potential loss of opportunity to feasibly transport oil and gas resources using 

pipelines. Prohibiting oil and gas pipelines from going through roadless areas from lands 

outside roadless areas may result in a loss of opportunity to feasibly extract and transport oil 

and gas resources. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 2. Alternatives, Including the Proposed Action—41

CHAPTER 2. ALTERNATIVES, INCLUDING THE PROPOSED 

ACTION

INTRODUCTION

This chapter provides a description of the four alternatives considered in detail in this RDEIS. 

Maps associated with each alternative are located in the map packet. This chapter also describes 

the alternatives comparatively and describes alternatives dismissed from detailed study. The 

range of alternatives is designed to address the purpose and need and issues described in 

chapter 1. 

Each alternative offers a different approach to conservation of roadless area characteristics, by 

providing a different mix of prohibitions on land use activities, different exceptions to 

prohibitions, and different requirements for the exceptions. The differences primarily are 

related to road construction or reconstruction; linear construction zones (LCZs); and treecutting, sale or removal in roadless areas. Alternative comparison tables at the end of this 

chapter summarize the differences in the design of each alternative as well as the differences in 

the environmental consequences or effects of each alternative based on the detailed analysis of 

environmental consequences contained in chapter 3. 

The four alternatives analyzed in detail are: 

Alternative 1: Provisions of the 2001 Roadless Area Conservation Rule (2001 Roadless 

Rule)11. This alternative establishes a state-specific roadless rule for Colorado that 

retains IRA boundaries12 and roadless area management provisions for management of 

roadless areas on NFS land in Colorado contained in the 2001 Roadless Rule. If a 

decision is made to select this alternative, it would not revoke, suspend, or modify any 

permit, contract or other legal instrument authorizing the occupancy and use of NFS 

lands issued before the effective date of the final Rule. 

Alternative 2: Proposed Action, Colorado Roadless Rule. This alternative establishes a 

state-specific roadless rule for Colorado. It modifies alternative 2 from the DEIS based 

on public comments and the revised petition submitted by the State of Colorado. It is 

based on the provisions of the 2001 Roadless Rule, but provides prohibitions and 

specific exceptions relevant to the State of Colorado. There are 562,200 acres identified as 

CRA upper tier under this alternative. Upper tier acres have fewer exceptions to the 

prohibitions than the other CRA acres. If a decision is made to select this alternative, it 

would not revoke, suspend, or modify any permit, contract or other legal instrument 

authorizing the occupancy and use of NFS lands issued before the date of the final Rule. 

Alternative 3: No Action, Forest Plan Direction. This alternative does not establish a 

state-specific roadless rule for Colorado and all lands in the IRAs and CRAs would be 

 

11 “2001 Roadless Rule” is described in the Federal Register, January 12, 2001, Vol. 66, No 9, pages 3244 - 3273

12 Congressionally designated acres as well as mapping errors associated with private lands and Wilderness have 

been eliminated from the IRA boundaries.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

42—Chapter 2. Alternatives, Including the Proposed Action

managed according to forest plan direction. The boundaries of the roadless areas shown 

in this alternative for information purposes are those in the most recent forest plans and 

are the same IRAs as those in alternative 1.

Alternative 4: Colorado Roadless Rule with Public Proposed Upper Tier. This 

alternative establishes a state-specific roadless rule for Colorado. This alternative 

provides the same prohibitions and exceptions as alternative 2. The difference is that 

2,614,200 acres are identified as CRAs upper tier acres in this alternative (over 2 million 

more acres in upper tier than alternative 2). If a decision is made to select this 

alternative, it would not revoke, suspend, or modify any permit, contract or other legal 

instrument authorizing the occupancy and use of NFS lands issued before the date of the 

final Rule.

ALTERNATIVES CONSIDERED BUT ELIMINATED FROM DETAILED 

STUDY

Federal agencies are required by NEPA regulations to explore and evaluate all reasonable 

alternatives to a proposed action and to briefly discuss the reasons for eliminating alternatives 

from detailed study (40 CFR §1502.14). 

The following three alternatives were submitted in response to information from scoping and 

comments on the DEIS and were considered and eliminated from detailed study. Below is a 

description of the alternatives and the reasons why these alternatives were eliminated from 

detailed study.

An alternative that provides the roadless area conservation provisions from alternative 

1, together with the CRA boundaries from alternative 2. 

This alternative is similar to alternative 1. The provisions of the 2001 Roadless Rule do allow for 

updating of the Inventoried Roadless Area maps13. This alternative is within the range of the 

alternatives and could be selected as alternative 1 modified because it falls within the range of 

the alternatives analyzed in this EIS and to eliminate redundancy in the analysis.

An alternative that allows for more commercial use such as increased timber harvesting. 

Alternative 3 allows for increased levels of commercial use. Another alternative that allows for 

more commercial use than alternative 2, but less than alternative 3, while meeting the purpose 

and need of protecting roadless area characteristics would not result in differences that can be 

meaningfully analyzed.

An alternative that offers reduced road densities, creation of new roadless areas, and 

more protective management than any of the alternatives analyzed in the DEIS. 

Reducing road densities is outside the scope of this rule-making and decision framework and is 

best decided during travel management analysis. In addition, all alternatives allow additions to 

roadless areas, if needed. Alternative 2 and 4, in response to public comments, have identified 

 

13 In §294.11 Definitions for Inventoried Roadless Area is: “Areas identified in a set of inventoried roadless area 

maps, contained in Forest Service Roadless Area Conservation, Final Environmental Impact Statement, Volume 2, 

dated November 2000, which are held at the National headquarters office of the Forest Service, or any subsequent 

update or revision of those maps.”
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 2. Alternatives, Including the Proposed Action—43

CRAs or portions of CRAs that are proposed to be managed as upper tier acres. Upper tier acres 

have limited exceptions to the tree-cutting and road construction prohibitions. Additional 

protections would not meet the purpose and need to accommodate state-specific situations and 

concerns. 

FEATURES COMMON TO ALL ALTERNATIVES

This section describes the features that are common to all alternatives analyzed in detail in this 

EIS. Features common to all alternatives are summarized in Table 2-2.

Federal and State Requirements

Management of NFS lands in Colorado are governed by a variety of federal statutes, 

regulations, executive orders, and the Forest Service Directive System (manuals and

handbooks). In addition, some State and local laws and regulations apply on NFS lands within 

the State. The selection of any of the alternatives in this EIS would not affect the applicability of 

any federal or State requirements.

Forest Plans

The National Forest Management Act (NFMA) and its implementing regulations at 36 CFR, part 

219, obligate the Forest Service to develop, amend, or revise plans for each National Forest unit. 

Forest plans provide guidance for management activities on a national forest; including 

establishing forest-wide management requirements and direction applicable to the entire forest 

or to specific management areas. When guidance in a forest plan is more restrictive than 

direction described under the proposed rule alternatives, actions must be consistent with the 

more restrictive direction. For example, if a forest plan standard prohibits road construction 

where it is allowed under a roadless rule, road construction cannot occur.

None of the alternatives compel the Forest Service to amend or revise any forest plan. In 

addition, none of the alternatives limit the authority of a responsible official to amend or revise 

a forest plan. 

Project Specific Environmental Analysis

None of the alternatives allow any specific project to occur. Any specific proposals for road 

construction and reconstruction, LCZs, tree-cutting, sale or removal, or other activities that are 

permissible under any alternative, must undergo site specific environmental analysis required 

by NEPA. 

Reserved and Outstanding Rights

Under all alternatives, the reasonable exercise of reserved or outstanding rights for access, 

occupancy, and use of NFS lands within roadless areas would not be affected. The rights 

include those that exist by law, treaty or other authority. They include but are not limited to the 

right to construct roads or provide other reasonable access across NFS lands for the purpose of 

access to: private property, mining claims for locatable minerals under the 1872 Mining Law, 

and land uses protected by American Indian treaty rights. 

In 1874, Congress approved an agreement between the United States and certain Ute Indians in 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

44—Chapter 2. Alternatives, Including the Proposed Action

Colorado, known as the "Brunot Agreement". Under this agreement, the Utes ceded certain land 

to the United States but reserved a right to hunt on those lands. The lands are predominately on 

the San Juan National Forest.

Existing Land Use Authorizations

―Authorizations‖ refer to land uses allowed under a special use permit, contract, or similar legal 

instrument. There are numerous types of lands and recreation-related authorizations issued for 

occupancy and use of NFS lands. Oil, gas and coal leases on NFS lands are a type of 

authorization issued by the Bureau of Land Management. All of the alternatives allow for the 

continuation, transfer, or renewal of valid and existing land use authorizations for activities in 

roadless areas. ‖Existing authorizations‖ are those that are issued prior to the effective date of 

the final Rule.

Examples of land use authorizations not specifically prohibited or restricted under any 

alternative include, but are not limited to, the following: 

Use of existing roads and trails, including motorized travel on roads and trails

Livestock grazing

Recreational activities, including but limited to hunting, fishing, hiking, camping, 

mountain biking, and skiing.

Definitions of Roads and Linear Construction Zones

For this EIS, Table 2-1 displays the specific definitions used for these terms. 

Table 2-1. Definitions of road and linear construction zone terms.

Term Definition

forest road Generally refers to a road determined to be necessary for the long term protection, 

administration, and utilization of national forest system land or resources, and is 

managed as part of the national forest transportation system. Previously called 

―system‖ or permanent, roads.

temporary road A road necessary for emergency operations or authorized by contract, permit, or 

other authorization that is not a forest road and that is not included on the forest 

transportation atlas.

linear construction zone A temporary linear area of surface disturbance over 50-inches wide that is used for 

motorized transport by vehicles or construction equipment to install a linear facility. It 

is not used as a motor vehicle route and is not engineered to road specifications. 

Linear facilities include pipelines, electrical power lines, telecommunication lines, 

ditches, and canals.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 2. Alternatives, Including the Proposed Action—45

Table 2-2. Features Common to All Alternatives

Features Common to All Alternatives

Affected national forests in 

Colorado

Arapaho-Roosevelt

Grand Mesa, Uncompahgre, and Gunnison

Pike-San Isabel

Rio Grande

Routt

San Juan

White River

Manti-La Sal – the 27,000 acres of the Manti-La Sal National Forest where it occurs in Colorado. 

Congressional designations Nine congressionally designated areas overlap portions of IRAs, totaling about 185,000 acres. These areas are excluded from 

the roadless areas analyzed in this EIS. Those areas are not subject to state-specific rulemaking because statutory provisions 

supersede rule (regulatory) provisions.

Federal and State authorities Numerous federal and state laws, regulations, executive orders, and Forest Service directives would continue to govern 

management of roadless areas on NFS lands in Colorado but would not allow for more activity than allowed by the final rule. 

Forest plans The analysis of alternatives in this EIS is predicated on forest plan direction at the time of the analysis, recognizing that forest 

plans are subject to change over time, and that several plans are currently undergoing revision. 

Rulemaking does not alter forest plans nor the ability to update forest plans through an amendment or revision process. 

Activities in roadless areas must adhere to forest plan direction where it is more restrictive than a roadless rule for specific areas 

and situations.

Project Specific Environmental 

Analysis

Although the alternatives establish specific prohibitions with exceptions for certain activities within roadless areas, alternatives do 

not compel or authorize implementation of any ground-disturbing actions in the roadless areas. Should such actions be proposed 

in the future, they must undergo environmental analysis, public involvement, and decision making processes pursuant to NEPA.

Reserved and outstanding rights,

statutes or treaties

Alternatives allow road construction or reconstruction, use of LCZs tree-cutting, sale or removal and other activities in roadless 

areas that are associated with rights allowed by existing laws or treaties. Rights include those for road access, surface 

occupancy, and use of NFS land in roadless areas for purposes of:

Accessing private lands within or adjacent to NFS land, as authorized under Alaska National Interest Land Conservation Act 

(ANILCA).

Accessing NFS lands for exploration and development of locatable minerals (e.g., gold, silver, copper, lead, zinc, uranium, and 

tungsten), as authorized under the General Mining Law of 1872, as amended.

Accessing NFS lands for American Indian land uses, as authorized under various American Indian treaties.

Accessing NFS lands to conduct a response action under the Comprehensive Environmental Response, Compensation, and 

Liability Act (CERCLA), including a natural resource restoration action under CERCLA, Section 311 of the Clean Water Act, or 

the Oil Pollution Act.

Accessing NFS lands for a Federal Aid Highway project, as authorized under Title 23 of the U.S. Code (23 USC). 

Existing authorizations Alternatives allow road construction / reconstruction, LCZs, tree-cutting, sale or removal, and other activities in roadless areas 

that are associated with valid authorizations issued by the Secretary of Agriculture or designated Forest Service official as of the 

effective date of the rule. These include authorizations granted by permits, contracts, or leases. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

46—Chapter 2. Alternatives, Including the Proposed Action

Features Common to All Alternatives

No alternative affects decisions related to renewal, continuation, or transfer of existing authorizations. 

Road construction/reconstruction, tree-cutting, sale or removal, motor vehicle uses, and other activities are not prohibited in 

roadless areas where they have been authorized under an existing land use authorization. Such instances include, but are not 

limited to, activities authorized for: 

Livestock grazing operations

Utility operations 

Ski area operations 

Mineral resource extraction operations, pursuant to 36 CFR part 228 regulations

Other activities under lands or recreation special use permits, contracts, or leases.

Other Land Uses Activities that are otherwise not prohibited under the alternatives are permissible in roadless areas. The activities include, but are

not limited to:

Prescribed burning

Trail construction or maintenance (motorized and non-motorized)

Public hunting, fishing, camping, or other dispersed recreation uses

Livestock grazing.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 2. Alternatives, Including the Proposed Action—47

ROADLESS INVENTORY AND ACRES IN ALTERNATIVES

Alternatives 1, 2, and 4 each provide for a state-specific roadless rule; however, the provisions 

of each alternative apply to different roadless inventories. Alternatives 1 and 3 use the 

inventory of the 2001 Roadless Rule IRAs. For alternatives 2 and 4, the Forest Service reexamined the boundaries and acreage of the 2001 Roadless Rule and other Forest Service lands 

in Colorado for roadless area management, as requested in the State‘s revised petition. From 

this effort, the Forest Service identified portions of the 2001 Roadless Rule inventory that were 

substantially altered and did not possess sufficient roadless area characteristics. In addition, the 

Forest Service identified areas outside the 2001 Roadless Rule inventory that did possess 

sufficient roadless area characteristics. Taken together, the exclusion of the substantially altered 

lands and inclusion of additional areas became the CRAs.

Table 2-3 displays the comparisons between the IRA inventory in alternatives 1 and 3 and the 

CRA inventory in alternatives 2 and 4. Overall, the CRAs have a net loss of 57,600 acres in 

roadless from the IRA acres.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

48—Chapter 2. Alternatives, Including the Proposed Action

Table 2-3. Net change in roadless acreage by forest—from inventoried roadless area acres to 

Colorado roadless area acres

2001 Rule 

Total IRA 

Acres 1

Corrected 

Colorado IRA 

Acres2

(Alternatives 

1 and 3)

Corrected 

IRA acres 

not included 

within CRAs

Roadless 

acres added 

to CRAs

Total CRA 

Acres 

(Alternatives 

2 and 4)

Proposed 

Net Change

Region 2 Colorado

Region 4 Colorado

Total, State of 

Colorado 4,433,000 4,243,600 467,100 409,500 4,186,000 (57,600)

Column 1 acres rounded to nearest 1,000 acres; others rounded to nearest 100 acres. Acres do not add due to rounding

1

The 2001 Roadless Rule used the inventoried roadless areas from the forest plans that were in effect at the time the 2001 Rule 

was developed, or a roadless inventory that had undergone public involvement. The date of each Forest’s inventory used for the 

2001 Rule is shown here. Acreages are from the 2001 Roadless Rule FEIS.

2

The acres to be used for the rulemaking analysis differ from the acres reported in the RACR FEIS because some Wilderness, 

private, and Special Areas were included in the 2001 roadless inventory. These acres will not be included in this rulemaking 

analysis as acres to be managed under a Colorado Rule because Congress has already set out specific management for those 

acres. Excluded acres are private and wilderness acres that have been found as mapping errors in the 2001 Rule IRA acres as 

well as those acres in the James Peak and Spanish Peak Wildernesses, the Indian Peaks Wilderness, Bowen Gulch and James 

Peak Protection Areas, Roubideau and Tabeguache Special Areas, Fossil Ridge Recreation Management Area, and the Piedra 

Special Management Unit all designated by Congress but were not excluded from the 2001 RACR inventory. 

ArapahoRoosevelt

391,000

(1997)

352,500 10,800 5,400 347,100 (5,400)

GMUG

1,127,000

(1979)

1,058,300 280,800 124,200 901,900 (156,500)

Pike San Isabel

688,000

(1979)

667,300 63,000 170,300 774,600 107,300

Rio Grande

530,000

(1996)

529,000 14,300 3,800 518,500 (10,500)

Routt

442,000

(1998)

442,300 10,300 1,700 433,700 (8,600)

San Juan

604,000

(1979)

543,600 76,600 98,900 565,900 22,300

White River

640,000

(2002)

639,500 7,500 4,700 636,700 (2,800)

Manti La Sal

11,000

(1979)

11,000 3,800 500 7,700 (3,300)
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 2. Alternatives, Including the Proposed Action—49

ALTERNATIVE 1: PROVISIONS OF THE 2001 ROADLESS RULE

This alternative reflects management under the provisions of the 2001 Roadless Rule. This 

alternative establishes general prohibitions on road construction/reconstruction and treecutting, sale and removal within IRAs, while permitting those activities in all parts of all IRAs 

under certain exceptions. This alternative does not include any prohibitions on LCZs.

Inventoried Roadless Areas

Under this alternative, the roadless areas consist of IRAs identified in the 2001 Roadless Rule; 

encompassing approximately 4.24 million acres of NFS lands in Colorado. The IRAs are based 

on the roadless inventories from forest plans that either were in effect or had undergone public 

comment at the time the 2001 Rule was developed. For the Grand Mesa, Uncompahgre, and 

Gunnison (GMUG), Manti-La Sal (within Colorado), Pike-San Isabel, and San Juan National 

Forests, the IRAs are composed of roadless area inventories completed (and manually mapped) 

in the 1970s, as part of the Roadless Area Review and Evaluation processes (commonly referred 

to as RARE II). For other national forests—the Rio Grande, Arapaho-Roosevelt, Routt, and 

White River National Forests—the IRAs adopted in the 2001 Roadless Rule consisted of the 

roadless area inventories completed during those forest plan revision processes (approximately 

1996 to 2002). Congressionally Designated Areas, private land and Wilderness were removed 

from IRAs for this analysis.

The IRAs under this alternative do not include additional acres with roadless area 

characteristics identified under alternatives 2 and 4 that are located outside the IRAs. Under this 

alternative, those acres would be managed according to their respective forest plans.

Management of Inventoried Roadless Areas

With certain exceptions, this alternative prohibits two main types of activities within IRAs: (1) 

road construction and reconstruction, and (2) tree-cutting, sale, or removal (called timber

harvest in the 2001 Roadless Rule). These exceptions are described in detail below.

Tree-cutting, Sale, or Removal

This alternative generally prohibits timber harvest. The alternative specifies exceptions to the 

general prohibition where one of five exceptions is met. Table 2-4 displays the exceptions in 

which timber harvest would be allowed in IRAs under this alternative. 

Table 2-4. Alternative 1, exceptions in which tree-cutting, sale, or removal is allowed in Inventoried 

Roadless Areas

Description of Exceptions

The cutting, sale, or removal of generally small-diameter timber may occur in IRAs where needed to maintain or 

improve threatened, endangered, proposed, or sensitive species habitat, consistent with maintaining or improving 

roadless area characteristics defined in the definitions section of the rule

The cutting, sale, or removal of generally small-diameter timber may occur in IRAs where needed to maintain or 

restore the characteristics of ecosystem composition and structure, such as to reduce the risk of uncharacteristic 

wildland fire effects, within the range of variability that would be expected to occur under natural disturbance 

regimes of the current climatic period, consistent with maintaining or improving roadless area characteristics defined 

in the definitions section of the rule 

The cutting, sale, or removal of timber may occur in IRAs where it is incidental to the implementation of a 

management activity not otherwise prohibited. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

50—Chapter 2. Alternatives, Including the Proposed Action

Description of Exceptions

The cutting, sale, or removal of timber may occur in IRAs where needed for personal or administrative uses 

provided for in 36 CFR part 223. 

The cutting, sale, or removal of timber may occur within portions of IRAs where roadless area characteristics have 

been substantially altered by the construction of a NFS road and subsequent timber harvest. Both the road 

construction and timber harvest must have occurred after the IRAs were designated and prior to effective date of 

rulemaking.

Road Construction and Reconstruction

This alternative generally prohibits road construction or reconstruction. However, this 

alternative does provide exceptions to the general prohibition. This alternative does not 

distinguish between forest (permanent) or temporary roads allowed under each exception. 

Table 2-5 describes the exceptions under which road construction or reconstruction would be 

allowed in IRAs under alternative 1. 

Table 2-5. Alternative 1, exceptions in which road construction and reconstruction may occur in 

Inventoried Roadless Areas

Description of Exceptions

Where a road is needed to protect public health and safety in cases of imminent threat of flood, fire, or other 

catastrophic event that, without intervention, would cause the loss of life or property. 

Where a road is needed to conduct a response action under the Comprehensive Environmental Response, 

Compensation, and Liability Act (CERCLA), or to conduct a natural resource restoration action under CERCLA, 

Section 311 of the Clean Water Act, or the Oil Pollution Act. 

Where a road is needed pursuant to reserved or outstanding rights, or as provided by statute or treaty.

Where road realignment is needed to prevent irreparable resource damage that arises from the design, location, use, 

or deterioration of a NFS road that cannot be mitigated by road maintenance. 

Where road reconstruction is needed to implement a road safety improvement project on a forest road determined to 

be hazardous on the basis of accident experience or accident potential on that road. 

Where the Secretary of Agriculture determines that a Federal Aid Highway project, authorized pursuant to Title 23 of 

the United States Code, is in the public interest or is consistent with the purposes for which the land was reserved or 

acquired and no other reasonable and prudent alternative exists. 

Where a road is needed in conjunction with the continuation, extension, or renewal of a mineral lease issued prior to 

the effective date of rulemaking, and includes any new lease issued immediately upon expiration of an existing lease. 

Such road construction or reconstruction must be conducted in a manner that minimizes effects on surface 

resources, prevents unnecessary or unreasonable surface disturbance, and complies with all applicable forest plan

direction, regulations, and laws. These roads must be obliterated when no longer needed for the purposes of the 

lease or upon termination or expiration of the lease, whichever is sooner. 

Road maintenance is permissible within IRAs. Road maintenance refers to the ongoing upkeep of a road necessary 

to retain or restore the road to the approved road management objectives (see Forest Service Manual 7705).

Linear Construction Zones (LCZs)

Alternative 1 has no specific restriction on the use of LCZs, the construction of oil and gas

pipelines, or the location of electrical power lines or telecommunication lines in IRAs.

Effective Date and Additional Information

Alternative 1 would implement the provisions of the 2001 Roadless Rule beginning when 

signed as the Colorado Rule, and not as a retroactive continuation of the national 2001 Roadless 

Rule. Therefore, if selected, this alternative would not revoke, suspend, or modify any permit, 

contract, or other legal instrument or project or activity decision authorized prior to the 

promulgation date of the final Colorado Rule. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 2. Alternatives, Including the Proposed Action—51

ALTERNATIVE 2: COLORADO ROADLESS RULE, PROPOSED ACTION

Alternative 2 is the proposed action, also called the Colorado Roadless Rule. The Colorado 

Roadless Rule is based on the petition submitted by the State of Colorado to the Secretary of 

Agriculture. The Colorado Roadless Rule establishes general prohibitions on road 

construction/reconstruction, LCZs, and tree-cutting, sale or removal within CRAs, while 

permitting those activities under certain exceptions to address State and local land management 

needs. Under this alternative, substantially altered acres within the IRAs have been removed

from the CRA inventory and would be managed following forest plan direction.

Colorado Roadless Areas

Under this alternative, approximately 4.19 million acres of NFS lands in Colorado would be 

identified as CRAs14. The CRAs in this alternative exclude the congressionally designated areas 

that overlap portions of the original 2001 Roadless Rule IRAs. Further, this alternative 

incorporates updated roadless area evaluations from the four national forests that are or will be 

working on land management plan revisions (GMUG; Manti-La Sal; Pike-San Isabel; and San 

Juan National Forests). This alternative updates the inventory by eliminating mapping errors on 

the four national forests in Colorado that completed roadless inventories from 1996 – 2002 as 

part of their revised land management plans (Arapaho-Roosevelt; Rio Grande; Routt, and White 

River). The CRAs are based on the most updated land ownership boundaries, roads inventories, 

and mapping technologies available. 

The inventory was reviewed by the Colorado Department of Natural Resources, Division of 

Wildlife, as well as the public during the initial draft EIS public comment period. Changes to 

the Colorado Roadless Areas were identified during this process. 

The CRAs in this alternative do not include 467,100 acres identified in the 2001 Roadless Rule. 

This includes 458,800 acres of substantially altered land and 8,300 acres within existing ski 

permits or ski area development allocations in the forest plans. The 458,800 acres of 

substantially altered lands are those that do not have roadless area characteristics, primarily 

because of road construction and timber harvest activities that have occurred in the area. The 

8,300 acres of ski area terrain not included in CRAs include 6,600 acres in ski areas under 

existing permits15 and 1,700 acres outside permit boundaries but within forest plan allocations 

for future ski area development (see Developed Ski Areas section in chapter 3). Under this 

alternative, all of the acres eliminated from the CRAs would be managed according to their 

respective forest plans. 

The CRAs under this alternative include approximately 409,500 acres of unroaded NFS lands 

that were not identified in the 2001 Roadless Rule. These areas contain roadless area 

characteristics and were recommended by the State to be included within the CRA inventory. 

This alternative also specifically identifies 20,000 acres in CRAs on the GMUG National Forests 

as the North Fork coal mining area. In this area, temporary road construction and 

reconstruction exceptions would apply (Map 13 in map packet).

 

14 Colorado Roadless Areas refer to areas identified in a set of maps maintained at the national headquarters office 

of the Forest Service, including records regarding any adjustments or modifications to such maps. 

15 For the 6,600 acres under permit, development can occur under any alternative after environmental analysis is 

complete.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

52—Chapter 2. Alternatives, Including the Proposed Action

This alternative designates a total of 562,200 acres as CRA upper tier acres16. The CRA upper tier 

acres in this alternative are generally unroaded and do not contain any existing oil and gas

leases. The Arapaho-Roosevelt, Rio Grande, Routt, and White River National Forests contain 

257,400 acres. These CRA upper tier acres prohibit or tightly restrict management activities 

related to road construction and tree-cutting under their current forest plans; forest plans that 

have gone through public comment periods during planning efforts. Details on the upper tier 

acres are found in Appendix B, Table B-8.

Approximately 304,900 upper tier acres occur on the GMUG National Forests and the San Juan

National Forest. Based on public involvement during previous and current revision processes, 

these acres were identified for management that prohibits or tightly restricts road construction 

and tree-cutting. Further detail on these upper tier acres are found in Appendix B, tables B-9 

and B-10. All 562,200 upper tier acres are analyzed in alternative 2.

Table 2-6. CRA Upper Tier Acres and CRA Optional Upper Tier Acres by Forest 

Forest

Upper Tier 

Acres

Revision

Completed

% of Forest 

CRA Acres

Upper Tier 

Acres

Revision Not

Completed 

% of Forest 

CRA Acres

Total of Upper 

Tier Acres

Arapaho-Roosevelt 149,700 43% - - 149,700

GMUG - - 182,700 20% 182,700

Manti-La Sal - - - - -

Pike-San Isabel - - - - -

Rio Grande 100 <1% - - 100

Routt 24,600 6% - 24,600

San Juan - 122,200 22% 122,200

White River 83,000 13% 83,000

Total, Colorado 257,400 6% 304,900 7% 562,200

Numbers may not add due to rounding.

In summary, the Colorado Roadless Rule identifies approximately 4.19 million acres of NFS

land in Colorado to be managed as CRAs. CRAs include 409,500 acres not identified as IRAs 

and exclude 467,100 acres that are within ski areas or substantially altered. Alternative 2 

identifies 562,200 acres for upper tier protections. 

Administrative Corrections or Modifications of Colorado Roadless 

Areas

This alternative allows the Chief of the Forest Service to make administrative corrections to the 

boundaries of CRAs after a public notice and 30-day comment period. Administrative 

corrections include clerical, typographical, and mapping errors or improvement in mapping

technology based on improved field data from updated imagery, global positioning system 

data, or other collected field data. The Chief of the Forest Service may make modifications to the 

CRA boundaries based on changed circumstances after public notice and 90-day comment 

period. The construction of temporary roads or tree-cutting, sale or removal within CRAs 

 

16 Colorado Roadless Areas upper tier acres refer to areas identified in a set of maps maintained at the national 

headquarters office of the Forest Service, including records regarding any adjustments or modifications to such 

maps. Further detail on the upper tier acres are found in Appendix Tables B-8, B-9, B-10 and on Map 4 in the map 

packet.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 2. Alternatives, Including the Proposed Action—53

cannot be the cause for a boundary modification. 

Management of Colorado Roadless Areas

With certain exceptions, the Colorado Roadless Rule prohibits three main types of activities 

within CRAs: (1) tree-cutting, sale or removal; (2) road construction and reconstruction; and (3) 

development of LCZs. Some exceptions also apply to the upper tier acres and are specifically 

noted below. 

Tree-cutting, Sale, or Removal

This alternative generally prohibits tree-cutting, sale or removal within CRAs, but it does 

provide for limited exceptions to this general prohibition. The exceptions under which treecutting, sale or removal would be allowed are described in Table 2-7. 

The responsible official may only authorize tree-cutting, sale, or removal for these exceptions 

where the Responsible Official determines the activity is consistent with the applicable forest 

plan, and one or more of the roadless area characteristics will be maintained or improved over 

the long-term (except for the last two exceptions in the following table—where it is incidental or 

for personal or administrative uses). Whether the exception applies or does not apply to upper 

tier acres is noted. 

Table 2-7. Alternative 2, exceptions in which tree-cutting, sale, or removal would be allowed in 

Colorado Roadless Areas (also applies to Alternative 4)17

Description of Exceptions

Where the Regional Forester determines tree-cutting is needed to reduce the wildfire hazard to an at-risk community

or municipal water supply system within the first 1⁄2 mile of the community protection zone or within the next one-mile 

of the community protection zone where proposed projects are within an area identified in a Community Wildfire 

Protection Plan (CWPP). For the CPZ to extend beyond the first 1⁄2 mile and up to an additional one-mile, the land 

must exhibit one of the following characteristics: a sustained steep slope that creates the potential for wildfire 

behavior endangering the at-risk community; has a geographic feature that aids in creating an effective fire break, 

such as a road or a ridge top; or is in condition class 3 as defined by Healthy Forest Restoration Act (Pub. L. 108–

148). If no CWPP exists, no project would be proposed beyond the first 1⁄2 mile. Projects would focus on small 

diameter trees to create strategic fuel breaks that modify fire behavior while retaining large trees to the maximum 

extent practical as appropriate to the forest type. Does not apply to upper tier acres.

Where needed outside of the community protection zone if the Regional Forester has determined there is a 

significant risk that a wildland fire disturbance event could adversely affect a municipal water supply system or the 

maintenance of the system. A significant risk exists where the history of fire occurrence and fire hazard indicate a 

serious likelihood that a wildland fire event would have adverse effects to a municipal water supply system. Does not 

apply to upper tier acres.

Where needed to maintain or restore the characteristics of ecosystem composition, structure and function. Does not 

apply to upper tier acres.

Where needed to improve threatened, endangered, proposed, or sensitive species habitat in coordination with the 

Colorado Department of Natural Resources including the Colorado Division of Wildlife. Does not apply to upper tier

acres.

Where it is incidental to the implementation of a management activity not otherwise prohibited by this subpart. This is 

applicable to all CRA acres, including upper tier.

Where needed and appropriate for personal or administrative use, as provided for in 36 CFR 223. This is applicable 

to all CRA acres, including upper tier.

 

17 Further details about the exceptions listed in table 2-7 are in the rule §294.42
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

54—Chapter 2. Alternatives, Including the Proposed Action

Roads and Linear Construction Zones

All of the road construction exceptions in the Colorado Roadless Rule dictate the type of road 

(forest road or temporary road) or LCZ allowed (see Table 2-1). In all of the exceptions, the 

decision as to the type of road constructed or the use of an LCZ will be that which meets the 

purpose and has the shortest duration on the land. For example, a temporary road would be 

constructed if it could provide reasonable access even if exceptions allow construction of a 

forest road. Except as allowed in the Colorado Roadless Rule, a temporary road shall not 

change designation to a forest road. Road maintenance would be allowed within CRAs.

Road Construction and Reconstruction 

Alternative 2 generally prohibits road construction/reconstruction within CRAs, but it does 

provide for limited exceptions to this general prohibition. There are required findings prior to 

road construction, reconstruction detailed in a following section. 

The exceptions under which forest (permanent) road construction or reconstruction would be 

allowed are described in Table 2-8 under this alternative. The descriptions include some minor 

paraphrasing from the Colorado Roadless Rule for readability in this EIS. Readers may refer to 

the published rule language for additional detail. Whether the exception applies or does not 

apply to upper tier acres is noted.

Table 2-8. Alternative 2, exceptions in which forest (permanent) road construction and 

reconstruction would be allowed in Colorado Roadless Areas (also applies to Alternative 4)18

Description of Exceptions

Where a road is needed pursuant to reserved or outstanding rights, or as provided for by statutes or treaties. This is 

applicable to all CRA acres, including upper tier.

Where road realignment is needed to prevent irreparable resource damage that arises from the design, location, use, 

or deterioration of a NFS road that cannot be mitigated by road maintenance. Road realignment may occur only if the 

road is deemed essential for administrative or public access, public health and safety, or other authorized use. Does 

not apply to upper tier acres.

Where road reconstruction is needed to implement a road safety improvement project on a forest road determined to 

be hazardous on the basis of accident experience or accident potential on that road. Does not apply to upper tier

acres.

Where the Regional Forester determines a road is needed to allow for the construction, reconstruction, or 

maintenance of water conveyance structures operated pursuant to a pre-existing water court decree issued by the

Colorado Water Courts prior to [final rule effective date] adjudicating as the point of a diversion or the place of use a 

location within a CRA. Does not apply to upper tier acres.

Table 2-9 summarizes the exceptions for only temporary road construction that could be 

allowed within CRAs and none of these exceptions are allowed in the upper tier acres in 

alternative 2. None of these exceptions could be upgraded to a forest road. 

 

18 Further details about the exceptions listed in table 2-8 are in the rule §294.43.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 2. Alternatives, Including the Proposed Action—55

Table 2-9. Alternative 2, exceptions in which only temporary road construction and reconstruction 

would be allowed in Colorado Roadless Areas (also applies to Alternative 4)19

Descriptions of Exceptions

Where a temporary road is needed for public health and safety in cases of threat of flood, fire, or other potential 

catastrophic event that without intervention, would cause the loss of life or property. Does not apply to upper tier

acres.

Where the Regional Forester determines a temporary road is needed to facilitate tree-cutting, sale or removal to 

reduce the wildfire hazard to an at-risk community or municipal water supply system within the first one-half mile of a 

community protection zone. Does not apply to upper tier acres.

Where the Regional Forester determines a temporary road is needed to facilitate tree-cutting for maintenance and 

restoration of the characteristics of ecosystem composition, structure and processes within the first one-half mile of 

the community protection zone. Does not apply to upper tier acres.

Where a temporary road is needed in conjunction with exploration or development of an existing oil and gas lease 

that otherwise does not prohibit road construction or reconstruction, including construction of infrastructure necessary 

to transport the product on NFS lands, under an existing lease as of the effective date of this rule. (Alternative 2 CRA 

upper tier acres have no existing oil and gas leases.)

Where a temporary road is needed for coal exploration and coal-related activities on CRA lands in the North Fork 

coal mining area (shown on Map13 in the map packet). Such roads may be used for the purpose of collecting and 

transporting methane gas from coal mines. Buried infrastructure, including pipelines, needed for the capture, 

collection, and use of coal mine methane would be located within the rights-of-way of temporary roads that are 

otherwise necessary for coal-related surface activities including the installation and operation of methane venting 

wells. Alternative 2 CRA upper tier acres are not located in the North Fork coal mining area).

Linear Construction Zones (LCZs)

Alternative 2 generally prohibits LCZs within CRAs, but it does provide for limited exceptions 

to this general prohibition. There are required findings prior to the use of an LCZ that are 

detailed in a following section. 

The exceptions under which LCZs would be allowed are described in Table 2-10 under this 

alternative. The descriptions include some minor paraphrasing from the Colorado Roadless 

Rule for readability in this EIS. Readers may refer to the published rule language for additional 

detail. All exceptions are applicable to the CRA upper tier acres. 

Table 2-10. Alternative 2, exceptions in which linear construction zones would be allowed in 

Colorado Roadless Areas (also applies to Alternative 4)20

Description of Exceptions

Where the Regional Forester determines a linear construction zone is needed to allow for the construction, 

reconstruction, or maintenance of water conveyance structures operated pursuant to a pre-existing water court 

decree issued by the Colorado Water Courts prior to [final rule effective date] adjudicating as the point of a diversion 

or the place of use a location within a CRA.

Where the Regional Forester determines a linear construction zone is needed to allow for the construction, 

reconstruction, or maintenance of existing or future authorized electrical power lines or telecommunication lines. 

Authorize electrical power lines or telecommunication lines within CRAs only if there is no opportunity for the project 

to be implemented outside of a CRA without causing substantially greater environmental damage.

Where the Regional Forester determines a linear construction zone is needed to allow for the construction or 

reconstruction of a pipeline associated with an oil and gas lease that allows surface use within a CRA or the 

construction or reconstruction of a pipeline needed to connect to infrastructure within a CRA from outside a CRA 

where such a connection would cause substantially less environmental damage than alternative routes. The 

construction of pipelines for the purposes of transporting oil or natural gas through a CRA where the source(s) and 

destination(s) of the pipeline are located exclusively outside of a CRA shall not be authorized.

 

19 Further details about the exceptions listed in table 2-9 are in the rule §294.43.

20 Further details about the exceptions listed in table 2-10 are in the rule §294.44.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

56—Chapter 2. Alternatives, Including the Proposed Action

Required Findings Prior to Road Construction/Reconstruction or LCZ

Prior to any decision allowing construction or reconstruction of any type of road or 

development of an LCZ under any of the exceptions in a CRA, the following required findings 

must be made, through a site-specific project analysis, before the activity is allowed:

that the action is consistent with forest plan direction; and 

that motorized access for the project without road construction or an LCZ is not 

technically feasible; and

that if the action occurs within native cutthroat trout catchments or identified recovery 

watersheds, conditions within the water influence zone and the native cutthroat trout 

habitat would not be diminished over the long-term, and

that for a proposed forest road, a temporary road would not provide reasonable access.

Road Construction/Reconstruction and LCZ Considerations 

This alternative would require that specific considerations be incorporated into any road 

construction, road reconstruction, or LCZ project implemented within CRAs.

All road construction in a CRA must be conducted in a manner that reduces, to the 

extent practicable, effects on surface resources and prevents unnecessary or 

unreasonable surface disturbance. 

All roads constructed in CRAs under all exceptions would prohibit public motor vehicle 

use (including off-highway vehicles) unless specifically allowed for the purpose for 

which the road was established (e.g. Federal Highways). Nothing in the rule would 

prohibit:

o the use of motor vehicles for administrative use by the Forest Service; 

o motor vehicle use that is specifically authorized under a written authorization 

issued under Federal law or regulation; or 

o motor vehicle use by any fire, emergency, or law enforcement personnel. 

When a road is no longer needed (for the established purpose), or upon termination or 

expiration of a contract, authorization, or permit, whichever is sooner, all roads shall be 

decommissioned and the affected landscape restored. A road decommissioning provision shall 

be required in all such contracts or permits. Decommissioning would be designed to stabilize, 

restore, and revegetate unneeded roads to a more natural state to protect resources and enhance 

roadless area characteristics.

When an LCZ is constructed in a CRA, installation of the linear facility would be done in a 

manner that minimizes ground disturbance, including placement within existing right-of-ways 

where feasible. When the LCZ is no longer needed for the installation of the linear facility, any 

ground disturbance associated with the LCZ and the affected landscape would be restored. A 

restoration provision is required in all LCZ contracts or permits and would not be waived.

Additional Provisions

Table 2-11 describes additional provisions in the Colorado Roadless Rule that may influence 

management of CRAs. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 2. Alternatives, Including the Proposed Action—57

Table 2-11. Alternative 2, additional provisions for managing land uses within Colorado Roadless 

Areas (also applies to Alternative 4)21

Description of Additional Provisions

Each environmental analysis for oil and gas leasing shall consider eight listed items in determining conditions for 

inclusion in approved Surface Use Plans of Operation. These considerations apply to both existing oil and gas 

leases, under which some roads would be allowed and future oil and gas leases under which no roads would be 

allowed. These eight items are: 

(1) locate roads, well sites, and facilities on pre-existing areas of surface disturbance and minimize the amount of 

necessary temporary road construction or reconstruction; 

(2) include an alternative for proposed operations that addresses directional drilling on multi-well sites on preexisting disturbance; 

(3) restrict road construction for leases partially within CRAs to portions of the lease outside of CRAs except when 

doing so would be substantially more environmentally damaging, compromise safety standards, or is 

unfeasible due to topography or surface conditions; 

(4) perform reclamation of surface disturbances incrementally to minimize the total area of disturbance at any given 

point in time during the exploration or development of a lease; (5) design temporary roads and facilities to 

blend with the terrain to minimize visual impacts and to facilitate restoration when the road is no longer 

needed; 

(6) co-locate power lines, flow lines and pipelines within the right-of-way of roads to minimize the area of surface 

disturbance; 

(7) consider new and developing low impact techniques and technologies and either dismiss or apply with 

justification; and 

(8) utilize the best available technology, to the extent possible, to minimize noise and air emissions. 

Environmental documentation would be prepared for any proposed action in a CRA, pursuant to the National 

Environmental Policy Act (NEPA) and its implementing regulations at 40 CFR §1500-1508.

ALTERNATIVE 3: NO ACTION – FOREST PLAN DIRECTION 

Alternative 3 would manage IRAs and the remainder of the acres within the analysis area based 

on direction in the forest plans for the eight national forests. Forest plan direction is applied to 

the IRAs as well as to the 409,500 newly identified roadless acres included in the CRAs. 

Forest plan direction that applies to the management of roadless areas includes forest plan goals 

(desired conditions), objectives, forest-wide standards and guidelines, management area 

standards and guidelines, and descriptions of suitable uses. In each forest plan, roadless areas 

overlap a number of different land management allocations. Therefore, roadless areas would be 

managed under this alternative according to a mix of forest plan direction.

As previously described in Features Common to All Alternatives, forest plans may be updated 

through an amendment or revision process to reflect changed conditions or specific public or 

management needs. The National Forest Management Act (NFMA) requires forest plans to be 

revised at least every 15 years. Project-level amendments to forest plans may be made to make 

the forest plan consistent with a specific project if warranted. Subsequent forest plan 

amendments and revisions may result in changes to roadless area management direction. These 

acres could be subject to or affected by subsequent reinstatement, reconsideration, revision, or 

revocation of the 2001 Roadless Rule because this alternative does not establish a roadless rule. 

Roadless Areas

There is no specific direction for roadless areas in alternative 3. This RDEIS analyzes the effects 

of alternative 3 by looking at the IRAs of alternative 1 (4.24 million acres) as well as the 

 

21 Further details about the provisions listed in table 2-11 are in the rule §294.45 and §294.46.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

58—Chapter 2. Alternatives, Including the Proposed Action

remainder of the analysis area for a total of 4.65 million acres.

During a forest plan revision potential wilderness areas are inventoried following the Forest 

Service Handbook 1909.12 Chapter 70. The forest plan revision process includes a requirement 

to review each administrative unit for potential wilderness areas and evaluation of those areas 

as recommended wilderness. The process includes meeting requirements under NEPA and 

requirements for public participation. An inventory of unroaded areas is the first step toward 

identification of potential wilderness areas during forest plan revisions. 

Management of Inventoried Roadless Areas

The Arapaho-Roosevelt, Rio Grande, Routt, and White River National Forests have completed 

forest plan revisions. The GMUG, Manti-La Sal, and Pike-San Isabel National Forests are 

expected to revise their forest plans in the next five years. The San Juan National Forest is 

currently undergoing forest plan revision. In the past few years, the trend has been to allocate 

more roadless areas to management prescriptions that protect roadless area characteristics. 

In general, alternative 3 potentially allows for more road construction/reconstruction and treecutting, sale or removal in roadless areas compared to the other three alternatives. Generally 

there is no specific forest plan language restricting the use of LCZs. Appendix B contains a 

summary of current forest plan management direction for road construction and reconstruction 

and tree-cutting, sale or removal activities in roadless areas. Map 5 in the map packet shows 

alternative 3 with management direction for road construction, reconstruction, and tree-cutting 

activities.

Tree-cutting, Sale, or Removal

Under alternative 3, there is no general prohibition on tree-cutting, sale, or removal within the 

IRAs. Therefore, tree-cutting, sale, or removal would be allowed in IRAs anywhere those 

activities are not specifically prohibited or limited by forest-wide or management area direction 

in the applicable forest plan. 

Forest plan direction for tree-cutting, sale or removal generally falls into one of four categories: 

Tree-cutting, sale, or removal is generally prohibited except where needed for reserved 

and outstanding rights, or for other exemptions mandated by law, regulation, or policy. 

Examples of exemptions mandated by law, regulation, or policy include: tree-cutting to 

maintain roads or trails for safety purposes; removal of hazard trees; fire line 

construction for wildland fire suppression or control of prescribed fire; tree-cutting 

allowed under existing authorizations such as for developing ski runs or utility 

corridors; and others.

Tree-cutting, sale, or removal is generally restricted based on desired conditions or 

guidelines; not based on mandatory direction.

Tree-cutting, sale, or removal is generally not restricted except under some specific 

exceptions based on the purpose and need of the project or for the protection of specific 

resources. Examples include situations in which tree-cutting is limited to certain 

locations or conditions, such as to reduce wildland fire hazard or improve wildlife

habitat. 

Tree-cutting, sale, or removal is generally allowed as needed to meet multiple-use 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 2. Alternatives, Including the Proposed Action—59

management purposes. 

Although management direction in the forest plans regarding tree-cutting differs by national 

forest, some direction is common among plans. Common to all forest plans, tree-cutting for 

hazardous fuel reduction or wildlife habitat improvement may occur on NFS lands that are 

considered unsuitable for timber production. Also common to all forest plans, tree-cutting for 

primarily timber production purposes is limited to NFS land identified as suitable for timber 

production. 

Road Construction and Reconstruction

Alternative 3 follows forest plan direction and Forest Service directives and regulations for road 

construction and reconstruction. The directives discourage construction of new forest 

(permanent) roads and require responsible officials to minimize the miles of forest roads to 

those determined to be necessary. Furthermore, the directives encourage use of temporary 

roads when permanent forest roads are not necessary. The responsible official may consider 

temporary road construction only after reviewing other access options, and such roads must be 

constructed in a manner that minimizes effects on surface resources, prevents unnecessary or 

unreasonable surface disturbances, and complies with all applicable forest plan direction, 

regulations and laws. When temporary roads are no longer needed, or upon termination or 

expiration of the lease, contract, or permit, whichever is sooner, those roads must be 

decommissioned and the affected landscape restored to a more natural state. These road 

construction and decommissioning policies associated with alternative 3 are generally the same 

as those described for the other alternatives. 

In addition to those road system management requirements just described, forest plan direction 

for road construction and reconstruction generally falls into one of four categories: 

Road construction/reconstruction is generally prohibited except where needed for 

reserved and outstanding rights or other exemptions mandated by law, regulation, or 

policy. 

Road construction/reconstruction is generally restricted based on a desired condition 

or guideline; not a mandatory restriction. 

Road construction/reconstruction is generally not restricted except under some specific 

exceptions based on the purpose of and need for the road, or road density limitations, or 

protection of natural resource values.

Road construction/reconstruction is generally allowed for any multiple-use 

management need, where consistent with law, regulation, or policy.

Alternative 3 differs from the other three alternatives in that it does not include a general 

prohibition on road construction or reconstruction or the construction of LCZs. Road 

construction in these roadless areas would be prohibited or limited only where there is specific 

forest plan direction. Map 5 in the map packet shows alternative 3 with management direction 

for road construction, reconstruction, and tree-cutting activities. 

Linear Construction Zones (LCZs)

Forest plans are usually silent on LCZs but certain management areas may limit the placement 

of linear features or provide direction to follow to protect resource values when proposing a 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

60—Chapter 2. Alternatives, Including the Proposed Action

linear feature and corresponding LCZ. 

ALTERNATIVE 4: COLORADO ROADLESS RULE WITH PUBLIC 

PROPOSED UPPER TIER

Alternative 4 has the same general prohibitions as alternative 2 on tree-cutting, sale or removal, 

road construction/reconstruction, and LCZs within CRAs, while permitting those activities 

under certain exceptions to address State and local land management needs (see Tables 2-6 

through 2-11). Identical to alternative 2, substantially altered acres within the IRAs have been 

removed from the CRA inventory and would be managed following forest plan direction. 

Identical to alternative 2, road construction and tree-cutting, sale or removal would be restricted 

within CRAs.

The only difference between alternative 4 and alternative 2 is that alternative 4 designates 

2,614,200 acres as CRA upper tier acres.22 Some, but not all of the alternative 2 upper tier acres 

are upper tier acres in alternative 4. Under this alternative, a portion of the CRA upper tier acres 

contain existing oil and gas leases that allow roads. The eight items listed in Table 2-11 for 

inclusion in Surface Use Plans of Operation in the development of oil and gas leases would also 

apply to this alternative. 

 

22 Further details on the CRA upper tier acres in alternative 4 are found in Appendix C and Map 6 in the map 

packet.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 2. Alternatives, Including the Proposed Action—61

Table 2-12. Upper Tier CRAs by Forest designated under Alternative 4

Forest Total Upper 

Tier Acres

Upper Tier 

Acres 

Overlap with 

562,200 in 

Alternative 2

% of 

Forest 

CRA 

Acres

Arapaho-Roosevelt 198,500 84,000 57%

GMUG 544,900 81,800 60%

Manti-La Sal 7,700 - 100%

Pike-San Isabel 312,900 - 40%

Rio Grande 323,500 - 62%

Routt 362,000 14,600 83%

San Juan 482,000 118,200 85%

White River 382,700 36,000 60%

Colorado 2,614,200 334,700 62%

Numbers may not add due to rounding.

COMPARISON OF ALTERNATIVES

This section provides a comparative summary of each alternative from two perspectives. Table 

2-13 compares each alternative by key elements of the proposed rule. Because the management 

direction in alternative 2 and 4 are the same, the table refers to both in the same column. 

Management direction relating to tree-cutting and road construction is more restrictive within 

Colorado Roadless Areas upper tier acres in alternatives 2 and 4 and the differences are noted 

within the column. Table 2-14 compares the estimated consequences of each alternative, 

summarized from the environmental consequences described in detail in chapter 3. The 

comparison tables focus on the key differences between the alternatives and their most likely 

consequences. Because the proposed rulemaking and its alternatives are broad and 

programmatic, and do not involve any proposed site-specific actions, the consequences are 

appropriately broad and qualitative rather than quantitative. In the few places where the 

alternatives differ, it is noted. All other management direction in these two alternatives is the 

same in the Colorado Roadless Areas, whether in the upper tier acres or not. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

62—Chapter 2. Alternatives, Including the Proposed Action

Table 2-13. Comparison of alternatives

Descriptor Alternative 1 – Provisions of the 2001 

Roadless Rule

Alternative 2 – Proposed Action

Colorado Roadless Rule; 

Alternative 4 – Colorado Roadless 

Rule with Public Proposed Upper Tier

Alternative 3 – No Action

Forest Plans

Overview and Where Alternative Applies

Roadless area management 

direction

The management of roadless areas on NFS

lands in Colorado would be governed by 

provisions of the 2001 Roadless Rule and 

by any additional limitations imposed by 

forest plans. 

Management of roadless areas on NFS

lands in Colorado would be governed by 

provisions of the Colorado Roadless 

Rule and by any additional limitations 

imposed by forest plans. 

Management of roadless areas on

NFS lands in Colorado would be 

governed exclusively by the 

applicable management direction in 

forest plans.

Roadless areas 4.24 million acres of IRAs established by the 

2001 Roadless Rule, excluding 185,000 

acres of wilderness and other 

congressionally designated acres as well as 

correcting mapping errors to remove areas 

identified as wilderness or private land from 

the inventory. 

4.19 million acres of CRAs that stem 

from the IRAs established by the 2001 

Roadless Rule, excluding 185,000 acres 

of wilderness and other congressionally 

designated acres, and modified by 

correcting map errors and updating NFS

land boundaries. 

Removing 8,300 acres of allocated ski 

areas and 458,800 substantially altered

areas.

Adding 409,500 acres of unroaded lands 

meeting roadless area criteria.

Designating portions of or entire CRAs 

as upper tier acres.

Designating 562,200 acres as upper tier

in alternative 2.

Asking for comment on CRA upper tier in 

alternatives 2 and 4.

IRAs and CRAs are managed 

according to forest plan direction.

Changes to roadless area 

boundaries

Currently there is no process for changing 

IRA boundaries.

Provides a process for the Forest 

Service to make changes to CRA 

boundaries. Changes are subject to 

public review and comment. 

Roadless inventories completed 

during forest plan revision process, 

subject to public review and 

comment, and other NFMA and 

NEPA regulations.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 2. Alternatives, Including the Proposed Action—63

Descriptor Alternative 1 – Provisions of the 2001 

Roadless Rule

Alternative 2 – Proposed Action

Colorado Roadless Rule; 

Alternative 4 – Colorado Roadless 

Rule with Public Proposed Upper Tier

Alternative 3 – No Action

Forest Plans

Comparison of Tree-cutting, Sale, or Removal by Alternative

General tree-cutting, sale, and 

removal provisions 

Tree-cutting, sale, or removal, is generally 

prohibited in roadless areas, with some 

exceptions (see below). 

In some IRAs forest plans add more 

restrictions related to conducting this

activity, to protect other resource values. 

Tree-cutting for all exceptions is expected to 

be infrequent.

Similar to the general prohibition in 

alternative 1, although there are more 

exceptions under this alternative (see 

below). An additional limitation is that the

Responsible Official must determine the 

activity is consistent with the forest plan

and one or more of the roadless area 

characteristics would be maintained or 

improved over the long-term except 

when tree-cutting is for incidental, 

personal or administrative uses. In some 

CRAs, forest plans add more restrictions 

related to conducting this activity to 

protect other resource values.

In some IRAs tree-cutting is 

prohibited or limited to protect 

resource values.

Forest plans in Colorado generally 

allow tree-cutting for non-timber

purposes on any NFS lands, subject 

to specific resource management 

direction. 

Forest plans identify lands suitable for 

timber harvest for timber production 

purposes.

Tree-cutting, sale, or removal for 

incidental, personal, 

administrative uses

This activity is allowed in IRAs:

Where incidental to other management 

activities (e.g., road or trail construction or 

maintenance, minerals operations, and other 

authorized uses).

For personal or administrative uses, as 

provided for in 36 CFR part 223 (e.g., 

firewood, Christmas trees).

Same as alternative 1 within CRAs 

including upper tier acres. 

Same as alternative 1.

Tree-cutting, sale, or removal in 

substantially altered areas

This activity is not rule-limited in 

substantially altered areas in IRAs and is 

only limited by applicable management 

direction in forest plans.

Substantially altered acres have been 

removed from CRAs and are only limited 

by applicable management direction in 

forest plans. 

This activity is only limited by 

applicable management direction in 

forest plans.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

64—Chapter 2. Alternatives, Including the Proposed Action

Descriptor Alternative 1 – Provisions of the 2001 

Roadless Rule

Alternative 2 – Proposed Action

Colorado Roadless Rule; 

Alternative 4 – Colorado Roadless 

Rule with Public Proposed Upper Tier

Alternative 3 – No Action

Forest Plans

Tree-cutting to maintain or 

restore ecosystem composition 

and structure within the range of 

variability expected to occur 

under natural disturbance 

regimes of the current climatic 

period

An example of this activity given in the rule 

is to reduce the risk of wildfire effects but 

could have other purposes.

Generally small-diameter trees and would

maintain or improve one or more roadless 

area characteristics.

This exception can also include treatments 

for prevention or suppression of insect and 

diseases in order to maintain or restore 

ecosystem characteristics.

Not allowed within CRA upper tier acres

Language simplified and updated to take 

into account climate change: ―to maintain 

or restore characteristics of ecosystem

composition, structure and processes‖. 

These are infrequent.

This exception can also include 

treatments for prevention or suppression 

of insect and diseases in order to 

maintain or restore ecosystem

characteristics.

Tree-cutting is only limited by 

applicable management direction in 

forest plans.

Tree-cutting, sale, or removal for 

habitat improvement 

This activity is allowed in IRAs to improve 

habitat for threatened, endangered, 

proposed, or sensitive species, and to 

maintain or improve roadless area 

characteristics.

Limited to generally small-diameter trees 

and would maintain or improve one or more 

roadless area characteristics

Not allowed within CRA upper tier acres.

This activity is allowed in CRAs to 

improve habitat for threatened, 

endangered, proposed, or Regionally 

designated sensitive species in 

coordination with the Colorado 

Department of Natural Resources 

including the Colorado Division of 

Wildlife.

Not limited to generally small diameter 

trees.

Forest plans generally allow treecutting in IRAs to improve habitat for 

all species including threatened, 

endangered, proposed, Regionally 

designated sensitive species or other 

species. 

Tree-cutting, sale, or removal to 

reduce wildland fire hazard

This activity is allowed in IRAs, to maintain 

or restore ecosystem composition and 

structure, such as to reduce the risk of 

uncharacteristic wildland fire effects, within 

the range of variability expected to occur 

under natural disturbance regimes of the 

current climatic period, and would maintain 

or improve roadless area characteristics.

Limited to generally small-diameter trees 

and prohibits associated road 

construction/reconstruction.

This activity is not allowed on upper tier

acres within CRAs

On acres within CRAs that are not upper 

tier, this activity is allowed where the 

Regional Forester determines it is 

needed to reduce wildland fire hazard to 

an at-risk community or municipal water 

supply system

Within the first 1⁄2 mile of the CPZ; 

Within the next one-mile of the CPZ

where projects would be within the area 

of a Community Wildfire Protection Plan. 

If no CWPP exists, no projects would be 

proposed in this next one-mile. For the 

CPZ to extend beyond the first 1⁄2 mile 

Forest plans allow tree-cutting in 

most IRAs for purposes described in 

alternatives 1 or 2, with exceptions in 

some specific management areas.

Not limited to generally smalldiameter trees, and does not 

preclude associated road 

construction/reconstruction except as 

precluded by specific forest plan

direction.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 2. Alternatives, Including the Proposed Action—65

Descriptor Alternative 1 – Provisions of the 2001 

Roadless Rule

Alternative 2 – Proposed Action

Colorado Roadless Rule; 

Alternative 4 – Colorado Roadless 

Rule with Public Proposed Upper Tier

Alternative 3 – No Action

Forest Plans

and up to an additional one-mile, the 

land must exhibit one of the following 

characteristics: a sustained steep slope

that creates the potential for wildfire

behavior endangering the at-risk 

community; has a geographic feature 

that aids in creating an effective fire 

break, such as a road or a ridge top; or 

is in condition class 3 as defined by 

Healthy Forest Restoration Act (Pub. L. 

108–148).

On acres within CRAs outside of the 

CPZ this activity is allowed where the 

Regional Forester has determined there 

is a significant risk that a wildland fire 

disturbance event could affect a 

municipal water supply system or the 

maintenance of the system. A significant 

risk exists where the history of fire 

occurrence and fire hazard indicate a 

serious likelihood that a wildland fire 

disturbance event would have adverse 

effects to a municipal water supply

system.

Such projects would focus on small 

diameter trees to create strategic fuel

breaks that modify fire behavior while 

large trees would be retained to the 

extent practical, as appropriate to the 

forest type, 

Projects outside of the CPZ are 

expected to be infrequent. 

Tree-cutting, sale or removal 

within newly designated roadless 

areas

These acres are not within the IRA 

inventory.

No regulatory limitation on tree-cutting, sale 

or removal

These acres are within the CRA 

inventory

Tree-cutting, sale or removal is subject 

to the prohibitions in the Colorado 

Roadless Rule

These acres are not within the IRA 

inventory

These acres remain subject to forest 

plan direction
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

66—Chapter 2. Alternatives, Including the Proposed Action

Descriptor Alternative 1 – Provisions of the 2001 

Roadless Rule

Alternative 2 – Proposed Action

Colorado Roadless Rule; 

Alternative 4 – Colorado Roadless 

Rule with Public Proposed Upper Tier

Alternative 3 – No Action

Forest Plans

Comparison of Road Construction and Reconstruction and Linear Construction Zones by Alternative

General road construction 

provisions

Generally prohibits road construction or 

reconstruction in IRAs. Exceptions do not 

distinguish between forest roads and

temporary roads.

Rule language does not include additional 

requirements for environmental analysis or 

NEPA documentation.

Does not include specific provisions about 

decommissioning and closing roads. 

Does not include provisions about closing 

roads to public motorized use.

Generally prohibits road construction or 

reconstruction in CRAs, distinguishing 

between forest roads and temporary 

roads. 

Includes additional environmental 

analysis and determination requirements 

for road construction determining that:

motorized access without road 

construction is not technically feasible; 

within a native cutthroat trout catchment

or identified recovery watershed, road 

construction would not diminish 

conditions in the water influence zone

and in the native cutthroat habitat over 

the long-term;

road construction is consistent with the 

applicable forest plan; 

when proposing to build a forest road, a 

temporary road would not provide 

reasonable access. 

Includes specific provisions about 

decommissioning and closing roads. 

Roads are closed to public motorized

use.

Forest plans include some IRAs 

where roads are generally prohibited. 

Some forest plan direction 

distinguishes between temporary and 

forest roads, and provides other 

direction to follow to protect resource 

values when proposing road 

construction.

Does not include additional 

environmental analysis requirements 

for road construction.

Includes some specific direction 

about road decommissioning.

Some plans include some direction 

about road closures to public use for 

protection of resource values in 

specific areas.

Road construction in ski areas Road construction or reconstruction is 

limited to within ski area permit boundaries 

established prior to [the effective date of this 

rule] (~6,600 acres).

The 8,300 acres of permitted and allocated 

to ski areas within IRAs remain within IRAs.

No rule-related limitations on road 

construction or reconstruction in 

permitted or forest plan-allocated ski 

areas (~8,300 acres). Ski areas remain 

subject to forest plan direction.

Ski areas are excluded from CRAs. 

Road construction allowed in these 

management areas.

Roads construction in 

substantially altered lands 

(~458,800 acres)

Road construction or reconstruction on 

substantially altered lands in IRAs is 

prohibited. 

Substantially altered acres remain in the 

IRAs. 

These acres are excluded from CRAs.

No rule-related limitations on road 

construction or reconstruction on the 

substantially altered lands; remain 

subject to forest plan direction.

Generally road construction is 

allowed in these management areas. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 2. Alternatives, Including the Proposed Action—67

Descriptor Alternative 1 – Provisions of the 2001 

Roadless Rule

Alternative 2 – Proposed Action

Colorado Roadless Rule; 

Alternative 4 – Colorado Roadless 

Rule with Public Proposed Upper Tier

Alternative 3 – No Action

Forest Plans

Road construction in newly 

identified roadless acres 

(~409,500 acres)

These acres are not within the IRAs. 

No rule-related limitations on road 

construction or reconstruction on the newly 

identified roadless acres; remain subject to 

forest plan direction.

These acres are within the CRAs.

Road construction or reconstruction on 

newly identified roadless acres subject to 

provisions within the rule.

These areas are not within the IRAs.

Road construction direction varies 

based on management designations 

within these areas. 

Road construction pursuant to 

reserved or outstanding rights or 

as provided by statute or treaty

Support actions covered by laws or treaties, 

including those for purposes of CERCLA,

Federal Highway Projects (23 USC), and 

locatable mineral operations (General 

Mining Law of 1872, as amended).

Same as alternative 1 within CRAs and 

upper tier acres.

Same as alternative 1.

Road construction for public 

health & safety and resource 

protections 

Road construction or reconstruction is 

allowed in IRAs where needed to: 

Prevent irreparable resource damage.

Address road safety hazards

Protect public safety from imminent threat of 

flood, fire, and other catastrophic events that 

may threaten loss of life or property.

Not allowed in upper tier.

Same as alternative 1 within standard 

tier and additionally:

Only temporary roads may be 

constructed or reconstructed as needed 

for public health and safety in cases of 

threat of flood, fire, and catastrophic 

events that without intervention may 

cause loss of life or property.

Additional environmental analysis and 

implementation requirements as noted 

above in general road provisions.

Same as alternative 1, per agency 

regulations and policy directives.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

68—Chapter 2. Alternatives, Including the Proposed Action

Descriptor Alternative 1 – Provisions of the 2001 

Roadless Rule

Alternative 2 – Proposed Action

Colorado Roadless Rule; 

Alternative 4 – Colorado Roadless 

Rule with Public Proposed Upper Tier

Alternative 3 – No Action

Forest Plans

Road construction for leasable 

minerals operations, specifically 

oil and gas

Road construction or reconstruction in IRAs 

related to oil and gas exploration and 

development is limited to roads needed 

pursuant to rights granted under an existing 

lease (issued prior to the effective date of 

the Colorado Rule) where lease stipulations 

and other regulations allow. Forest or 

temporary roads could be constructed.

Road construction is prohibited on leases 

within IRAs issued after (the effective date of 

the Colorado Rule)

Road construction or reconstruction in 

CRAs related to oil and gas exploration 

and development is limited to roads 

needed pursuant to rights granted under 

an existing lease (issued prior to the 

effective date of the Colorado Rule) 

where lease stipulations and other 

regulations allow. Roads are temporary 

roads.

Road construction is prohibited on 

leases within CRAs issued after (the 

effective date of the Colorado Rule)

Eight conditions are to be considered for 

inclusion in approved Surface Use Plans 

of Operation.

Alternative 2 has no oil and gas leases 

within the upper tier acres. 

Alternative 4 upper tier acres include 

current oil and gas leases where road 

construction could occur if allowed by 

lease terms and considering eight 

conditions for inclusion in approved 

Surface Use Plans of Operation. 

Leasing stipulations from oil and gas

leasing decisions may constrain 

surface occupancy and use in IRAs to 

protect resources, and include 

reclamation requirements and other 

resource protection measures. Future 

leases are possible based on forest 

plans or oil and gas leasing 

decisions. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 2. Alternatives, Including the Proposed Action—69

Descriptor Alternative 1 – Provisions of the 2001 

Roadless Rule

Alternative 2 – Proposed Action

Colorado Roadless Rule; 

Alternative 4 – Colorado Roadless 

Rule with Public Proposed Upper Tier

Alternative 3 – No Action

Forest Plans

Roads for leasable coal

operations

Road construction or reconstruction in IRAs 

for coal exploration and development are 

limited to areas under an existing lease 

(issued prior to the effective date of the 

Colorado Rule). This includes 5,900 acres 

within IRAs. 

No rule related language on location of 

buried infrastructure needed for capture, 

collection, and use of coal mine methane.

No regulatory prohibition on the use of roads 

constructed or reconstructed for purpose of 

collecting and transporting coal mine 

methane

Road construction or reconstruction in 

CRAs is allowed for coal exploration and 

development in existing lease areas, and 

in future lease areas within the North 

Fork coal mining area (20,000 acres). 

This includes 4,000 acres currently 

leased in the North Fork coal mining

area. 

Roads constructed or reconstructed for 

coal exploration or coal related surface 

activities may also be used for the 

purpose of collecting and transporting 

coal mine methane in the North Fork 

coal mining area when authorized under 

a gas lease.

Roads are temporary roads.

Buried infrastructure needed for capture, 

collection, and use of coal mine methane 

would be located within road rights-ofway.

No CRA upper tier acres in either 

alternative are located in the North Fork 

coal mining area.

Current forest plan direction does not 

limit road-building in areas where coal

resources exist.

Forest plans include management 

direction for areas where coal

resources exist to protect sensitive 

surface resources.

Current forest plan direction does not 

limit location of buried infrastructure.

Road construction for water 

conveyance facilities

Road construction or reconstruction related 

to water conveyances is limited in IRAs to 

areas under an existing permit (issued prior 

to effective date of Colorado Rule). Road 

construction or reconstruction is not allowed 

for future water conveyance structures.

The Regional Forester determines road 

construction or reconstruction is needed 

related to authorized water conveyance 

structures operated pursuant to a preexisting water court decree (issued prior 

to effective date of Colorado Rule). 

Water conveyances are defined as 

facilities associated with the 

transmission, storage, impoundment, 

and diversion of water on and across 

NFS lands.

Not allowed within CRA upper tier acres.

Road construction/reconstruction 

activities in IRAs would be governed 

by forest plan direction. 

Forest plan direction includes areas 

where road construction is prohibited,

limited, discouraged, or unrestricted. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

70—Chapter 2. Alternatives, Including the Proposed Action

Descriptor Alternative 1 – Provisions of the 2001 

Roadless Rule

Alternative 2 – Proposed Action

Colorado Roadless Rule; 

Alternative 4 – Colorado Roadless 

Rule with Public Proposed Upper Tier

Alternative 3 – No Action

Forest Plans

Road construction for reducing 

wildland fire hazards

Construction or reconstruction of a road is 

not allowed in IRAs to reduce wildland fire 

hazard to at-risk communities.

Construction or reconstruction of a 

temporary road is allowed with Regional 

Forester determination to facilitate treecutting, sale or removal within the first 

one-half mile of the CPZ to reduce the 

wildfire hazard to an at-risk community

or municipal water supply.

Not allowed within CRA upper tier

acres.

Road construction/reconstruction 

activities would be governed by forest 

plan direction, which varies by 

management area. 

Road construction to facilitate 

maintenance and restoration of 

ecosystem characteristics.

Construction or reconstruction of a road is 

not allowed in IRAs for maintenance and 

restoration of ecosystem characteristics.

Construction or reconstruction of a 

temporary road is allowed with Regional 

Forester determination to facilitate treecutting, sale or removal within the first 

one-half mile of the CPZ to maintain or 

restore ecosystem characteristics.

Not allowed within CRA upper tier acres.

Road construction/reconstruction 

activities would be governed by forest 

plan direction, which varies by 

management area.

General linear construction zone

provisions (LCZs)

Does not include any prohibition on LCZs

Does not include additional environmental 

analysis requirements for LCZs.

Does not include specific provisions about 

decommissioning and closing LCZs. 

Generally prohibits LCZs in CRAs. 

Includes additional environmental 

analysis and determination requirements 

for LCZs determining that:

motorized access without LCZs is not 

technically feasible; 

within a native cutthroat trout catchment

or identified recovery watershed, an LCZ

would not diminish conditions in the 

water influence zone and in the native 

cutthroat habitat over the long-term;

an LCZ is consistent with the applicable 

forest plan; 

Includes specific provisions about 

decommissioning and closing LCZs. 

Standard and upper tier provisions the 

same. 

Some Forest plans provide direction 

to follow to protect resource values 

when proposing the use of an LCZ.

Does not include additional 

environmental analysis requirements 

for LCZs. 

Does not include specific provisions 

about decommissioning and closing 

LCZs. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 2. Alternatives, Including the Proposed Action—71

Descriptor Alternative 1 – Provisions of the 2001 

Roadless Rule

Alternative 2 – Proposed Action

Colorado Roadless Rule; 

Alternative 4 – Colorado Roadless 

Rule with Public Proposed Upper Tier

Alternative 3 – No Action

Forest Plans

LCZs for water conveyance 

structures

No rule-related prohibition on LCZs. The Regional Forester determines an 

LCZ is needed related to an authorized 

water conveyance structure operated 

pursuant to a pre-existing water court 

decree (issued prior to effective date of 

Colorado Rule). Water conveyances are 

defined as facilities associated with the 

transmission, storage, impoundment, 

and diversion of water on and across 

NFS lands. 

Generally forest plan direction does 

not limit the use of LCZs.

LCZs for electrical power lines

and telecommunication lines

No rule-related prohibition on LCZs or 

location of electrical power lines or 

telecommunication lines.

Construction or an LCZ, with Regional 

Forester determination, based on a sitespecific NEPA analysis, is allowed for 

the construction, reconstruction, or 

maintenance of existing or future 

authorized electrical power lines and 

telecommunication lines where it has 

been determined such utility lines cannot 

be located outside of a CRA without 

causing substantially greater 

environmental damage. 

Generally forest plan direction does 

not limit the use of LCZs or the 

location of electrical power lines or 

telecommunication lines.

Use of an LCZs for construction 

or reconstruction of an oil and 

gas pipeline 

There is no rule-related language prohibiting 

the use of an LCZ for this purpose.

Where the Regional Forester determines 

a linear construction zone is needed to 

allow for the construction or 

reconstruction of a pipeline associated 

with an oil and gas lease that allows 

surface use within a CRA or the 

construction or reconstruction of a 

pipeline needed to connect to 

infrastructure within a CRA from outside 

a CRA where such a connection would 

cause substantially less environmental 

damage than alternative routes. 

Generally forest plan direction does 

not limit the use of LCZs. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

72—Chapter 2. Alternatives, Including the Proposed Action

Descriptor Alternative 1 – Provisions of the 2001 

Roadless Rule

Alternative 2 – Proposed Action

Colorado Roadless Rule; 

Alternative 4 – Colorado Roadless 

Rule with Public Proposed Upper Tier

Alternative 3 – No Action

Forest Plans

Other Requirements for Management of Roadless Areas in Colorado

Oil and gas pipelines where the 

source(s) and destination(s) of 

the oil and natural gas is not 

within the roadless area

No prohibition on oil or gas pipelines through 

IRAs from sources outside IRAs.

The construction of pipelines for the 

purposes of transporting oil or natural 

gas through a CRA where the source(s) 

and destination(s) of the pipeline are 

located exclusively outside of a CRA 

shall not be authorized. 

Forest plans generally allow oil or gas 

pipelines through IRAs from sources 

outside IRAs
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 2. Alternatives, Including the Proposed Action—73

Table 2-14. Comparison of alternatives by environmental consequences (refer to chapter 3 for details)23

Issue or Affected Resource

Alternative 1

Provisions of the 2001 

Roadless Rule

Alternative 2

Proposed Action

Colorado Roadless Rule

Alternative 3

No Action

Forest Plans

Alternative 4 

Colorado Roadless Rule

Fire and Fuels 1,800 acres in the analysis 

area have projected treecutting activities to reduce 

hazardous fuels each year 

(900 acres within IRAs).

Least flexibility to conduct 

hazardous fuel reduction and 

reduce fire risk to 

communities and municipal 

water supply systems.

5,900 acres in the analysis 

area have projected treecutting activities to reduce 

hazardous fuels each year 

(5,300 acres within CRAs).

Medium flexibility to conduct 

hazardous fuel reduction and 

reduce fire risk to 

communities and municipal 

water supply systems.

Unable to conduct hazardous 

fuels reduction on 12% of 0.5 

mile CPZ and 13% of 1.5 mile 

CPZ due to upper tier acre 

prohibitions.

13,100 acres in the analysis 

area have projected treecutting activities to reduce 

hazardous fuels each year.

Greatest flexibility to conduct 

hazardous fuel reduction and 

reduce fire risk to 

communities and municipal 

water supply systems.

2,200 acres in the analysis 

area have projected treecutting activities to reduce 

hazardous fuels each year 

(1,600 acres within CRAs).

Within the CRAs that are not 

upper tier acres, the flexibility 

to conduct hazardous fuel

reduction and reduce fire risk 

to communities and municipal 

water supply systems is 

identical to alternative 2.

Unable to conduct hazardous 

fuels reduction on 48% of 0.5 

mile CPZ and 52% of 1.5 mile 

CPZ due to upper tier acre 

prohibitions; 

Ecosystem Composition, 

Structure and Processes

500 acres per year in the 

analysis area have projected 

tree-cutting activities for forest 

health purposes (300 acres

within IRAs).

Fewest opportunities to 

maintain and restore 

ecosystem characteristics, 

including resilience to insect 

and disease outbreaks and 

climate induced stressors.

1,000 acres per year in the 

analysis area have projected 

tree-cutting activities for forest 

health purpose (400 acres

within CRAs).

More opportunities than 

alternatives 1 and 4, but fewer 

opportunities than alternative 

3 to maintain and restore 

ecosystem characteristics, 

including resilience to insect 

and disease outbreaks and 

climate induced stressors.. 

Unable to treat upper tier

acres.

3,500 acres per year within 

the analysis area have 

projected tree-cutting 

activities for forest health

purposes.

Greatest opportunities to to 

maintain and restore 

ecosystem characteristics, 

including resilience to insect 

and disease outbreaks and 

climate induced stressors.

800 acres per year in the 

analysis area have projected 

tree-cutting activities for forest 

health purposes (200 acres

within CRAs).

More opportunities to maintain 

and restore ecosystem

characteristics, including 

resilience to insect and 

disease outbreaks and climate 

induced stressors than 

alternative 1 but less than 

alternative 3 and alternative 2 

due to upper tier acres.

Aquatic Species and Habitat Least risk for adverse impacts 

on aquatic species.

More risk than alternatives 1 

and 4, less than alternative 3 

for adverse impacts on 

Greatest risk of adverse 

impacts on aquatic species.

Less risk for adverse impacts 

on aquatic species than 

alternatives 2 and 3; greater 

 

23 The analysis area is all acres within either the IRAs or the CRAs, or acres that are common between the two and are within both the IRAs and the CRAs. This 

totals 4,653,100 acres. Table 3-1 explains this in more detail. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

74—Chapter 2. Alternatives, Including the Proposed Action

Issue or Affected Resource

Alternative 1

Provisions of the 2001 

Roadless Rule

Alternative 2

Proposed Action

Colorado Roadless Rule

Alternative 3

No Action

Forest Plans

Alternative 4 

Colorado Roadless Rule

Site specific design criteria 

and mitigation measures are 

expected to minimize risk.

aquatic species. 

Site specific design criteria 

and mitigation measures are 

expected to minimize risk.

Site specific design criteria 

and mitigation measures are 

expected to minimize risk.

risk than alternative 1. 

Site specific design criteria and 

mitigation measures are 

expected to minimize risk.

Threatened Endangered or 

Sensitive Plants

No adverse impacts to 

threatened or endangered 

plants because no road 

construction or tree-cutting, 

sale or removal is projected to 

occur where threatened or 

endangered plants exist.

Least risk to adverse impacts 

to sensitive plants

Site specific design criteria 

and mitigation measures are 

expected to minimize risk.

No adverse impacts to 

threatened or endangered 

plants because no road 

construction or tree-cutting, 

sale or removal is projected to 

occur where threatened or 

endangered plants exist.

More risk of adverse impacts 

to sensitive plants than 

alternatives 1 or 4; less than 

alternative 3.

Site specific design criteria 

and mitigation measures are 

expected to minimize risk.

No adverse impacts to 

threatened or endangered 

plants because no road 

construction or tree-cutting, 

sale or removal is projected to 

occur where threatened or 

endangered plants exist.

Greatest risk of adverse 

impacts to sensitive plants.

Site specific design criteria 

and mitigation measures are 

expected to minimize risk.

No adverse impacts to 

threatened or endangered 

plants because no road 

construction or tree-cutting, 

sale or removal is projected to

occur where threatened or 

endangered plants exist.

More risk of adverse impacts 

to sensitive plants than 

alternative 1; less than 

alternatives 2 or 3.

Site specific design criteria and 

mitigation measures are 

expected to minimize risk.

Economics Average annual jobs 

associated with –

Oil/gas drilling = 489 jobs

Oil/gas production = 360 jobs

Coal production = 1,033 jobs

Average annual labor income

associated with –

Oil/gas drilling = $25.3 million

Oil/gas production =$ 24.6

million

Coal production = $75.2 

million

Average annual value of 

production associated w/ –

Oil/gas drilling = $156.9 

million

Oil/gas production = $269.4 

million

Coal production = $305.9 

Average annual jobs 

associated with –

Oil/gas drilling = 489 jobs

Oil/gas production = 360 jobs

Coal production = 1,912 jobs

Average annual labor income

associated with –

Oil/gas drilling = $25.3 million

Oil/gas production =$ 24.6 

million

Coal production = $139.1 

million

Average annual value of 

production associated w/ –

Oil/gas drilling = $156.9 

million

Oil/gas production = $269.4 

million

Coal production = $566.2 

Average annual jobs 

associated with –

Oil/gas drilling = 553 jobs

Oil/gas production = 406 jobs

Coal production = 1,912 jobs

Average annual labor income

associated with –

Oil/gas drilling = $28.6 million

Oil/gas production =$ 27.8 

million

Coal production = $139.1 

million

Average annual value of 

production associated w/ –

Oil/gas drilling = $177.6 

million

Oil/gas production = $303.9 

million

Coal production = $566.2 

Average annual jobs 

associated with –

Oil/gas drilling = 489 jobs

Oil/gas production = 360 jobs

Coal production = 1,912 jobs

Average annual labor income

associated with –

Oil/gas drilling = $25.3 million

Oil/gas production =$ 24.6 

million

Coal production = $139.1 

million

Average annual value of 

production associated w/ –

Oil/gas drilling = $156.9 million

Oil/gas production = $269.4 

million

Coal production = $566.2 

million
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 2. Alternatives, Including the Proposed Action—75

Issue or Affected Resource

Alternative 1

Provisions of the 2001 

Roadless Rule

Alternative 2

Proposed Action

Colorado Roadless Rule

Alternative 3

No Action

Forest Plans

Alternative 4 

Colorado Roadless Rule

million million million

No difference expected between alternatives at the State level in recreation, tourism, or wood products due to the lack of project 

specific data needed for analysis, and the ability to substitute sites and resources at the larger, State-wide scale.

Soils No major difference among alternatives related to the risk of soil impacts. Alternatives 1 and 4 would have the least risk of adverse 

effects, and alternative 2 would have a slightly higher risk, followed by alternative 3. However, these differences are insignificant 

because they would be small in magnitude and spread over a wide geographic area. Most of the potential effects would be 

mitigated by site-specific mitigation measures. The risk of post-fire soil erosion may be higher under alternative 1 and lowest under 

alternative 3 as a result of projected levels of fuel treatments. 

Developed Ski Areas Least opportunities for ski 

area development and 

expansion.

6,600 acres within the IRA 

boundaries and under permit 

prior to the effective date of 

rulemaking would allow for 

road construction and treecutting, sale or removal.

Forest Plan allocations for ski 

areas outside of existing 

permit areas (1,700 acres) 

would prohibit road 

construction.

Greater opportunity for ski 

area development and 

expansion.

Forest Plan allocations for ski 

areas outside of existing 

permit areas (1,700 acres) 

would allow road construction 

and tree-cutting more than 

alternative 1.

Forest plans can be amended 

or revised to expand ski area

allocations beyond the current 

allocation.

Same as alternative 2.

Scenic Quality Least risk to scenic

resources.

More risk to scenic resources

than alternatives 1 and 4.

Upper tier acres same as 

alternative 1.

Greatest risk to scenic

resources.

Same as alternative 2 within 

CRA boundaries that are not 

upper tier; upper tier areas 

same as alternative 1.

Social Values No disproportionate negative 

impact on minority or lowincome groups as defined in 

the Bureau of the Census' 

Current Population Reports.

Preference towards 

preservation of nondevelopment social values.

No disproportionate negative 

impact on minority or lowincome groups as defined in 

the Bureau of the Census' 

Current Population Reports.

Slightly less than alternative 1 

preference towards nondevelopment social values.

No disproportionate negative 

impact on minority or lowincome groups as defined in 

the Bureau of the Census' 

Current Population Reports.

Less preference towards nondevelopment social values than 

alternatives 1, 2, and 4.

Same as alternative 2.

Terrestrial Species and 

Habitat

Least risk to terrestrial

species and habitat.

Site specific design criteria 

More risk than alternative 1 

and 4 to terrestrial species 

and habitat.

Greatest risk to terrestrial

species and habitat.

Site specific design criteria and 

More risk than alternative 1

and less risk than alternatiave 

2 to terrestrial species and 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

76—Chapter 2. Alternatives, Including the Proposed Action

Issue or Affected Resource

Alternative 1

Provisions of the 2001 

Roadless Rule

Alternative 2

Proposed Action

Colorado Roadless Rule

Alternative 3

No Action

Forest Plans

Alternative 4 

Colorado Roadless Rule

and mitigation measures are 

expected to minimize risk.

Tree-cutting to improve 

habitat for TEPS species 

prohibited in upper tier acres.

Site specific design criteria 

and mitigation measures are 

expected to minimize risk.

mitigation measures are 

expected to minimize risk.

habitat.

Tree-cutting to improve 

habitat for TEPS species 

prohibited in upper tier acres.

Site specific design criteria 

and mitigation measures are 

expected to minimize risk.

Recreation Settings Likely to retain the greatest 

proportion of acreage in 

primitive or semi-primitive

settings

The substantially altered

portion of the IRA inventory 

would continue to be 

inconsistent with primitive or 

semi-primitive settings.

The newly identified roadless 

acres (409,500 acres) where 

road construction and treecutting, sale or removal is 

projected to occur that are not 

within the IRAs could shift to 

less primitive settings. 

Likely to retain a high 

proportion of acreage in 

primitive or semi-primitive

settings. However, some 

areas where road 

construction and tree-cutting, 

sale or removal is projected to 

occur could shift to less 

primitive settings.

The exclusion of the 

substantially altered acreage 

and inclusion of new roadless 

acres would create a more 

homogeneous primitive or 

semi-primitive recreation 

setting.

Least likely to retain a high 

proportion of acreage in 

primitive or semi-primitive

settings; especially where road 

construction and tree-cutting, 

sale or removal is projected to 

occur.

More likely than alternatives 2 

and 3 to retain a high 

proportion of acreage in 

primitive or semi-primitive

settings.

Lands-Special Use 

Authorizations

Special use authorizations 

issued prior to the effective 

date of rulemaking would be 

unaffected.

Future special use 

authorizations in IRAs would 

generally prohibit road 

construction.

There would be no prohibition 

on the use of LCZs for future 

electrical power lines or 

telecommunication lines, 

water conveyance structures 

and oil and gas pipelines from 

sources outside of IRAs.

Special use authorizations 

issued prior to the effective 

date of rulemaking would be 

unaffected.

Future special use 

authorizations in CRAs would 

generally prohibit road 

construction.

Limited exceptions for the use

of LCZ for future electrical 

power lines or 

telecommunication lines, 

water conveyance structures 

and oil and gas pipelines from 

sources outside of CRAs.

Current and future special use 

authorizations would generally 

allow for road construction; 

except where prohibited under 

forest plans.

There would be no prohibition 

on the use of LCZs for future 

electrical power lines or 

telecommunication lines, water 

conveyance structures or oil 

and gas pipelines.

More restrictions than 

alternative 2, due to the 

greater proportion of upper 

tier acres, and fewer 

restrictions than alternative 1.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 2. Alternatives, Including the Proposed Action—77

Issue or Affected Resource

Alternative 1

Provisions of the 2001 

Roadless Rule

Alternative 2

Proposed Action

Colorado Roadless Rule

Alternative 3

No Action

Forest Plans

Alternative 4 

Colorado Roadless Rule

Invasive Plants Least risk of spread of 

invasive plants because this 

alternative has the least 

projections of road 

construction or tree-cutting, 

sale or removal.

Site specific design criteria 

and mitigation measures are 

expected to minimize risk.

Slightly higher risk than 

alternatives 1 and 4 for the 

spread of invasive plants 

because this alternative has a 

higher projection of road 

construction or tree-cutting, 

sale or removal.

Site specific design criteria 

and mitigation measures are 

expected to minimize risk.

Greatest risk of the spread of 

invasive plants because this 

alternative has the highest 

projections for road 

construction or tree-cutting, 

sale or removal.

Site specific design criteria and 

mitigation measures are 

expected to minimize risk.

Slightly higher risk than 

alternative 1 but less than 

alternative 2 for the spread of 

invasive plants because this 

alternative has a higher 

projection of road 

construction or tree-cutting, 

sale or removal.

Site specific design criteria 

and mitigation measures are 

expected to minimize risk.

Cultural Resources Least risk of damage to 

cultural resources because 

this alternative has the least 

projections for tree-cutting, 

sale or removal.

Site specific design criteria 

and mitigation measures are 

expected to minimize risk.

Slightly higher risk of damage 

to cultural resources than 

alternative 1 because this 

alternative has a high 

projection of tree-cutting, sale 

or removal and road 

construction.

Site specific design criteria 

and mitigation measures are 

expected to minimize risk.

Highest risk of damage to 

cultural resources because this 

alternative has the highest 

projection of tree-cutting, sale 

or removal and road 

construction.

Site specific design criteria and 

mitigation measures are 

expected to minimize risk.

Less risk than alternative 2

due to more acres in the 

upper tier..

Site specific design criteria 

and mitigation measures are 

expected to minimize risk.

Roadless Area 

Characteristics

Minimal effect to roadless 

area characteristics because 

there is little projected activity 

to occur.

No consideration or regulatory 

protection of roadless area 

characteristics on 409,500 

acres outside of IRA 

boundaries.

Minimal effect to roadless 

area characteristics because 

there is little projected activity

to occur.

Consideration and protection 

of roadless area 

characteristics on 409,500 

acres within CRA boundaries.

More effect to roadless area 

characteristics because there 

is an increase in projected 

activities to occur compared to 

the other alternatives. 

Some risk of adverse effects to 

roadless area characteristics

because there are no 

regulatory prohibitions on road 

construction, use of linear 

construction zones or treecutting, sale or removal on any 

of the analysis area. 

Minimal effect to roadless 

area characteristics because 

there is little projected activity 

to occur.

Consideration and protection 

of roadless area 

characteristics on 409,500 

acres within CRA boundaries.

Air Resources Differences in effects on air quality do not substantially differ between the alternatives. Atmospheric emissions within the analysis 

area are not expected to increase to a level that would be likely to exceed state or federal air quality standards.

Administratively and 

Congressionally Designated 

There are no differences between the alternatives to administratively or congressionally designated areas because none of the 

alternatives project tree-cutting, sale or removal or road construction in administratively designated areas and tree-cutting, sale or 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

78—Chapter 2. Alternatives, Including the Proposed Action

Issue or Affected Resource

Alternative 1

Provisions of the 2001 

Roadless Rule

Alternative 2

Proposed Action

Colorado Roadless Rule

Alternative 3

No Action

Forest Plans

Alternative 4 

Colorado Roadless Rule

Areas removal or road construction is prohibited in congressionally designated areas.

Wilderness Alternatives 1 and 2 have a low likelihood of affecting 

wilderness characteristics because tree-cutting, sale or 

removal and road construction are prohibited in Wilderness 

areas and projected activities within roadless areas are not 

expected to occur adjacent to Wilderness area boundaries.

Higher risk of adverse effect 

to wilderness areas because

of the high projections for 

tree-cutting, sale or removal 

and road construction and a 

higher likelihood that these 

activities could occur adjacent 

to Wilderness boundaries.

Same as alternatives 1 and 2.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—79

CHAPTER 3. AFFECTED ENVIRONMENT AND 

ENVIRONMENTAL CONSEQUENCES

INTRODUCTION

This chapter summarizes the physical, biological, social, and economic environment of the 

project area and the potential effects of implementing each alternative on the environment. It

also presents the programmatic analysis and comparison of alternatives presented in the 

previous chapter. 

This analysis is structured around four alternatives that were described in detail in chapter 2: 

Alternative 1 – Provisions of the 2001 Roadless Rule 

Alternative 2 – Colorado Roadless Rule (Proposed Action)

Alternative 3 – Forest Plans (No Action)

Alternative 4 – Colorado Roadless Rule with Public Proposed Upper Tier 

The description of the affected environment (current conditions and trends), followed by the 

environmental consequences (impacts or effects) associated with each alternative are presented 

for comparison.

Analysis Area 

The area of analysis for determining effects is limited to National Forest System (NFS) lands 

determined to be roadless areas within the State of Colorado. Roadless areas in Colorado are 

generally undeveloped areas, typically exceeding 5,000 acres and meet the minimum criteria for 

inclusion in the National Wilderness Preservation System. These areas were identified through 

a variety of assessments and inventories including, the Forest Service‘s Roadless Area Review 

and Evaluation (RARE II) processes, and forest planning. 

While the areas and acreages for each alternative are different, the analysis area for all of the 

alternatives is the same in order to compare the environmental effects of each alternative (see 

Map Packet, Map 1). The area of analysis is NFS lands within: (1) the CRAs; and (2) the 2001 

IRAs, excluding proclaimed Wilderness and other congressionally designated areas. The 

alternatives differ in terms of which acres would be managed according to a roadless rule and 

forest plans, and which acres would be managed according to direction in the forest plan only. 

Table 3-1 displays the number of acres of the analysis area that would be managed according to 

a roadless rule and forest plans and how many acres would be managed according to the forest 

plans only under each alternative. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

80—Chapter 3. Affected Environment and Environmental Consequences

Table 3-1. Provisions that Apply to each Portion of the Analysis Area by Alternative.

Alternative

Portion of the Analysis Area for Alternatives 

(Total analysis area = 4,653,100 acres)

Roadless Acres in 

Common

IRAs and CRAs

3,776,500 acres

Substantially Altered 

and Ski Area Acres,

IRAs only

467,100 acres

New Roadless Acres

CRAs only

409,500 acres

Alternative 1 – provisions 

of the 2001 Roadless Rule

IRAs – Forest Plan & 

2001 Rule

IRAs – Forest Plan & 

2001 Rule Forest Plan

Alternative 2 – Colorado 

Roadless Rule 

(Proposed Action)

CRAs – Forest Plan & 

CO Rule Forest Plan CRAs – Forest Plan & CO Rule

Alternative 3 – Forest 

Plans 

(No Action)

Forest Plan Forest Plan Forest Plan

Alternative 4 - Colorado 

Roadless Rule with Public 

Proposed Upper Tier

CRAs – Forest Plan & 

CO Rule Forest Plan CRAs- Forest Plan & CO Rule

Alternative 1 identifies 4.24 million acres that would be managed according to the provisions of 

forest plans and the 2001 Roadless Rule. The additional 409,500 acres within the analysis area 

not covered by the 2001 Roadless Rule that were found to contain roadless area characteristics

would be managed according to the respective forest plan.

Alternative 2 identifies 4.19 million acres (3,776,500 acres of the 2001 Roadless Rule IRAs and an 

additional 409,500 acres that were found to have roadless area characteristics) that would be 

managed according to forest plans and the Colorado Roadless Rule. The 467,100 acres not 

within the CRAs would be managed according to the respective forest plan and includes acres 

that have been substantially altered; acres permitted for ski areas; or acres that forest plans have 

currently allocated to ski areas. This alternative designates a total of 562,200 upper tier acres. 

Alternative 3 would require that all of the acres within the analysis area be managed according 

to the respective forest plan. 

Alternative 4 identifies 4.19 million acres (3,776,500 acres of the 2001 Roadless Rule IRAs and an 

additional 409,500 acres that were found to have roadless area characteristics) that would be 

managed according to the Colorado Roadless Rule and forest plans. The 467,100 acres that 

includes permitted or forest plan allocated ski area acres and those that have been substantially 

altered would be managed according to the respective forest plan. This alternative has the same 

provisions as alternative 2 and differs by the amount of acres designated to upper tier. This 

alternative designates 2,614,200 acres as CRA upper tier acres.

Further details on the roadless inventory for each alternative are found in chapter 2. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—81

Analysis Framework

The scope of this analysis is programmatic in nature. The actions to be analyzed consist of 

establishing regulatory prohibitions with specific exceptions. There are no ground disturbing 

activities proposed or authorized by any of the alternatives. All subsequent proposals for 

activities would require the preparation of a separate site-specific analysis and decision 

pursuant to the National Environmental Policy Act (NEPA). The potential environmental 

consequences are based on projected probable actions and are primarily described in qualitative 

and comparative terms.

Prohibitions and exceptions apply to road construction or reconstruction and tree-cutting, sale, 

or removal in roadless areas and, in some alternatives, certain other activities such as linear 

construction zones (LCZs), construction of oil and gas pipelines, electrical power lines, 

telecommunication lines, and water conveyances. In order to display the differences in 

environmental consequences between the alternatives, this analysis uses assumptions and 

probable levels of three activities because they have the greatest likelihood of altering

landscapes resulting in the loss of roadless area characteristics:

tree-cutting, sale or removal

road construction or reconstruction

linear construction zones.

In order to compare the alternatives, it was necessary to project what was likely to occur under 

each of the alternatives. To make the forecast, project planners looked at past and projected 

needs on the ground to provide information regarding the likelihood that tree-cutting, sale, or 

removal; road construction or reconstruction and linear construction zones would occur within 

the full analysis area over the next 15 years under the management direction contained in each 

alternative. This information was used to make projections on the number of acres of treecutting, sale or removal; the number of miles of road construction or reconstruction and the 

number of miles of linear construction zones that may occur under each alternative. The 

projections are only estimates and are not proposals for action. 

Analysis Assumptions and Projections

Tree-cutting, Sale, or Removal

Assumptions

The following assumptions were made for tree-cutting, sale, or removal activities that are 

projected to occur within the analysis area under the alternatives:

Budgets would continue to be flat. The primary focus for tree-cutting, sale or removal 

for the foreseeable future is fuels reduction adjacent to communities.

Under alternative 1, tree-cutting to maintain or restore the characteristics of ecosystem

composition and structure would be utilized primarily in the ponderosa pine/Douglasfir and pinyon-juniper forest cover types. Lodgepole pine cover types rarely fit this 

exception. This exception is not specifically associated with at-risk communities or 

municipal water supply systems, but its use would likely be associated with these. With 

no corresponding road construction exception, tree-cutting under this exception is 

limited for alternative 1.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

82—Chapter 3. Affected Environment and Environmental Consequences

Under alternatives 2 and 4, tree-cutting to maintain or restore ecosystem characteristics 

includes potential projects to reduce tree mortality from spread of insects and diseases 

that would change ecosystem composition and structure. These projects would be 

infrequent.

Under alternatives 2 and 4, the majority of tree-cutting, sale, or removal would occur for 

hazardous fuel reduction within 1⁄2 mile of communities where temporary roads can be 

utilized to remove the fuels. Activities are projected to occur in lodgepole pine, 

ponderosa pine/Douglas-fir, and pinyon-juniper forest cover. Tree-cutting is prohibited 

in the upper tier acres under the hazardous fuel reduction exception. 

Even if allowed for in an alternative, it would be rare to cut and remove trees for 

hazardous fuel reduction where the average log skidding distances to an existing or 

newly constructed temporary road exceed 1,000 feet. However, in some instances logforwarding equipment could be utilized to cut and remove trees when the average skid 

distance exceeds 1,000 feet without the need for additional temporary roads. In other 

cases, machinery such as a masticator could be utilized without additional road access to 

cut and treat trees and undergrowth on-site. Finally in some instances, crews may be 

utilized to cut trees and treat the resulting slash on site by hand.

Tree-cutting would occur at historic levels in all alternatives when incidental to an 

otherwise permitted purpose; such as, removal of hazard trees adjacent to roads or trails 

for public health and safety reasons; fire line construction for wildland fire suppression 

or control of prescribed fire; survey and maintenance of property boundaries; mining

operations, maintenance of power or water lines, or trail maintenance or construction. 

Tree-cutting and removal for personal or administrative use would occur at historic 

levels under all alternatives. Personal use includes activities such as Christmas tree and 

firewood cutting. Administrative use includes such activities as construction of fences or 

footbridges. 

Projections

Projections are based on the exceptions under each alternative that allow tree-cutting, sale and 

removal in roadless areas and on the assumptions described above. All projections for treecutting, sale or removal are annual averages and can be expected to vary from year to year. For 

every alternative, projected probable activities are those that would occur in the analysis area 

for the next 15 years. Table 3-2 displays the purpose for and number of acres where tree-cutting, 

sale, or removal is projected to occur under the alternatives over the next 15 years. Alternative 3

has the greatest number of acres where tree-cutting, sale or removal is projected to occur 

followed by alternatives 2, 4 and 1 respectively. More information about the likelihood of treecutting, sale or removal activities, including projected acreages is contained in Appendix D.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—83

Table 3-2. Distribution of average annual tree-cutting, sale or removal projections in analysis area 

by alternative, by purpose. 

Purpose for 

projected treecutting, sale or 

removal

Average annual tree-cutting, sale or removal*

Alternative 1 Alternative 2 Alternative 3 Alternative 4

IRA 

roadless

Other 

acres 

Forest 

Plan

CRA 

roadless

Other 

acres 

Forest 

Plan

All acres,

Forest 

Plan

CRA

roadless

Other 

acres 

Forest 

Plan

- - - - - - - - - - - - - - average annual acres – to nearest 100 acres - - - - - - - - - - - - -

Hazardous fuels 

reduction treatments 900 900 5,300 600 13,100 1,600 600

Restore and maintain 

ecosystem 300 200 400 600 3,500 200 600

TEPS habitat 

improvement <5 0 <100 0 <100 <5 0

Other** 40 40 100 <100 300 <100 <100

Total tree-cutting, sale 

or removal 1,200 1,100 5,800 1,200 16,900 1,800 1,200

Data source: Forest Service Region 2, August, 2010.

*Totals may not add due to rounding. **Other includes tree-cutting that is incidental to the implementation of a 

management activity and tree-cutting for personal or administrative use.

Road Construction and Reconstruction 

According to the Forest Service Region 2 INFRA-GIS roads databases (April 2008), 

approximately 1,260 miles of National Forest System and other authorized roads occur within 

IRAs. Other authorized road miles include state, county, local, and private roads. About 8.5 

miles of the authorized roads occur in CRAs, and approximately 1,250 miles are in the 

substantially altered portions of the IRAs, which are not included in the roadless inventory for 

the Colorado Roadless Rule due to the presence of these roads. The 8.5 miles within CRAs occur 

exclusively on the White River (8.3 miles) and Arapaho-Roosevelt (.2 miles) National Forests 

and all but 0.5 miles on the White River NF are proposed to be decommissioned. Unauthorized 

or non-system roads are not included in the mileage. Inventories indicate that there are at least 

35 to 45 miles of unauthorized roads in the IRAs and CRAs. It is suspected that additional 

unauthorized roads exist in roadless areas but have not been identified. It is anticipated that, in 

most cases, the unauthorized roads as well as some of the authorized roads within the analysis 

area would be decommissioned as budgets allow. Table 3-3 displays the miles of NFS roads and 

other authorized roads on NFS lands in roadless areas by alternative.

Table 3-3. Miles of existing authorized roads in roadless areas 

Type of Road

Roads in IRAs

Alternatives 1 and 3

Roads in CRAs

Alternatives 2 and 4

- - - - - - total miles of road- - - - - - - -

National Forest system roads 1,234 8

Other authorized roads 26 0.5

Total existing roads 1,260 8.5

Roads to be decommissioned 24 8

Data source: Forest Service Region 2 INFRA-GIS roads databases, April 2008.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

84—Chapter 3. Affected Environment and Environmental Consequences

Assumptions

The following assumptions were made for road construction or reconstruction that could occur 

within the analysis area under the alternatives:

Road construction or reconstruction would not likely see an increase in the foreseeable 

future because the appropriated budget is flat or declining, and long term funding 

expectations are a main determinate in identifying the minimum road system. In 

addition, there is a backlog of road maintenance; therefore, there is no emphasis on 

constructing new roads that need to be maintained. 

All road construction/reconstruction would be conducted in accordance with road 

engineering design standards found in Forest Service Handbook 7709.59.

In all alternatives, road construction and the level of road that is constructed would be 

the minimum necessary to accommodate access. Where a project, such as vegetative 

treatment, can be completed without road construction, this is usually the chosen 

option. If road construction is needed for the project, a temporary road is the first option 

while a permanent road is usually the last option if allowed by the alternative. 

If roads are constructed in roadless areas, under alternatives 2 and 4, they are required 

to be temporary, closed to public vehicle travel, and decommissioned after their 

intended use. This is likely but not required to occur in the other alternatives.

The roads projected in all of the alternatives for the existing oil and gas leases that allow 

road construction are associated with reasonable foreseeable development of the leases 

over the next 15 years. It is understood that future energy policies, prices, and 

development are highly uncertain.

The roads projected in all alternatives for coal development are over the next 15 years

(yearly projections are utilized in the effects analyses). It is understood that future 

energy policies, prices, and development are highly uncertain.

Projections

All projections for road construction or reconstruction are annual averages and can be expected 

to vary from year to year. The purpose for and number of miles of road construction or 

reconstruction projected under the alternatives for the analysis area are identified in Appendix 

D. The projections are based on the exceptions for road construction or reconstruction that are 

allowed in roadless areas under each alternative along with the assumptions described above.

The projections do not identify roads that may be needed in response to emergencies. The 

greatest number of road miles for all activities is projected to occur under alternative 3 followed 

by alternatives 2, 4 and 1 respectively. The majority of road construction or reconstruction 

would take place in areas previously leased for oil and gas development, in the North Fork coal 

mining area, and adjacent to communities for hazardous fuels reduction. Details are outlined 

below. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—85

Table 3-4. Distribution of average annual road construction and reconstruction projections in 

analysis area for each alternative, by general purpose roads

Projected road 

construction or 

reconstruction for 

general purpose

Average annual road construction and reconstruction

Alternative 1 Alternative 2 Alternative 3 Alternative 4

IRA 

roadless

Other 

acres 

Forest 

Plan

CRA 

roadless

Other 

acres 

Forest 

Plan

All acres,

Forest Plan

CRA 

roadless

Other 

acres 

Forest 

Plan

- - - - - - - - - - - - - - - - - - - - - annual average miles - - - - - - - - - - - - - - - - - - - - - - -

Hazardous fuels 

reduction treatments 0.0 0.8 2.1* 0.8 7.1 0.8* 0.8

Maintain and restore 

ecosystem 0.0 0.1 0.7* 1.2 2.7 0.3* 1.2

Recreation special uses 

(ski areas, recreation 

residences, etc.)

0.2 0.0 0.1 0.5 0.6 0.0 0.5

Water conveyances 0.8 0.0 0.3 0.5 1.0 0.2 0.5

Utility special uses

(power lines, etc) 0.3 0.0 0.1 0.3 0.6 0.0 0.3

Hard rock minerals 0.3 0.0 0.3 0.0 0.3 0.3 0.0

Other roads (health and 

safety, Federal Highway, 

CERCLA)

0.2 0.0 0.1 0.2 0.4 0.1 0.2

Total general purpose 

road construction/ 

reconstruction projected 

(nearest mile)

2 1 4 3 13 2 3

Data source: Forest Service Region 2, August 2010.

Totals may not add due to rounding.

*can only be temporary roads under alternatives 2 and 4 and would be restored after use

Coal Road Construction/Reconstruction Projections

Table 3-5 displays by alternative the projections for road construction and reconstruction that 

could occur for coal development in the coal analysis area (39,600 acres).

The majority of projected coal-related temporary roads are for exploration or methane drainage 

purposes, and these would be on the landscape for 2-5 years. A small number of coal roads 

access ventilation shafts and monitoring facilities that are expected to be on the landscape for 30 

years or more. The projections for roads associated with coal lease, exploration and 

development were based on a 39,600 acre area, the only place on NFS lands in Colorado where 

economically viable coal resources are presently being developed. There are 7,100 acres 

currently leased within the 39,600 acre area. Of the 7,100 acres leased, 5,900 acres are within 

IRAs and 4,000 acres are within CRAs. No additional coal could be leased within the IRAs 

under alternative 1. Alternatives 2 and 4 allow additional coal leasing in the CRAs only within 

the 20,000 acre North Fork coal mining area; where approximately 15,630 acres are not currently 

leased. Alternative 3 allows coal leasing within the entire 39,600 acre area. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

86—Chapter 3. Affected Environment and Environmental Consequences

Table 3-5. Projected Road Construction/Reconstruction in Coal Analysis Area by Alternative, 15-

years. 

Alternative 1 Alternative 2 & 4 Alternative 3 

Road construction and 

reconstruction would be 

allowed in IRAs on coal

leases in effect prior to 

effective date of rule; and in 

CRAs that are not within 

IRAs according to forest plan

management direction

Road construction and 

reconstruction could occur 

in CRAs within the North 

Fork Coal Mining Area; and 

in the IRAs that are not 

within the CRAs according to 

forest plan management 

direction

Road construction and 

reconstruction could occur 

in IRA and CRA according to 

forest plan management 

direction

IRA only 2 miles temporary roads 2 miles temporary roads 2 miles temporary roads

IRA/CRA in 

common

5 miles temporary roads 44 miles temporary road

38 miles forest road

24 miles temporary road

CRA only 9 miles temporary or forest 

road 6 miles temp road 9 miles temporary or forest road 

Total by 

alternative 

for 15 year

7 within IRAs;

16 total miles

50 within CRAs;

52 total miles

64 within IRAs;

73 total miles

Total by 

alternative 

annually

1 mile 3 miles 5 miles

All of the roads constructed for coal exploration and development under alternatives 2 and 4 

would be temporary and must be decommissioned. Under alternatives 1 and 3, roads 

constructed could be converted to permanent roads, if determined to be appropriate according 

to the forest plan.

Oil and Gas Road Construction/Reconstruction Projections

Road construction and reconstruction for oil and gas development would occur almost 

exclusively on the GMUG and White River National Forests.

Overall, alternative 3 projects the greatest number of miles of road construction or 

reconstruction for oil and gas development because under the other alternatives all future oil 

and gas leases as of the date of the Colorado Rule would not allow road construction. Under 

alternatives 2 and 4, roads allowed by existing oil and gas leases are only temporary and would 

not become forest or permanent roads. Under alternatives 1 and 3, oil and gas roads are 

considered forest or administrative roads and could be made into permanent roads if 

determined to be appropriate according to the forest plan.

Table 3-6 displays the annual average projections for road construction or reconstruction for oil 

and gas development.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—87

Table 3-6. Distribution of average annual road construction and reconstruction projections in 

analysis area for each alternative, for oil and gas development

Average annual road construction and reconstruction

Alternative 1 Alternative 2 Alternative 3 Alternative 4

IRA 

roadless

Other 

acres 

Forest 

Plan

CRA 

roadless

Other 

acres 

Forest 

Plan

All acres,

Forest Plan

CRA 

roadless

Other 

acres 

Forest 

Plan

-------------------------------------------- miles ------------------------------------------

Projected road 

construction or 

reconstruction for oil 

or gas development

9 1 9 0.3 11 9 0.3

Data source: Forest Service Region 2, August, 2010.

Generally numbers rounded to nearest mile. 

Summary Road Construction/Reconstruction Projections

Table 3-7 displays a summary of the total average annual miles of road projected to be 

constructed or reconstructed for all activities under each alternative. Table 3-7 also displays the 

type of road (temporary or forest) that is projected to be constructed or reconstructed.

Table 3-7. Average annual road construction and reconstruction miles projected by alternative

Type of projected road 

construction or 

reconstruction

Average annual road construction and reconstruction

Alternative 1 Alternative 2 Alternative 3 Alternative 4

IRA 

roadless

Other 

acres 

Forest 

Plan

CRA 

roadless

Other 

acres 

Forest 

Plan

All acres,

Forest 

Plan

CRA 

roadless

Other 

acres 

Forest 

Plan

--------------------------------------------- miles ---------------------------------------------

Temporary 1.7 1.6 6.6 2.7 11.0 4.8 2.7

Forest * 9.3 1.3 9.6 1.1 17.4 9.5 1.1

Total Construction / 

Reconstruction (nearest mile) 11 3 16 4 28 14 4

Data source: Forest Service Region 2, August, 2010.

Totals may not add due to rounding and may not add to the totals in Tables 3-4; 3-5; and 3-6 due to rounding

* These represent the highest level of road development, in some cases temporary roads may be used rather than a Forest road.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

88—Chapter 3. Affected Environment and Environmental Consequences

Linear Construction Zones

Assumptions

An LCZ is a short-term construction area and equipment staging and movement area for 

constructing a linear feature when continued roaded facility operation and maintenance 

access is not needed.

Under alternative 3, while forest plans are usually silent on the use of LCZs, a forest 

plan may restrict the construction of linear features within a particular management 

area, depending on management area direction.

Projections

Table 3-8 displays a summary of the average annual miles of LCZs projected to be constructed 

for all three of the above listed activities under each of the alternatives. Overall, alternative 3 

projects the greatest number of miles of LCZs with the other three alternatives projecting 

identical miles.

Table 3-8. Average annual LCZ miles projected by alternative

Type of projected LCZ

Average annual LCZ miles

Alternative 1* Alternative 2 Alternative 3 Alternative 4

IRA 

roadless

Other 

acres 

Forest 

Plan

CRA 

roadless

Other 

acres 

Forest 

Plan

All acres,

Forest Plan

CRA 

roadless

Other 

acres 

Forest 

Plan

--------------------------------------------- miles ---------------------------------------------

Water conveyance 0.5 0 0.5 0 0.5 0.5 0

Electrical power line or 

telecommunication line 2.0 0 2.0 0 2.0 2.0 0

Oil and gas pipeline 0.7 0 0.7 0 1.1 0.7 0

Total LCZ (nearest mile) 3 0 3 0 4 3 0

* Alternative 1 is silent on the use of LCZs within IRAs. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—89

VEGETATION AND FOREST HEALTH

Introduction

Roadless areas contain a diverse array of forest vegetation, ranging from warm, dry pinyonjuniper woodlands to cold, moist sub-alpine forests. Species composition is generally correlated 

with elevation and aspect. Forest vegetation cover types in Colorado‘s roadless areas are based 

on information in the R2Veg database, which is primarily developed from aerial photography. 

The cover type refers to the most dominant species in the overstory canopy and does not 

include the wide variation in understory trees and other vegetation. The non-forest cover types 

within the roadless areas include grasslands and meadows, shrublands, areas devoid of 

vegetation such as exposed bedrock, and a minor amount of surface water.

The roadless areas in the State are predominantly coniferous forest types occupying 

mountainous terrain. Forested land covers approximately 3,330,000 acres or 72 percent of the 

NFS lands within the analysis area (a total of 4,653,100 acres). Table 3-9 displays the cover type 

distribution within the analysis area that includes all IRAs and CRAs.

Table 3-9. Forest cover type distribution in the Colorado Roadless Rule analysis area*

Vegetation Cover Types Acres Portion of total

Rock and Water 212,400 14%

Grass and Forbs 672,600 5%

Shrubs 437,800 9%

Pinyon-Juniper 105,700 2%

Ponderosa Pine 183,200 4%

Douglas-fir 366,000 8%

Lodgepole Pine 556,100 12%

Spruce/Fir 1,068,800 23%

Aspen 957,400 21%

Other Tree Species 93,000 2%

* Information from R2Veg database for the analysis area (area is approximate and rounded to nearest 100 acres). 

Forest species composition has changed somewhat from pre-European settlement conditions as 

a result of human and natural disturbances as well as successional processes. The amount of 

change varies based on the types and frequency of disturbances and the response of the 

vegetation types. Roadless areas by their very nature have limited access and therefore have 

had little timber management. Forest vegetation changes in roadless areas have primarily been 

influenced by natural processes in concert with management such as fire suppression and 

grazing that have affected fire frequency in some areas. 

The disturbance processes provide insights into current and likely future forest conditions. 

Grasses, shrubs, ponderosa pine, and Douglas-fir have higher natural fire frequencies than 

lodgepole pine and spruce-fir cover types and therefore generally have higher departures from 

historic conditions due to fire suppression. Tree species composition in southwest Colorado has 

changed in many places from ponderosa pine dominated stands with relatively few medium 

and large diameter trees to many smaller diameter Douglas-fir and white fir trees (Covington 

and Moore 1994; Fulé et al. 1997). The Colorado Front Range had a mixed-severity fire regime

that provided a complex forest structure of openings, patches of pure ponderosa pine and 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

90—Chapter 3. Affected Environment and Environmental Consequences

patches of mixed ponderosa pine and Douglas-fir (Kaufman et al. 2001). Fire suppression in the 

20th century reduced tree mortality and resulted in forests with much higher tree density than 

existed historically (Kaufman et al. 2000, Veblen et al. 2000). The forest structure in more mesic 

upper montane ponderosa pine – Douglas-fir forests, particularly in the northern Front Range 

may not have been as severely altered (Baker et al. 2007). An on-going study is finding fire 

frequency and intensity were variable based on elevation and through time in the mixed conifer 

zone and in the foothills in Northern Colorado. There appear to be ecological break points, 

where species composition and fire regimes change. Those break points have moved up and 

down the elevational gradient in the last 1,000 years. Localized surface fires were the norm, 

with occasional, climate-driven mixed severity fires that burned larger areas the last 500 years 

(Huckaby 2009). 

The departure from historic conditions is smaller in the infrequent, high intensity fire regimes of 

spruce-fir and lodgepole pine forests. Although the departure from historic conditions is less 

than in lower elevation forest types, dramatic changes can and have occurred with highintensity fires and beetle epidemics such as the on-going mountain pine beetle and spruce 

beetle epidemics. 

The current distribution of forest composition and structure has resulted from the type of 

disturbances and time since disturbance. In addition to the cover types, the size of the trees is an 

important metric for wildlife habitat, aesthetics, forest health, and timber management. Tree 

size is estimated from the R2Veg database and displayed below in Table 3-10. 

Table 3-10. Tree size distribution*

Size Class Description

Size

(DBH)

IRA

(portion of total)

Seedling and Sapling < 5‖ 4%

Young Forest 5-9‖ 35%

Mature Forest 9-16‖ 54%

Old Forest >16‖ 7%

* Information from R2Veg database for the analysis area

Forest Management

The National Forests in Colorado sold approximately 200 million board feet (MMBF) of timber

annually from the 1950s through the 1980s. The level decreased to approximately 50 MMBF 

annually between 1995 and 2005. Timber sales then increased to approximately 100 MMBF 

annually since 2006 in response to the current mountain pine beetle epidemic.

Within the analysis area there are approximately 2,700,000 acres (58 percent) available for treecutting to achieve multiple use objectives and provide a sustainable supply of timber

(determined to be suitable through the forest plans). Most of the area available for tree-cutting 

in the roadless areas is not associated with timber production. Tree-cutting and harvest are 

primarily permitted to achieve multiple resource management objectives, including improving 

forest health and reducing hazardous fuels where timber volume is a secondary objective or a 

by-product. Roads are used where timber is removed and to increase economic feasibility. 

Removal of trees to reduce hazardous fuels or reduce the spread of forest diseases or insects is 

often economically feasible only if a road system is present. 

Reducing hazardous fuels has been an important objective in forest vegetation management in 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—91

recent years. The emphasis on hazardous fuel reduction has focused on commercial and noncommercial thinning in the pinyon-juniper, ponderosa pine, and Douglas-fir cover types. 

Lodgepole pine and aspen are early successional species. These species are typically 

regenerated using even-aged methods; thinning is not generally an option as they are 

susceptible to wind throw. Forest vegetation management in spruce-fir forests primarily relies 

on uneven-aged methods with limited thinning.

Forest Health - Insects and Diseases: Affected Environment 

Forest health describes the forest condition associated with its age, composition, structure, 

function, vigor, insects and disease, and resilience to disturbances (Helms 1998). Forest health is 

framed by the individual or societal perspective, including the land management objectives and 

spatial and temporal scales. Trees growing in dense stands are often weakened by the 

competition for light, nutrients and moisture. Stand conditions can be used to estimate the risk 

of mortality from damaging insects and disease organisms. Landscapes with high levels of 

stressed, dying, or dead trees are considered unhealthy for purposes of this analysis. 

Stressed, dead, and dying trees may become more prevalent in Western landscapes from 

impacts associated with climate change, such as warming temperatures and changes in 

precipitation patterns. Climate change may compromise the ability to achieve desired structure 

and composition for forest vegetation at landscape scales, especially with regard to wildfire

severity and damage from forest insects and diseases. The effects of wildfire, insects, and 

disease are expected to be greatest within roadless areas that have large contiguous areas where 

management responses are restricted or prohibited.

Forest health conditions in the roadless areas are variable, with some areas considered healthier 

than others. Roadless areas are experiencing similar health concerns comparable to those in 

other parts of Colorado. Recent outbreaks have been larger than most historical outbreaks, 

although a spruce beetle outbreak affected hundreds of thousands of acres on the White River

Plateau in the 1940s and 1950‘s. In addition, outbreaks affecting different forest types have been 

more synchronized than in the past. Recent outbreaks are attributable to stand conditions with 

high portions of susceptible, mature trees and warmer winter temperatures. Lower montane 

forests, primarily ponderosa pine and Douglas-fir, are generally considered outside their 

historic range of variation. These forests are at risk of uncharacteristic, high-intensity fire as well 

as forest health concerns.

Forest types are susceptible to a suite of insects and diseases. The acres given below are for the 

full analysis area (acres within both the IRAs and the CRAs). The forest pests of highest concern 

are as follows:

Mountain pine beetle (Dendroctonus ponderosae) activity was detected on over 200,000 

acres within the analysis area in 2009. The mountain pine beetle is considered the most 

destructive bark beetle in the West (Furniss and Carolin 1977). All western pines are 

susceptible to mountain pine beetle, but the majority of the mortality is in lodgepole 

pine and ponderosa pine. Studies in lodgepole pine show trees exceeding 8 inches in 

diameter, 80 years old and growing in a suitable climate for beetle development are 

most susceptible (Amman et al. 1977). Studies in ponderosa pine stands indicate stand 

density contributes to stand susceptibility (Schmid and Mata 1992, Negron and Popp 

2004) and there is evidence that this is true in lodgepole pine stands as well (McGregor 

et al. 1987). Much of the 556,000 acres of lodgepole pine has already been infested or is 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

92—Chapter 3. Affected Environment and Environmental Consequences

likely to be infested. The current mountain pine beetle epidemic threatens to kill most 

mature lodgepole pine in Colorado. The epidemic also affects ponderosa pine and other 

pines, but the extent of its impact cannot be predicted with much certainty at this time.

Spruce beetle (Dendroctonus rufipennis) activity was detected on approximately 27,000 

acres in 2009. Engelmann spruce and Colorado blue spruce (Picea pungens) are 

susceptible to spruce beetle. Outbreaks generally occur following widespread 

blowdown of spruce trees. Areas most susceptible are dense stands with high portions 

of large spruce greater than 16 inches in diameter (Schmid and Frye 1977). Within a 

large spruce beetle epidemic area, spruce trees as small as four inches in diameter are 

killed.

Douglas-fir beetle (Dendroctonus pseudotsugae) activity was detected on approximately 

8,000 acres in 2009. Douglas-fir beetle is often a secondary agent that attacks low vigor or 

damaged trees. Outbreaks usually occur in areas of wind-thrown trees, at sites damaged 

by fire or during periods of extreme drought (Furniss and Carolin 1977). The beetle often 

attacks Douglas-fir trees that are infected with root disease or that have been defoliated 

by western spruce budworm (Choristoneura occidentalis) or Douglas-fir tussock moth 

(Orgyia pseudotsugata). 

Subalpine fir succumbs to a combination of western spruce budworm, western balsam 

bark beetle (Dryocoetes confusus), and Armillaria root disease (Armillaria ostoyae). 

Combined, these forest pests result in subalpine fir decline and have affected 

approximately 53,000 acres of subalpine fir in 2009.

Aspen throughout much of Colorado has been recently affected by sudden aspen 

decline (SAD). The recent sudden aspen mortality has not been attributed to agents that 

typically kill mature aspen. Severe drought combined with high temperatures during 

the growing season appears to be responsible (Worrall et al. 2008). SAD is estimated to 

occur on over 70,000 acres of aspen in 2009.

White pine blister rust (Cronartium ribicola) is an exotic fungus that kills bristlecone pine

(Pinus aristata) and limber pine (Pinus flexilis). Native five-needle pines have little 

resistance to this invasive disease. A small percentage of five-needle pines have been 

shown to have genetic resistance to white pine blister rust. Preserving genetic diversity 

in these stands is important for the species. Mountain pine beetles also kill the fiveneedle pines and could threaten genetic diversity. Protection of trees carrying genetic 

resistance using insecticide sprays or antiaggregation pheromones is an effective tool 

during mountain pine beetle outbreaks. Affected acres are not available, but are 

relatively small since little of the roadless area contains five-needle pines.

White fir (Abies concolor) is primarily attacked by western spruce budworm and fir 

engraver bark beetle (Scolytus ventralis). Affected acres are not available, but are 

relatively small since little of the roadless area contains white fir. 

Table 3-11 displays the forest acres infested by damaging organisms in the analysis area based 

on aerial detection flights since 2003. The aerial surveys typically under-estimate actual acres of 

tree mortality because the flights do not cover all areas every year; observers miss some 

mortality; and some damage is not detectable from the air.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—93

Table 3-11. Principal insect and disease damaging agents within the analysis area.

Damage agent

Acres (thousands) affected by year 1, 2

2003 2004 2005 2006 2007 2008 2009

Mountain Pine Beetle 54.6 119.5 131.2 174.0 187.5 236.6 208.5

Spruce Beetle 18.7 14.2 23.9 16.1 22.8 12.2 27.0

Douglas-Fir Beetle 9.9 13.8 8.7 6.1 14.8 8.7 7.6

Subalpine Fir Decline 165.3 91.8 127.1 99.0 86.5 91.4 53.4

Sudden Aspen Decline 31.5 2.8 6.3 25.6 91.8 121.8 69.9

1Based on annual aerial detection surveys within the analysis area. Not all areas are surveyed every year resulting in underestimates of areas affected.

2Acres are not additive across years - some areas are affected for multiple years.

3Aspen was not extensively sampled in 2003-2005. The aerial survey does not differentiate sudden aspen decline, frost damage and tent caterpillar damage.

Forest Health - Insects and Diseases: Environmental Consequences 

Silvicultural Practices – General Effects

Forest health prevention and treatment options vary by forest type, pest species and other 

factors. Treatment methods may include, but are not limited to: pesticide spraying, 

pheromones, biological controls, trap trees, thinning, salvage and sanitation harvests, 

prescribed burning, and/or reforestation of non-host tree species. 

A combination of tree-cutting, removal, and prescribed burning are used to reduce the 

occurrence or spread of damaging insects and diseases, address other forest health concerns, 

and provide desirable forest conditions to reduce fire hazard. Management practices vary by 

management objectives and habitat type. 

Specific forest health treatments involving tree-cutting can include the following:

Thinning to improve stand health – reducing competition between trees can provide 

long lasting resilience to western bark beetles and can also reduce risk associated with 

wildfire. Results can be variable and thinning may not be as effective in preventing 

spread of certain species in certain forest conditions, but thinning also can be an 

important long-term strategy for fuels reduction (see Fire and Fuels). 

Sanitation – Removal of infested trees can greatly reduce attacks on adjacent trees and 

can help protect trees on adjacent lands. These treatments are very effective in small 

isolated infestations, but may not be effective in outbreak conditions. Removal of 

windthrown trees is an important management tool for spruce beetle. 

Felling and treatment on site – There is evidence that felling, burning, chipping, 

spraying or solar insolation can be effective in reducing attacks on adjacent trees. These 

treatments can be very effective in small isolated infestations, but may not be effective in 

outbreak situations.

Trap trees – Trees that are intended to be sacrificed can be baited with aggregation 

pheromones to attract large numbers of beetles; trees are either treated with insecticides 

or are felled and removed before the brood matures and emerges. 

Management in the lower montane forests of ponderosa pine and Douglas-fir typically includes 

thinning out smaller trees and prescribed burning to reduce hazardous fuels, improve forest 

health, and restore ecological processes. Mastication is often used in the lower montane zone. 

Mesic forests, primarily lodgepole pine and spruce-fir, generally have too much biomass to use 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

94—Chapter 3. Affected Environment and Environmental Consequences

mastication to achieve management objectives. The current mountain pine beetle epidemic has 

exceeded any possible control capabilities. Management in the general forest is limited to 

salvaging dead and dying trees to reduce hazardous fuels to recover economic value where 

feasible and along roads and trails to provide for public safety. Some spruce beetle outbreaks 

can be prevented by removing large spruce trees within two years of being wind thrown. 

All Alternatives

Tree-cutting within roadless areas is anticipated to be relatively modest under any alternative. 

Almost all of the forest vegetation would remain unmanaged over the next 15 years. 

Unmanaged areas, particularly in the ponderosa pine and Douglas-fir cover types, would likely 

continue to depart from historic conditions and would likely experience uncharacteristic fire 

behavior. 

Tree-cutting and road construction restrictions indirectly affect tree mortality associated with 

insect and disease agents and would result in some landscapes being less resilient to large-scale 

insect and disease outbreaks because of high stocking levels. 

These outbreaks could worsen with projected climate change impacts. Climate change 

projections do not currently have the accuracy at fine resolutions to anticipate site-specific 

outcomes and responses. Therefore, alternatives that offer the most management flexibility 

would be more likely to achieve healthy forest stands, more resilient to climate change and 

other stressors.

Assisted migration through reforestation of species or genetics that are better adapted to future 

climates could potentially increase the resiliency of forests to increased temperatures and 

variable precipitation. Alternatives that would treat more acres would create more 

opportunities to respond proactively to climate change.

Larger areas of stands with forest health concerns may conflict with land management 

objectives including a potential increased wildfire hazard and effects on adjacent lands. 

Standing and down dead trees add to the hazardous fuel load, which can result in wildfire 

impacts on forest and adjacent lands. 

Alternative 1- 2001 Roadless Rule

Under this alternative, tree-cutting would be limited to the following: 1) small diameter timber

needed to restore ecosystem composition and structure or improve threatened, endangered, 

proposed or sensitive species habitat; 2) incidental cutting associated with permitted activities; 

3) for personal or administrative use; or 4) within areas that have already been substantially 

altered that do not require road construction. 

There is no associated road construction exception to facilitate the tree-cutting. Costs often 

increase substantially with the distance of a project from a road. Lands within one-quarter to 

one-half mile of existing roads would be the most likely to have some trees cut and/or removed 

consistent with the above tree-cutting limitations. 

Under this alternative, based on forest projections, annually approximately 1,200 acres in IRAs 

and 1,100 acres in CRAs that are not in IRAs would have tree-cutting activities to contribute to 

hazardous fuels reduction and other forest vegetation management. Tree-cutting and road 

construction have more restrictions on the majority of the IRA acres. The restrictions on forest 

management activities under alternative 1 are more restrictive than any of the other 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—95

alternatives, except for the upper tier of alternatives 2 and 4. There would be some limited 

opportunities to reduce hazardous fuels near communities but in many cases, the forest 

conditions, technical and economic conditions may not fit the exceptions in this alternative. This 

alternative would not substantially improve forest health and hazardous fuel conditions.

Alternative 2 –Colorado Roadless Rule (Proposed Action)

This alternative provides greater opportunities to improve forest health to meet desired 

vegetation conditions compared to alternatives 1 or 4. This alternative has three exceptions to 

the prohibition on tree-cutting, sale or removal for forest health purposes. The exceptions 

would not be allowed within the 562,200 upper tier acres. 

Tree-cutting to reduce the wildfire hazard to an at-risk community is restricted to the CPZ. The 

CPZ within one-half mile of communities is approximately 285,000 acres; 29,000 are upper tier

acres. Where the CPZ meets the requirements of the rule and extends an additional mile, there 

are an additional 750,000 CPZ acres; 108,000 of these are upper tier acres. 

Tree-cutting to reduce the wildfire hazard to a municipal supply system can extend beyond the 

CPZ if warranted. Tree-cutting to maintain or restore characteristics of ecosystem composition, 

structure and processes, including the possibility of treatments for insect and disease

prevention, are not limited to a specific area of the CRAs. Neither is allowed within the upper 

tier acres; 425,000 upper tier acres are outside of the CPZs. 

Temporary roads can be constructed to facilitate the tree-cutting only within the first one-half 

mile of the CPZ which would greatly restrict what tree-cutting would be accomplished for 

restoration and maintenance of ecosystem characteristics, including prevention of disease and 

insect spread.

Under this alternative, based on forest projections, annually approximately 5,800 acres in CRAs 

and 1,200 acres in the substantially altered acres (that are within the IRAs but are not within the 

CRAs) would be treated by tree-cutting practices, for hazardous fuels reduction and/or for

maintenance or restoration of ecosystem characteristics.

Although this alternative is unlikely to substantially improve forest health and hazardous fuel

conditions overall, the increased flexibility compared to alternatives 1 and 4 would increase the 

likelihood of achieving management objectives in critical areas, especially in the CPZs. Like 

alternative 1, the feasibility of tree-cutting without temporary road access would limit the extent 

of forest health treatments in large portions of roadless areas. The upper tier CRA acres would

preclude forest health treatments involving tree-cutting and may thereby lead to larger areas of 

dead trees, and potentially larger and more damaging wildfires. 

Alternative 3 – Forest Plans (No Action)

Compared to the other three alternatives, this alternative provides the greatest opportunities to 

achieve resource management objectives that include improving forest health and reducing 

hazardous fuels. While forest plan direction may limit tree-cutting, sale or removal and road 

construction in some of the analysis acres, generally forest management to improve forest 

health would be allowed on most acres. Economics would limit the extent of forest management 

in portions of roadless areas that would continue to be unroaded.

Under this alternative, based on forest projections, annually approximately 16,600 acres within 

the analysis area would be treated by tree-cutting practices, for hazardous fuels management 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

96—Chapter 3. Affected Environment and Environmental Consequences

and/or other purposes. Although this alternative provides the most flexibility for management, 

accessibility and other resource requirements would result in most of the roadless area 

remaining unmanaged and at high risk of mortality over the next 15 years.

Alternative 3 would not improve forest health or reduce hazardous fuels on most of the area 

within roadless areas but it provides more flexibility than the other three alternatives to address 

concerns that arise and increases the likelihood of achieving management objectives in critical 

areas, especially in the wildland urban interface. 

Alternative 4 –Colorado Roadless Rule with Public Proposed Upper Tier 

This alternative provides greater opportunities to conduct forest health treatments for 

maintenance and restoration of ecosystem composition and structure than alternative 1 but less 

than alternatives 3 or 2. This alternative has the same three exceptions to the prohibition on treecutting, sale or removal for forest health purposes as alternative 2. Like alternative 2, these 

exceptions would not be allowed within the upper tier acres. The upper tier acres under this 

alternative are 2,614,200, over 2 million acres more than alternative 2.

Tree-cutting to reduce the wildfire hazard to an at-risk community is restricted to the CPZ. The 

CPZ within one-half mile of communities is approximately 285,000 acres; 43% or 122,000 are 

upper tier acres proposed under this alternative. Where the CPZ meets the requirements of the 

rule and extends an additional mile, there are an additional 750,000 CPZ acres; 415,000 of these 

are upper tier acres, or 55% of the additional CPZ acres under this alternative. Where the CPZ 

has the conditions to extend to 1.5 miles, slightly over half are upper tier acres where no forest 

health tree-cutting is allowed.

Tree-cutting to reduce the wildfire hazard to a municipal supply system can extend beyond the 

CPZ if warranted and tree-cutting to maintain or restore ecosystem characteristics, including 

current composition and structure, is not limited to a specific area of the CRAs. Neither is 

allowed within the upper tier acres; over 2 million upper tier acres are outside of the CPZs. 

Temporary roads can be constructed to facilitate the tree-cutting only within the first one-half 

mile of the CPZ which would greatly restrict what tree-cutting would be accomplished for the 

forest health activities designed to maintain or restore ecosystem characteristics.

Under this alternative, based on forest projections, annually approximately 1,800 acres in CRAs 

and 1,200 acres in the substantially altered acres that are within the IRAs but are not within the 

CRAs would be treated by tree-cutting practices, for hazardous fuels reduction and/or forest 

health purposes. 

This alternative is unlikely to substantially improve forest health and hazardous fuel conditions 

overall. There is some increased flexibility compared to alternative 1 to achieve management 

objectives in critical areas, especially in the community protection zones but much less than 

alternative 3 and less than alternative 2 because of the large amount of upper tier acres. Like 

alternatives 1 and 2, the feasibility of tree-cutting without temporary road access would limit 

the extent of forest health treatments designed to maintain or restore ecosystem characteristics 

in large portions of roadless areas. 

Forest Health – Insects and Diseases: Cumulative Effects

Cumulative effects to forest health were considered in terms of forested lands in Colorado. 

Table 3-11 displays the level of insect and disease outbreaks within the analysis area. Similar 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—97

forest health concerns exist outside of roadless areas with the potential to spread into adjacent 

roadless areas. Conversely, forest health concerns within roadless areas have potential to 

expand to adjacent areas.

Congressionally designated areas such as wilderness areas and wild and scenic rivers have 

restricted management in some areas near roadless areas. Forest plan management area 

allocations allow, restrict, or prohibit forest vegetation management activities in various ways. 

The Southern Rockies Lynx Amendment placed additional restrictions on some vegetation 

methods and timing within the spruce-fir habitat type.

Roaded areas would continue to be more intensively managed than roadless areas. Forest 

management permitted under each alternative would cumulatively provide for meeting forest 

health and other management objectives across the landscape; however, cumulative restrictions 

would reduce the ability to achieve some desired conditions of healthy forests and fire hazard

reduction. Restrictions would reduce forest growth rates and would slightly reduce the longterm sustained yield of timber.

Forest health treatments and other forest management projects are limited to some degree in 

roadless areas under any of the alternatives. Tree-cutting and road construction restrictions and 

economic limitations would add to existing treatment constraints in Wilderness and other 

special area designations. Alternatives 1, 2, and 4 would result in a cumulative reduction of 

opportunities to improve forest health conditions and achieve other management objectives on 

NFS lands in Colorado. 

Forest Health – Invasive Species: Affected Environment

Invasive species include non-indigenous plant species that have adverse economic, 

environmental and/or ecological effects on the habitats they invade. It is recognized that other 

invasive taxa besides non-indigenous plants (e.g. New Zealand mudsnails, exotic fish and 

others) are a threat in Colorado ecosystems. However, with such species, the outcomes 

associated with disturbance and changes in roadless area management are poorly understood.

Non-plant invasives are perceived to be much less predictable, and because much less is known 

about their dispersal mechanisms, this section will deal only with invasive plants. Although 

there are differences in definitions between the terms ―invasive plants‖ and ―noxious weeds‖, 

the two will be used interchangeably.

Invasive plants become established after seed or other plant parts have been imported to an 

area, and where suitable environments exist. Often ground disturbance creates ideal conditions 

for invasive plant establishment. Once established, invasive plants often become detrimental to 

resource values, and these detrimental effects may persist for decades or perhaps indefinitely 

(Olson 1997). Sources of soil disturbance which create opportunity for invasive plant invasion 

include wildfire and prescribed fire, mechanical vegetation treatments, livestock grazing, road 

construction, LCZ construction, recreation activities including hiking, horseback riding, off-road 

vehicle use, and a variety of other activities. Areas such as road cuts and fills, mines, sites where 

mechanical vegetation treatment has occurred, and gravel pits can aid the spread of noxious 

weeds (Baker 1986). The spread of invasive species may be exacerbated by projected impacts of 

climate change if native plants become stressed and less competitive.

Currently, there are seventy-one invasive plant species which are classified as ―noxious weeds‖ 

by the Colorado Department of Agriculture (2001). Aside from their effects on production 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

98—Chapter 3. Affected Environment and Environmental Consequences

agriculture, the effects of noxious weeds can also degrade wild lands such as national forests, 

state parks, county open space lands, and other natural areas. Such degradation may be 

manifested in one or more of the following ways:

Reduction of biological diversity; degrading ecosystem health, recreation values and 

scenic beauty, all of which can negatively impact resource values generally associated 

with uninfested areas 

Declines in terrestrial habitat for wildlife

Increase in overland water flows, resulting in soil erosion and stream sedimentation, 

causing a decline in water quality (Lacey et al. 1989)

Alteration of ecosystem functions such as nutrient cycling, watershed stability, and 

others.

Approximately three percent of all lands in Colorado were estimated to be occupied by invasive 

plants at some density (Colorado Department of Agriculture 2001). Within Colorado, important 

invasive plants are identified as ―noxious weeds‖ under State agricultural laws, and listed as 

either A, B, or C list species according to their potential threat to agricultural or wildland values 

within the State. (The A list includes the newer invaders, generally less abundant with more 

potential for eradication and control; the B and C list species include less important, and 

generally more abundant species, which tend to be more widely established.) In Colorado there

are 18 plant species on the ―A list‖; 39 on the B list; and 14 species on the C list.

Each of the Colorado National Forests has identified ―priority‖ invasive species. Priority Species 

as defined in the Rocky Mountain Region Invasive Species Management Strategy, are species 

which are low in abundance, have the ability to establish dominance in plant communities, and 

invade a variety of relatively healthy ecosystems. Priority invasive plants by Forest are 

identified in the Forest‘s Invasive Species Action Plans, located on the internet at 

http://www.fs.fed.us/r2/resources/.

Current noxious weed management programs on Colorado national forests are preventing 

substantial increases in total acres of invasive plant populations. Substantial increases in 

noxious weeds on a broad scale are likely to have a measurable effect on long term health of 

forest and rangelands on all forests. Where populations of invasives currently exist, population 

expansion as a result of existing avenues would continue at the current estimated rate of 8-12% 

annually, depending on species, site characteristics, and other variables (Hiebert and 

Stubbendieck 1993). Indirect effects could result from the gradual steady encroachment of 

newly established invasive plant populations over the long term, particularly if resources are 

not available to conduct ongoing detection and treatment of new populations.

Forest Health – Invasive Species: Environmental Consequences 

All Alternatives

In all alternatives, the placement of acres in roadless areas could over the long run have a lower 

risk of invasive plant invasion and/or spread. The prohibitions on management activities limit

ground disturbing activities, and thereby reduce the likelihood of the spread of invasive 

species. 

The Invasive Species Executive Order 13112 (1999) directs federal agencies to use relevant 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—99

programs and authorities to: (1) prevent the introduction of invasive species; (2) detect and 

respond rapidly to and control invasive populations efficiently and safely; (3) accurately 

monitor invasive populations; (4) provide for restoration of native species and habitat

conditions in ecosystems that have been invaded; and (5) promote public education on invasive 

species. 

In all alternatives, best management practices are implemented for all disturbance activities, 

which are designed to minimize or prevent the spread of invasive species. These practices are 

summarized as follows: 

1. Use of certified weed free straw or mulch if re-seeding or other restoration practices are 

used post-project.

2. Where gravel is imported for road surfacing, acquire from gravel pits which are 

inspected and known to be weed free. 

3. Inspection of seed by a seed lab, to ensure the absence of noxious weeds. 

4. Washing of vehicles used in off-road operations such as skid trail construction, skidding, 

or other equipment prior to entry into the Forest. 

A complete listing of Best Management Practices for Invasive Plant prevention can be found at 

http://www.fs.fed.us/r2/resources/ and these practices should be applied to all grounddisturbing activities. 

Vehicular travel is widely accepted to be a major source of transport of exotic plant seed 

throughout the western United States (Sheley et al. 1995, USDA Forest Service, 2003a). Other 

mechanisms that spread noxious weeds include heavy equipment, humans, and livestock. 

Linear construction zones are a short-term use for motorized transport to install linear facilities. 

Because of the short-term use there is less likelihood of elevating the risk of invasive plant 

import, establishment and spread than from road construction and use. When vegetative 

manipulation (harvest, prescribed burning, etc.) opens the tree canopy and allows more 

sunlight to reach the soil, site conditions are often created which are more favorable to invasion. 

Transported seed in camping equipment, clothing and equipment unloaded from vehicles by 

National Forest users is often inadvertently deposited, allowing new invasive plant populations 

to become established. Under all alternatives, numerous natural mechanisms also spread weeds 

including wildlife (birds, rodents, and big game), livestock, wind, and flowing water. After seed 

is imported into an area, invasive plants are often able to successfully establish in certain 

habitats even without ground disturbance, due to their aggressive nature and adaptability. 

Once new populations are established by wind, wildlife, etc, any subsequent increases of 

human activity and ground disturbance would likely accelerate the spread.

In all alternatives, road decommissioning may cause a gradual reduction in the likelihood of 

imported seed. Cleaning of equipment prior to use and routine roadside monitoring for new 

populations can minimize the likelihood of roadside populations spreading from the roadway 

and/or harvest areas into native habitats. While roads can be a contributing factor to the import 

of seed, they may also improve the ease with which invasive plant populations can be managed 

due to improved access to the site. The traditional cost of chemical or mechanical treatment in 

Colorado‘s forests on an acre of weeds is approximately $50-75 where vehicle access is easy due 

to the presence of roads or motorized trails. Comparatively, remote infestations cost 5-8 times 

that amount, when treatment must occur through the use of horses, hiking, or other primitive

access. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

100—Chapter 3. Affected Environment and Environmental Consequences

Under each alternative there are projected or foreseeable activities which would likely result in 

ground disturbance, increased vehicle activity, construction and other activities. All activities 

generally elevate the risk of invasive plant import, establishment, and spread. Comparisons of 

alternatives disclose the estimated relative degree of elevated risk which could occur as a result 

of the range of activities. In all alternatives, potential increases in the introduction or spread of 

invasive plants would be minimized by implementing standard or required mitigation

measures. 

Alternative 1- 2001 Roadless Rule 

Under alternative 1, ground disturbance in the roadless areas resulting from potential future 

road construction and other management activities is projected to be the lowest of the four 

alternatives under consideration. By maintaining a high level of limitation on future road 

construction or reconstruction and tree-cutting activities within roadless areas, the introduction 

or spread of invasive plants would remain limited to the current rate of invasive species spread 

resulting primarily from the natural mechanisms mentioned in the introductory part of this 

section. The use of linear construction zones is not limited in this alternative. Although linear 

construction zones are used for only a short duration of time, they do provide opportunities for 

invasive species to become established. For those areas not included in roadless area 

classification under this alternative or IRAs that have been substantially altered, new invasive 

populations could more readily become established due to vehicular transport of seed, and 

higher levels of human activity, thus the rate of spread would likely be expected to be higher. 

Alternative 2- Colorado Roadless Rule (Proposed Action)

Under alternative 2, potential future ground disturbance resulting from management activities 

is intermediate among the alternatives under consideration. Invasive plant expansion due to 

vehicles and human activity, including foreseeable management activities, would likely be 

somewhat higher than alternatives 1 and 4 and less than alternative 3. 

Foreseeable activities that are increased from alternatives 1 and 4 include road construction and 

tree-cutting for maintenance and restoration of ecosystem characteristics and community 

protection purposes. Coal development is higher under this alternative than under alternative 1. 

Although most roads constructed in this alternative are temporary, there is a moderate risk of 

import of noxious weed seed for the length of the project. The use of linear construction zones is 

limited in this alternative. Increased risks of invasive plant establishment and spread are only 

expected in the small percentage of the CRA acreage where these activities would occur. For the 

majority of the CRA acres, including the newly identified roadless acres within the CRAs and 

the upper tier acres, there is a minimized risk of future plant establishment and spread. The 

acres that have been removed from the CRAs would likely have some increased management 

activities and may see elevated levels of invasive plant establishment and spread. 

Alternative 3 – Forest Plans (No Action)

Alternative 3 has the highest amounts of potential ground disturbance due to projected road 

construction/reconstruction, tree-cutting, fuels management, future oil and gas activities, and 

coal activities outside the North Fork coal mining area in roadless areas. The use of linear 

construction zones is not limited in this alternative. Although linear construction zones are used 

for only a short duration of time, invasive plants could be introduced. This alternative would 

therefore result in a substantially higher risk scenario for invasive plant establishment, as 

compared to the other three alternatives.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—101

Under alternative 3, forest plans include allowances for temporary or permanent forest road 

construction, and tree-cutting, sale or removal for a variety of purposes on many of the acres. In 

these cases, there would be a moderately higher risk of import of noxious weed seed, and 

therefore a higher risk of establishing and spreading new populations. Indirect effects could 

result from the gradual steady encroachment of newly established invasive plant populations 

over the long term. 

Alternative 4- Colorado Roadless Rule with Public Proposed Upper Tier

Under alternative 4, invasive plant expansion due to vehicles and human activity, including 

foreseeable management activities, would likely be somewhat higher than alternative 1 but less 

than alternatives 2 and 3 based on the projections of future activities. 

Foreseeable activities include road construction and tree-cutting for hazardous fuel treatments 

around communities and coal development in the North Fork coal mining area. The use of 

linear construction zones is limited in this alternative. Although most roads constructed in this 

alternative are temporary, there is a moderate risk of import of noxious weed seed for the 

length of the project. Increased risks of invasive plant establishment and spread are only 

expected in the small percentage of the CRA acreage where these activities would occur. For the 

majority of the CRA acres, including the newly identified roadless acres within the CRAs and 

the upper tier acres, there is a minimized risk of future plant establishment and spread 

compared to alternatives 1 and 2. A much greater percentage of CRA acres are identified as 

upper tier, where little to no activity would occur. The acres that have been removed from the 

CRAs would likely have some increased management activities and may see elevated levels of 

invasive plant establishment and spread. 

Forest Health – Invasive Species: Cumulative Effects 

Roads are often the primary vectors for noxious weed establishment and spread. When there is 

an increase in the numbers of vehicles using NFS roads and roads adjacent to NFS lands, there 

is an elevated risk of seed transport. Taken cumulatively, an increase in roads and road use 

combined are likely to represent a measurable, if not quantifiable adverse effect to the extent 

and distribution of invasive plant populations in and around National Forests in Colorado in 

the future.

Current State and Federal activities and authorities (such as the Rocky Mountain Region‘s 

Invasive Species Management Strategy [http://www.fs.fed.us/r2/resources/] and the National 

Strategy and Implementation Plan for Invasive Species Management address some invasive 

species and their prevention and spread (USDA Forest Service 2004a). Other programmatic 

policy and management direction can also indirectly influence the ability to construct roads. 

The Travel Management Policy24 can provide information on what roads are needed and 

unneeded, and which roads would remain open or closed. As roads are decommissioned, fewer 

roads are constructed and with additional emphasis on invasive species management and 

prevention, there would be little cumulative effects from any of the alternatives. 

 

24 Federal Register / Vol. 70, No. 216 / Wednesday, November 9, 2005 / Rules and Regulations pages 68264 –

68291; http://www.fs.fed.us/recreation/programs/ohv/final.pdf
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

102—Chapter 3. Affected Environment and Environmental Consequences

FIRE AND FUELS

This analysis evaluates the relative ability to treat hazardous fuels primarily within the 

wildland urban interface because this is a major focus area of the National Fire Plan, Healthy 

Forest Restoration Act (HFRA), Healthy Forest Initiative and congressional budget direction. 

The prohibitions and exceptions for tree-cutting, sale or removal and road construction or 

reconstruction contained in the four alternatives influence the ability to treat hazardous fuels 

which can affect the amount of hazardous fuels, frequency and intensity of wildfire, and 

response to wildfires.

Introduction

Wildland fire plays an integral role in many forest and rangeland ecosystems. Decades of efforts 

at extinguishing most fires on public lands have disrupted the natural fire regimes that once 

existed and have increased the fuel loadings. In April 1999, the General Accounting Office 

(GAO) published a report entitled Western National Forests: a Cohesive Strategy is Needed to 

Address Catastrophic Wildfire Threats (http://www.gao.gov/products/RCED-99-65). In the 

report, the GAO states that, "[t]he most extensive and serious problem related to the health of 

national forests in the interior West is the over-accumulation of vegetation." 

The Forest Service responded to the GAO report by developing, "Protecting People and 

Sustaining Resources in Fire-adapted Ecosystems: A Cohesive Strategy" (Cohesive Strategy) 

(http://www.fs.fed.us/publications/2000/cohesive_strategy10132000.pdf). Approved on 

October 13, 2000, the Cohesive Strategy provides an approach to achieve improved forest and 

grassland resilience, protect people and communities and sustain resources by reducing fuel

loadings in fire-prone forests. In addition, in September 2000, the USDA and United States 

Department of Interior (USDI) issued a report titled Managing Impacts of Wildfires on 

Communities and the Environment (USDA Forest Service and USDI 2001). This report provided 

a strategic framework for reducing hazardous fuels within the Wildland Urban Interface (WUI), 

readily accessible watersheds, threatened and endangered species habitat, and other important 

local factors. This report, along with the USDI and Related Agencies Appropriations Act of 2001 

and other strategies is known as the National Fire Plan (NFP). As a result of the NFP, reducing 

hazardous fuels in Colorado became a priority for the Forest Service. Reducing fuel loadings 

can be accomplished by several methods; however, the most common used in Colorado include:

thinning, commercial timber harvest, stewardship projects, prescribed burning, and other 

mechanical biomass treatments such as hydro-mulching.

The Cohesive Strategy identifies priority areas for fuel reduction across the interior West. The 

priority areas include: (1) WUI areas where flammable wildland fuels are adjacent to homes and 

communities; (2) readily accessible municipal watersheds; (3) threatened and endangered

species habitat; (4) maintenance of existing low risk Condition Class 1 areas25. 

 

25 The historic disturbance regime in Condition Class 1 areas is largely intact and functioning as defined by the 

historic natural fire regime.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—103

Fuel Treatments 

Fuel treatments are not performed to prevent fires but to alter fuel profiles so that public and 

firefighter safety is improved and communities, watershed, infrastructure, and other values-atrisk are less vulnerable to wildfire impacts. The goals of hazardous fuel treatments are to 

achieve some combination of (a) reducing flammability, (b) reducing fire intensity, (c) reducing 

the potential for creating firebrands (spotting) and crown fires, and (d) increasing firefighter 

safety and effectiveness. 

For hazardous fuels management to create the desired effect on fire behavior, management 

strategies must address the local and landscape scales. Local scale addresses effects of fire 

within a forest stand, treatment unit, or adjacent to or including the area around a house or 

other structure (Finney and Cohen 2003). Treatment of fuels only within the structure ignition 

zone (within 200 feet of structures) is not sufficient to reduce the threat to neighborhoods and 

individual structures. Fuel treatments outside and adjacent to a structure ignition zone could 

reduce flame and firebrand exposure (Finney and Cohen 2003). Research by Cohen (1995) has 

shown that structures with typical ignition characteristics are at risk of catching on fire from one 

of three sources: (1) direct exposure to intense flames from a nearby source (structures may be 

at risk from a flame front no more than 100 feet away); (2) less intense sources against or very 

near the side of the structure which can occur if a ground fire or firebrands ignite firewood or 

other flammable material next to the structure; and (3) firebrands (spotting) falling directly on 

roofs if the roof is flammable or if flammable debris is present.

Spotting is defined as behavior of a fire that produces firebrands that are transported by 

ambient winds, fire whirls, and/or convection columns causing spot fires ahead of the main fire 

perimeter (Andrews 1996; National Wildfire Coordinating Group 2005). Spotting can occur 

from a few meters to several miles (Albini 1983). 

As there is no mechanism to require homeowners to engage in efforts to reduce the threat 

adjacent to their homes, they would continue to be at risk without management of the 

surrounding fuels. Fire prevention programs, Community Fire Safe Councils, as well as 

Community Wildfire Protection Plans (CWPPs) are valuable tools in communicating to the 

public the need for clearing and maintaining fuels away from residences and structures, 

assisting residences in coordinating local hazard reduction efforts, and educating individuals on 

less flammable building designs and construction materials.

While fuel treatments in themselves would not stop wildland fires, they can change fire 

behavior such that the outcomes are less catastrophic or may increase the effectiveness of fire 

suppression by reducing resistance to control. Fire behavior alteration is accomplished by 

removing ladder fuels and reducing stand densities. Priorities for hazardous fuels reduction are 

to reduce surface and ladder fuels, raise the bottom of the live canopy, reduce stand density by 

thinning, and provide safe zones for firefighters. 

The performance of fuels treatments in wildfire situations has been documented in several 

recent evaluations (Jimerson and Jones 2000; USDA Forest Service 2007; USDA and USDI 2007; 

USDA 2008; Graham et al. 2009). Key findings include:

Where fuels had been treated, fire behavior was noticeably different from that which 

occurred in neighboring untreated fuels. Most fuel treatments reduced fire behavior 

from a crown fire to a surface fire. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

104—Chapter 3. Affected Environment and Environmental Consequences

Treatment location and juxtaposition and the treatments of surface fuels, ladder fuels 

and crown fuels (in order of importance) are major determinates of both wildfire

intensity and burn severity.

The presence of fuels treatments directly impacted the survivability of structures. Area 

fuel treatments adjacent to subdivisions provided important safety zones, increasing 

suppression effectiveness which saved houses. Fuel treatments, when of sufficient size, 

often provide safe zones for firefighters.

Fuel treatments influence burn severity. A higher proportion of acres burned severely on 

untreated lands than where fuel or other vegetation treatments had been applied. 

Reduced fire severity in fuels treatments that result in remnant trees and green 

vegetation would lead to more rapid vegetative recovery compared to high severity 

areas where all trees are black. Fuel treatments that create irregular forest structures and 

compositions, both within and among stands (macro and micro mosaics), tend to 

produce wildfire resilient forests.

Some fuel treatment units burned at high fire intensity because they were adjacent and 

downwind from untreated units. Crown fire momentum carried high fire intensity 

partway into these treated areas before the more widely spaced crowns and reduced 

surface fuel caused the fire to fall to the surface. 

Fuel treatment longevity and effectiveness are dependent on location, dead and live fuel

ratios, and rate, composition, and structure of vegetation recovery. More recent and 

more intensive fuel treatments reduced fire behavior and fire effects more effectively 

than older and less intense treatments. Incomplete or partial treatments are less effective 

or can be ineffective. Large fuel removal alone, without the follow-up treatment of 

smaller diameter fuels, may not provide adequate fuels reduction to prevent a fire from 

becoming stand-replacing. 

Fuel treatments increase suppression effectiveness. By modifying the fire‘s behavior, fuel

treatments present suppression opportunities that otherwise may not have been 

available. When Incident Management Teams had knowledge of treatments, they used 

these treated areas to plan and implement suppression. These opportunities include 

both providing locations for burnouts to placement of hand and machine fire lines. 

Decreased fire intensity in fuel treatments allow fire crews to more easily suppress spot 

fires that may ignite. 

Even in the face of extreme fire behavior, treated areas may slow the spread of the fire 

and disrupt the fire‘s progress. 

In addition to structures in the WUI there are other values to be considered for fuels treatments.

In July 2007, The Pinchot Institute for Conservation released an assessment report titled 

―Protecting Front Range Forest Watershed form High Severity Wildfires‖ (LeMaster et al. 2007). 

Key findings in the report include:

―When forests burn, watersheds also are affected and in the case of high-severity 

wildfires, watersheds are substantially altered. Depending on intensity and duration, 

wildfires can change the soil composition of a watershed by consuming the litter layer at 

the surface of the soil and by destroying binding organic matter in the soil itself. A 

water-repellent zone or layer forms when hydrophobic organic compounds from 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—105

burning vegetation coat soil aggregates or minerals at or parallel to the surface. This 

hydrophobic layer prevents water from penetrating soil aggregates and seals off soil 

during rainfall events, which accelerates surface runoff resulting in the transport and 

deposit of sediments. 

The adverse impacts continue when the water, sediment and debris pour off slopes into 

receiving channels, scouring banks and bottoms, often overwhelming them and causing 

flooding, sometimes many miles away from the precipitating wildfire event. Such 

sediment and organic debris can dramatically alter water courses.

Wildfires are not only a threat to water supplies but the sediment transport and organic 

debris flows that often follow wildfires can be even more problematic. If watersheds are 

not protected through mitigation projects such as fuel breaks, then sediment and organic 

debris can destroy reservoirs as a functional part of the water supply system‖ (see Water 

section).

On national forests in the State of Colorado from FY 2001 to 2009, an average of approximately 

64,000 acres of fuels treatments occurred per year. There was an average of 4,400 acres within 

the IRAs, 1,200 of which were mechanical treatments. There was an average of 3,400 acres 

within the CRAs, 1,100 acres of which was mechanical treatments. Approximately 19% of the 

acres treated within the IRAs occurred within 1.5 miles of the Forests on the Edge (FOTE) 2000 

at-risk communities while 22% of the acres treated within the CRAs occurred within 1.5 miles of 

the FOTE 2000 at-risk communities (Stein et al. 2007).

Affected Environment

Natural disturbances such as fire, wind, and insects and diseases help shape forests. Although 

fire is widespread, it is seldom uniform; every forest has its own characteristic pattern of fire 

intensity, frequency, and size. Fire regime and condition class are used to characterize fire.

Fire Regimes

"Fire regime" refers to the nature of fire occurring over long periods and the prominent 

immediate effects of fire that generally characterize an ecosystem (Brown and Smith 2000, Lyon 

et al. 2008). There are five fire regime types, expressed as fire return interval and fire severity. 

They are, as modified by Keeley et al. (2009):
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

106—Chapter 3. Affected Environment and Environmental Consequences

Table 3-12. Fire Regime Types

Fire 

Regime 

Type

Fire 

Return 

Interval

(years)

Fire Spread 

Driven By Fire Intensity Fire Effects Ecosystem Examples

The fire regime classifications utilized in this analysis are based upon fire severity as detailed in 

Brown and Smith (2000) and the Forest Encyclopedia Network (Lyon et al. 2008). Using this 

system, the understory and mixed severity fire regimes apply only to forest and woodland 

vegetation types. All other ecosystem types are considered to have a stand replacement fire 

regime because the above ground vegetation is typically killed or removed by most fires. 

Fire Regimes in Colorado

The analysis area generally falls into two fire regimes: III (less frequent, mixed severity); and IV 

(less frequent, high severity) (USDI Geological Survey 2007). Approximately 60% of the analysis 

area acreage, within 11⁄2 miles of at-risk community (Stein et al. 2007), is in Fire Regime III and 

20% is in Fire Regime IV. This is important, especially in the WUI, because these fire regimes 

(mixed severity and stand replacement, respectively) are difficult for firefighters to control. This 

leaves communities-at-risk vulnerable to the negative impacts and potentially adverse 

consequences of wildland fires. The table below details the fire regime classes in the 1.5 mile 

CPZ.

I 1-35

Surface and other 

low understory 

fuels

Heavy understory 

and fuel

consumption

Low to moderate fuel

overstory mortality

Ponderosa pine, pine 

oak savannah, dry site 

Douglas-fir

II 1-35 Mostly surface 

fuels Low to moderate

Above ground biomass 

killed, most fuels 

consumed

Drier grassland types, 

tall grass prairie, low 

scrub, some pacific 

chaparral communities

III 35-100 Surface and 

canopy fuels Mixed high and low

High understory 

mortality and fuel

consumption, thinning 

of the overstory

Western mixed conifer, 

dry site shrub 

communities

IV 35-100 Mostly canopy 

fuels High

Above ground biomass 

killed, high fuels 

consumption

Chaparral, sagebrush, 

dry site lodgepole pine

V >200 Mostly canopy 

fuel High

Above ground biomass 

killed, high fuels 

consumption

Subalpine forests, cool 

moist lodgepole pine, 

Engelmann spruce
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—107

Table 3-13. Fire Regime Classes in 1.5 mile CPZ IRAs and CRAs

Fire Regime

Inventoried Roadless Areas Colorado Roadless Areas

Acres in 1.5 mile 

CPZ

Percent of Area Acres in 1.5 mile 

CPZ

Percent of Area

FR I 103,800 10% 107,700 10%

FR II 14,900 1% 14,600 1%

FR III 615,300 59% 619,200 60%

FR IV 215,000 21% 204,000 20%

FR V 43,800 4% 42,700 4%

Other 45,800 4% 46,400 4%

Total 1,038,700 100% 1,034,600 100%

Note: Totals may not add due to rounding

Fire Regime Condition Class

Fire Regime Condition Class (FRCC), also referred to as ―Condition Class‖, describes the degree 

of departure from reference conditions, potentially resulting in changes to key ecosystem

components such as vegetation characteristics (species composition, structural stage, stand age, 

canopy closure, and mosaic pattern); fuel composition, fire frequency, severity, and pattern; and 

other associated disturbances, such as insect and disease mortality, grazing, and drought 

(http://www.fire.org/niftt/released/FRCC_Guidebook_2010_final.pdf).

Condition Classes are defined as follows:

Condition Class 1 – Ecosystems with low (< 33 percent) departure from reference 

conditions and still within the estimated historical range of variability over a specifically 

defined reference period. Risk of losing key ecosystem components is low.

Condition Class 2 – Ecosystems with moderate departure (33 to 66 percent) departure

from reference conditions. Risk of losing key ecosystem components is moderate.

Condition Class 3 – Ecosystems with high (>66 percent) departure from reference 

conditions. Risk of losing key ecosystem components is high.

Characteristic vegetation and fuel conditions are those that occur within the natural fire regime, 

and are categorized as Condition Class 1. Uncharacteristic conditions are those that did not

occur within the natural fire regime, and are categorized as Condition Class 2 or 3. 

In the past 100 years, wildfires in forest ecosystems throughout the West have shown a trend of 

being larger, more intense and causing more damage than the fires that historically occurred in 

those same ecosystems, particularly during drought periods. In CRAs, seven wildland fires over 

1,000 acres in size have occurred since 1980. From 1980 - 2008, over 1,700 ignitions affecting over 

45,000 acres occurred in CRAs/IRAs. Approximately 75% of the fires were caused by lightning 

and 25% were human-caused. 

In Colorado and throughout much of the Rockies, lodgepole pine forests are experiencing a 

severe and widespread epidemic of mountain pine beetle. In Colorado, tree mortality from the 

beetle currently covers over 2.9 million acres, which includes virtually all of the Colorado‘s 

mature lodgepole pine in addition to other forest types. Generally speaking, crown and surface-
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

108—Chapter 3. Affected Environment and Environmental Consequences

fire risks change with time following outbreaks, and factors such as weather and forest 

composition play large roles in determining whether and how intensely a fire would burn 

(Bentz 2009).

Wildland Urban Interface (Community Protection Zones) 

In Colorado, there are currently 1,712 at-risk communities listed in the Federal Register (66 FR 

751). For analysis purposes, housing density information from the National Forests on the Edge 

(FOTE) (Stein et al. 2007) analysis is used as a proxy for communities-at-risk. The FOTE data 

map communities at-risk in Colorado in the year 2000 and projects the communities-at-risk 

(CAR) in the year 2030, based on projections of housing growth. They define three categories of 

housing densities:

Rural I – lands with 16 of fewer housing units per square mile;

Rural II – land with 17 to 64 housing units per square mile; 

Exurban/Urban – lands with 65 or more housing units per square mile.

The Rural II and Exurban/Urban categories were used for this analysis. Census blocks 

identified as Rural II or Exurban/Urban were buffered with an area defined as the ―community 

protection zone‖ (CPZ). CPZ and WUI are used interchangeably in this analysis. The CPZ 

extends one-half mile from the boundary of an at-risk community, and up to one additional 

mile if any land exhibits one or more of the following characteristics:

1. has a sustained steep slope that creates the potential for wildfire behavior endangering 

the at-risk community; 

2. has a geographic feature that aids in creating an effective fire break, such as a road or a 

ridge top; or

3. is in condition class 3 as defined by HFRA.

The delineation of the CPZ around communities was determined using the 0.5 mile default 

distance and 1.5 miles as the maximum CPZ distance. Approximately 6% and 25% of the 

roadless acres are within 0.5 mile and 1.5 mile respectively of the FOTE 2000 CARs. Over 30% of 

the roadless acres on three National Forests, the Arapaho-Roosevelt, Pike-San Isabel and White 

River, are within 11⁄2 miles of the FOTE 2000 at-risk communities. 

As population increases in these communities, their boundaries may expand closer to National 

Forest land, it is expected that there would be moderate increases in the percentage of roadless 

acres within 1⁄2 mile and 11⁄2 mile of the FOTE at-risk communities. It is forecast that 

approximately 7% and 26% of the roadless acres are within 0.5 mile and 1.5 mile respectively of 

the FOTE 2030 CARs. The most significant increases in the percentage of acres within 11⁄2 miles 

of the FOTE 2030 at-risk communities are on the Arapaho-Roosevelt, Pike-San Isabel and White 

River National Forests. In 2030 it is projected that 35% or greater of the roadless acres on each of 

the forests would be within 11⁄2 miles of the FOTE 2030 at-risk communities. 

Within 1 1⁄2 miles of the 2000 FOTE at-risk communities, approximately 43% of the IRA and 

CRA acreage is in Condition Class 2; and 15% of the IRA acreage and 16% of the CRA acreage is 

in Condition Class 3. These areas are generally in need of some type of fuel treatment to reduce 

the wildland fire threat to the public and firefighters, as well as to reduce the hazard to 

communities, municipal water supplies, and other local resources consistent with A 

Collaborative Approach for Reducing Wildland Fire Risks to Communities and the Environment: 10 Year 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—109

Comprehensive Strategy (USDA and USDI 2006). The table below details the current Condition 

Class present in the IRAs and CRAs. 

Table 3-14. Condition Class in 1.5 mile CPZ in IRAs/CRAs

Inventoried Roadless Areas Colorado Roadless Areas

Condition Class Acres in 1.5 mile 

CPZ

Percent of Area Acres in 1.5 mile 

CPZ

Percent of Area

Total 1,035,100 100% 1,031,000 100%

Note: Totals may not add due to rounding

Carbon Storage and Fire

Forests can help mitigate atmospheric greenhouse gases by storing carbon in vegetation and soil

(carbon sink); however, changes to forests, like fire, insects, and other disturbances, can result in 

greenhouse gas emissions (carbon source). Movement of carbon from the atmosphere into 

vegetation and soil, and back into the atmosphere, is a fundamental part of the terrestrial

carbon cycle. Changes in this cycle can be natural, or influenced by human activities. Fires can 

dramatically impact the amount of stored carbon released into the atmosphere. Stand-replacing

fires switch forest ecosystems from a carbon sink to a net source of carbon added to the 

atmosphere. Fires are a natural part of much of the western landscape; however, they have been 

altered though fire suppression and other forest management activities. Climate change is likely 

to increase the magnitude and frequency of fires in Colorado, as well as other Western states.

Forests contain large amounts of carbon, stored as biomass both in the above-ground biomass 

and soil component. Forests accumulate carbon through the process of photosynthesis, which 

converts sunlight and water to carbon. As the majority of forest ownership in Colorado is on 

federal lands, national forests are important for carbon storage. 

Forests in the United States are thought to have been in approximate carbon balance from 1600 

to 1800. A large pulse of carbon release occurred during the 1800s, largely due to utilization of 

forests (cutting) and land conversions, primarily to agricultural uses. The last century saw a regrowth of forests that had been harvested and the re-establishment of forests on abandoned 

agricultural lands. These conditions resulted in carbon storage in domestic forests. In the West, 

the effects of fire suppression are thought to have been a contributor to this increase in stored 

carbon (Birdsey et al. 2006). 

Environmental Consequences 

It is anticipated that most of the projected future treatments would generally be targeted at 

community protection in the mountain pine beetle impacted areas of the WUI in addition to the 

general priorities of lower elevation ponderosa pine, Gambel oak, Douglas-fir and dry type 

lodgepole pine. These are Fire Regime I, II and III, and Condition Class 2 and 3.

1 386,900 37% 381,400 37%

2 445,700 43% 440,300 43%

3 157,000 15% 163,700 16%

Other 45,500 4% 45,600 4%
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

110—Chapter 3. Affected Environment and Environmental Consequences

Assumptions Related to Hazardous Fuels Treatment Tools

Stephens et al. (2009) found that a combination of mechanical and fire treatments were the most 

effective in reducing fire severity. A single fire only treatment that creates standing dead trees 

would increase future fuel loads when the dead trees fall and shorten the longevity of fuel 

treatments. They found that several fire-only treatments would be needed to achieve a desired 

condition for potential fire behavior.

The longevity of the fuel reduction from these treatments depends on the type of treatment and 

the vegetation type. The period of effectiveness may be a relatively short time for fuel types

with a simple structure such as grasslands, or many years in more complex fuel types such as 

multi-storied coniferous forests. 

The period of time over which fuel reduction remains effective depends upon:

the type and intensity of the treatment, 

the number of fuel layers involved, 

the rate of accumulation of fuels, 

fuel decomposition rates, and other factors. 

Even though prescribed fire is not limited or restricted in any of the alternatives there may be: 

1. a reduction in the number of acres treated because the risk of escape is too high due to 

the inability to mitigate high fuel loadings in burn units or the inability to create a buffer 

of sufficient depth to reduce the risk of an adverse outcome of an escaped fire to 

communities or

2. an increased risk of escape due to the need for multiple prescribed fire treatments to 

achieve the desired fuels conditions. 

Prescribed fire alone, without mechanical treatments, is not likely to be a primary fuels 

treatment within the WUI due to a high risk of escape.

Assumptions Related to Access (Roads) and Costs of Hazardous Fuel Reduction

Only authorized roads are used for hazardous fuel management. 

The four alternatives vary in the ability to use temporary roads to facilitate tree-cutting, sale or 

removal activities for hazardous fuels management. Critical locations within roadless areas may 

not be treated if the area cannot be accessed by roads. This can be due to factors such as:

Size of material too large for hand treatments.

Amount of material to be treated would result in unacceptable fuels beds; without 

removal the result is in a minimal reduction in fire hazard.

Size of trees to be treated exceeds mastication equipment capabilities, generally 

maximum 8-10 inches diameter at breast height.

Inability to ―walk‖ equipment into critical treatment areas due to terrain and or distance 

limitations.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—111

Assumptions Related to Hazardous Fuels Management and Response to Wildland 

Fires

Depending on the degree to which each alternative limits treatment activities in roadless areas, 

the following components of the wildland fire management program may be affected:

None of the alternatives considered restricts the management response to a wildfire.

The inability to conduct vegetation treatments to create defensible fuels profiles in the 

WUI/CPZ and in areas outside of the WUI/CPZ could result in an increase in fire 

suppression costs, property loss, and other economic impacts. 

Fewer hazardous fuels treatments can result in a higher risk of high-severity wildfires.

The inability to disrupt the flow of fire across the landscape could impact both 

prescribed fire and wildfire management. 

Prohibitions on tree-cutting could result in fewer tactical options being available to fire 

management personnel. In areas with fuel treatments, there is often an increase in 

suppression opportunities. 

Depending on the point of ignition, as well as other factors, wildland fires could have 

the potential to become larger and more damaging as a result of no road access. Roads 

serve as fuel breaks, suppression fire lines, anchor points, and most importantly as 

safety zones for firefighters. 

Roads provide efficient access for firefighting crews and other suppression resources 

such as engines and heavy equipment for fire line construction, as well as aviation 

support needs. A lack of access can increase the exposure of firefighters to possible 

injury due to an increased reliance on hand treatment methods resulting in multiple 

trips, longer periods of exposure, and exposure to multiple hazards including rolling 

materials, lifting and burns. 

Larger and more damaging fires may result in the need for extensive and costly 

restoration and rehabilitation needs within roadless areas. The higher severity and 

larger fire size could result in increased adverse post fire effects due to erosion and 

slower vegetation recovery on lands near community watersheds or infrastructure.

As a measure of potential effects, each alternative was evaluated to determine the impact it 

would have on the ability to conduct hazardous fuels reduction treatments in the WUI/CPZ

and the resulting impact on wildland fire management. 

Alternative 1- 2001 Roadless Rule

This alternative is the most restrictive of the four alternatives in treating hazardous fuels. Under 

this alternative, tree-cutting, sale or removal is generally prohibited in IRAs with very limited 

exceptions. The one tree-cutting exception that could be used to reduce hazardous fuels is the 

cutting of generally small diameter trees to maintain or restore the characteristics of ecosystem

composition and structure within the range of variability that would be expected to occur under 

natural disturbance regimes of the current climatic period. As stated in the Analysis Framework 

section of this chapter, this exception would be utilized primarily in the ponderosa 

pine/Douglas-fir and pinyon-juniper forest cover types. Lodgepole pine cover types rarely fit 

this exception. There is no corresponding road construction exception. Fuel reduction activities 

would generally consist of prescribed burning, mechanical treatments using existing roads, and 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

112—Chapter 3. Affected Environment and Environmental Consequences

hand treatments.

Under this alternative, approximately 900 acres per year of mechanical fuels treatments is 

projected (tree-cutting, sale or removal) within the IRAs. The analysis area outside of the IRAs, 

managed according to direction in the forest plans, have a projected 900 acres per year of 

mechanical fuels treatments. An additional 500 acres per year of tree-cutting (not including 

incidental, administrative or personal use tree-cutting) are projected for purposes other than 

hazardous fuels reduction that may or may not modify fire behavior to meet desired conditions. 

Three hundred of the 500 acres are within IRAs and 200 acres are within the rest of the analysis 

area. Approximately 0.2% of the IRA acres would be treated per decade with an additional 2.6% 

of the analysis area outside of the IRAs treated per decade according to forest plan management 

direction. These projections are shown in Table 3-2.

The prohibition on road construction would result in less hazardous fuels treatment. Fuel 

reduction treatments would likely be focused in the substantially altered portion of the IRAs 

where there are existing roads. Other than in the roaded areas of the IRAs, fuel treatments that 

are completed are likely to be more expensive and less efficient to implement. This would result 

in the timeline for treating priority fuels being extended with incrementally increasing costs. 

There would be a higher risk of a high-severity wildfire than in the other alternatives because of 

the smaller amount of hazardous fuels treatments. The lack of tree-cutting and road 

construction would impact suppression opportunities and could result in the need for extensive 

and costly restoration and rehabilitation. 

Fewer treatments for maintenance and restoration of ecosystem composition and structure may 

lead to more dead trees and increase in severity of wildfires, which would release carbon as 

well as potentially unhealthy levels of smoke and particulates into the atmosphere. Without the 

ability to remove material from hazardous fuel and other treatments using roads, the 

opportunity to substitute this material for fossil fuels would be foregone. 

Alternative 2 – Colorado Roadless Rule (Proposed Action)

This alternative is less restrictive than alternatives 1 and 4, but more restrictive than alternative 

3 in treating hazardous fuels in the standard tier. It is more restrictive than alternatives 1 and 3 

and equal to alternative 4 in the upper tier. Under this alternative, tree-cutting, sale, or removal 

is generally prohibited in CRAs with limited exceptions. Two of the tree-cutting exceptions are 

available within the CRAs to reduce hazardous fuels in all but the upper tier acres, where there 

is no tree-cutting for this purpose. Within the CPZ, trees can be cut to reduce the wildfire

hazard to an at-risk community or municipal water supply system. The additional conditions 

that extend the CPZ beyond 0.5 miles are specific and may not allow for many additional 

treatments outside the 1⁄2 mile portion of the CPZ. 

Outside of the CPZ, trees can be cut to reduce the wildfire hazard to a municipal water supply 

system. Temporary road construction is allowed to facilitate the treatments within the first 0.5 

mile of the CPZ only. All of the treatments would focus on small diameter trees to create 

strategic fuel breaks while retaining large trees to the maximum extent practical to the forest 

type. Fuel reduction activities would generally consist of prescribed burning, mechanical 

treatments, and hand treatments.

Under this alternative approximately 5,300 acres per year of mechanical fuels treatments are 

projected (tree-cutting, sale or removal) in the CRAs, with the majority within the first 1⁄2 mile of 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—113

the CPZ. Approximately 12% of the CRA acres within 0.5 miles of the FOTE 2000 at-risk 

communities (the 0.5 CPZ) are in upper tier where no tree-cutting can be done for hazardous 

fuels treatments. Approximately 13% of the CRA acres within 1.5 miles of the FOTE 2000 at-risk 

communities (the maximum 1.5 CPZ) are in upper tier where no tree-cutting can be done for 

hazardous fuels treatments. The analysis area outside of the CRAs, managed according to 

direction in the forest plans, has a projected 600 acres per year of mechanical fuels treatments. 

An additional 1,100 acres per year of tree-cutting for purposes other than hazardous fuels 

reduction (not including incidental, administrative or personal use tree-cutting) that may or 

may not modify fire behavior to meet desired conditions is projected. Five hundred of the 1,100 

acres are within CRAs and 600 acres are within the rest of the analysis area. Projections show 

that 1.3% of the CRA acres are projected to be treated per decade with an additional 2.6% of the 

―substantially altered acres‖ projected for treatment per decade according to forest plan 

direction. Projections are shown in Table 3-2.

The increased flexibility as opposed to alternative 1 for temporary road construction in the first 

0.5 mile of the CPZ could: reduce the costs of treatment; improve the efficiency of treatment 

implementation; increase the tools available to for fire prevention; and facilitate the removal 

and utilization of woody biomass from treated areas. All of the aforementioned items assist in 

the ability to treat priority acres and achieve desired conditions. 

Although there is increased flexibility over alterative 1, critical locations outside the 0.5 mile 

CPZ may not be treated due to the limitations on temporary road construction. There would be 

a higher risk of a high-severity wildfire than in alternative 3 but less than alternatives 1 or 4, 

because of the projected amount of hazardous fuels treatments. Although there is a tree-cutting 

exception and a temporary road construction exception for hazardous fuels treatment, the 

purpose and area available for treatment and temporary road construction is restricted. 

Analysis (Langowski 2009) has shown that under moderate fire weather conditions, gusts of 

2026 mph produce spotting distance of over 1⁄2 mile and that under the influence of stronger 

gusts, such as those experienced from passing thunderstorms, spotting distances in excess of 1.5 

miles are possible from groups of subalpine fir and lodgepole pine. Therefore the 1⁄2 mile may 

not be sufficient for community protection goals as spotting could easily breach the treatments. 

There may be critical locations in fire pathways that cannot be treated outside the CPZ. 

Suppression opportunities would be impacted by the restrictions on tree-cutting and road 

construction. During their active life, temporary roads constructed for hazardous fuels 

treatments would provide short term increased firefighting efficiencies in the event a fire starts 

in the area near the road. In the event of a wildfire, there could be the need for extensive and 

costly restoration and rehabilitation.

Intermediate levels of treatments for maintenance and restoration of ecosystem composition 

and structure may lead to more dead trees and higher severity wildfires than alternative 3. 

Dead trees would release carbon and wildfire would release carbon as well as potentially 

unhealthy levels of smoke and particulates into the atmosphere. With reduced opportunity to 

remove material from hazardous fuel and other treatments using roads, the opportunity to 

substitute this material for fossil fuels would be foregone. 

Alternative 3 – Forest Plans (No Action)

This alternative is the least restrictive of the four alternatives in treating hazardous fuels. Under 

 

26 A maximum probable gust of 20 mph is associated with a 10 minute average 20 foot wind speed of 6 mph.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

114—Chapter 3. Affected Environment and Environmental Consequences

this alternative, tree-cutting, sale or removal and road construction follows the direction in the 

forest plans. This alternative provides the most management flexibility of the four alternatives. 

Under this alternative, the options available for fuel reduction include prescribed fire, 

mechanical treatment, and road construction as needed to facilitate treatment.

Based on projections, approximately 13,100 acres per year of mechanical fuels treatments (treecutting, sale or removal) is projected to occur in the analysis area. An additional 3,600 acres per 

year of tree-cutting for purposes other than hazardous fuels reduction (not including incidental, 

administrative or personal use tree-cutting) that may or may not modify fire behavior to meet 

desired conditions is projected. Projections show 3.6% of the analysis area would be treated per 

decade under alternative 3. Projections are shown in Table 3-2.

The increase in treatments being implemented reflects the ability to treat priority acres that are 

not easily treated under the other three alternatives. The increased flexibility for road 

construction would allow for cost effective and efficient implementation of hazardous fuels 

reduction projects as well as an efficient means of removing the resulting biomass. In addition, 

greater access would be available to do maintenance treatments in the long term and at-risk 

communities would receive substantial benefit from hazardous fuels reduction treatments. 

This alternative would likely have increased positive benefits to wildland fire management 

including a reduction in the cost of suppression. The ability to treat areas without limitation by

the distance from the at-risk communities or purpose (i.e. watershed protection rather than 

municipal water supplies only) may result in reduced fire severity and less adverse fire effects. 

There may be more areas that firefighters can utilize in suppression efforts with a resulting 

increase in firefighter safety. The increase in projected roads would facilitate efficient initial 

attack response and increase firefighting efficiencies in both the short and long term during the 

active lifespan of the road. 

This alternative allows the most treatment for maintenance and restoration of ecosystem

composition and structure, so that there are the fewest dead trees and wildfires compared to 

other alternatives. Fewer dead trees would release less carbon, and fewer wildfires would 

release less carbon as well as lower levels of potentially unhealthy levels of smoke and 

particulates into the atmosphere. With the greatest opportunity to remove biomass from 

hazardous fuel and other treatments using roads, this alternative provides the best opportunity 

to substitute biomass for fossil fuels, thereby providing a low carbon energy substitute. 

Alternative 4 - Colorado Roadless Rule with Public Proposed Upper Tier

This alternative is less restrictive than alternatives 1, equal to alternative 2, and more restrictive 

than alternative 3 in treating hazardous fuels in the standard tier. It is more restrictive than 

alternatives 1 and 3 and equal to alternative 2 in the upper tier. This alternative has the same 

prohibitions and exceptions as alternative 2. The difference is there are more upper tier acres 

where tree-cutting, sale or removal for hazardous fuels treatment is prohibited. As with 

alternative 2, fuel reduction activities allowed in this alternative would generally consist of 

prescribed burning, mechanical treatments, and hand treatments.

Under this alternative approximately 1,600 acres per year of mechanical fuels treatments (treecutting, sale or removal) are projected in the CRAs, with the majority within the first 1⁄2 mile of 

the CPZ. Approximately 48% of the CRA acres within 0.5 miles of the FOTE 2000 at-risk 

communities (the 0.5 CPZ) are in upper tier where no tree-cutting can be done for hazardous 

fuels treatments. Approximately 52% of the CRA acres within 1.5 miles of the FOTE 2000 at-risk 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—115

communities (the maximum 1.5 CPZ) are in upper tier where no tree-cutting can be done for 

hazardous fuels treatments. The analysis area outside of the CRAs, managed according to 

direction in the forest plans, has a projected 600 acres per year of mechanical fuels treatments. 

An additional 800 acres per year of tree-cutting for purposes other than hazardous fuels 

reduction (not including incidental, administrative or personal use tree-cutting) that may or 

may not modify fire behavior to meet desired conditions is projected. Two hundred of the 800 

acres are within the CRAs and 600 acres are in the remainder of the analysis area. Projections 

show that 0.4% of the CRA acres would be treated per decade with an additional 2.6% of the 

―substantially altered acres‖ treated per decade according to forest plan direction. Projections 

are shown in Table 3-2.

The decrease in projected treatments being implemented in roadless areas from alternative 2 

reflects the number of upper tier acres within the CRAs where tree-cutting for fuels treatment is 

prohibited. 

On the acres within the CRAs that are not upper tier, the treatment options and effects are 

identical to those listed in alternative 2. Because of the large number of upper tier acres within 

the CPZ in this alternative, there would be a higher risk of a high-severity wildfire than in 

alternative 2 or 3 but slightly less than in alternative 1. Suppression opportunities would be 

impacted by the restrictions on tree-cutting and road construction. During their active life,

temporary roads constructed for hazardous fuels treatments would provide short term 

increased firefighting efficiencies in the event a fire starts near the road. In the event of a 

wildfire, there could be the need for extensive and costly restoration and rehabilitation. 

Compared to alternatives 2 and 3, fewer treatments for maintenance and restoration of 

ecosystem composition and structure may lead to more dead trees and higher severity 

wildfires, which would release carbon as well as potentially unhealthy levels of smoke and 

particulates into the atmosphere. With lessened ability to remove material from hazardous fuel

and other treatments using roads, the opportunity to substitute biomass for fossil fuels would 

be reduced.

Cumulative Effects 

Past fire exclusion, lack of treatment and insect outbreaks have contributed to an accumulation 

of fuels and the current amount of area that is in Condition Classes 2 and 3. Laws, regulations, 

and policies described in the Affected Environment section, such as the NFP and HFRA, have 

placed an emphasis on reducing hazardous fuels and unwanted and uncharacteristic wildland 

fires.

Residential development in the WUI has raised concern among natural resource managers and 

is recognized as a primary factor influencing management activities. This interface poses a 

number of challenges including invasive species, fragmentation and loss of wildlife habitat, and 

air pollution. Colorado was among the top nine western states with the greatest proportion of 

WUI expansion from 1970-2000, and is among the top six states from the intermountain west 

with the greatest anticipation of WUI expansion from 2000 to 2030 (Theobald and Romme 2007).

As development increases in fire-prone areas, the cost of protecting homes from wildfires is 

expected to continue to grow. Even with fuels treatments, the rising cost of wildland 

firefighting would not be controlled without additional controls at the state, county and local 

levels to control the pace, scale, and pattern of development in the WUI. Reliance on the federal 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

116—Chapter 3. Affected Environment and Environmental Consequences

government to provide wildfire suppression services places an enormous financial burden on 

the Forest Service. Federal agencies do not have the power to regulate development. Zoning 

and planning authority rest entirely with State and local governments. (USDA and USDI 2006)

Over the next 15 years, the number of approved CWPPs in the State of Colorado is expected to 

increase with an end goal of having them in place for all identified at-risk communities. CWPPs 

coupled with other policies and implementation strategies would identify priority acres that are 

in need of some type of treatment to reduce the threat to communities, municipal water supply 

systems, and other critical resources. Fuel treatments are far more effective if they are 

strategically located and collaboration occurs between landowners and other cooperators. It is 

likely that other ownerships adjoining roadless areas would engage in implementing hazardous 

fuels reduction projects concurrent with those occurring on NFS lands.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—117

MINERAL RESOURCE AND ENERGY DEVELOPMENT – SALEABLE,

LOCATABLE, AND LEASABLE

Introduction

A variety of mineral and energy resources occur on NFS lands in Colorado‘s roadless areas. 

Mineral resources may be classified into three categories: saleable minerals, locatable minerals, 

and leasable minerals. Leasable minerals (oil, gas, and coal, etc.) are related to energy 

development. 

Saleable Minerals 

Saleable minerals are common variety mineral materials such as sand, gravel, stone, cinders, 

and clay. Generally, they are common, of low value, and used primarily for construction, 

building, or landscaping materials. Their value depends on market factors, quality of the 

material, and transportation costs. Disposal of these resources is at the discretion of the Forest 

Service and is subject to the provisions of 36 CFR 228, subpart C. Under these regulations, the 

Forest Service may either: (1) sell material for commercial use; (2) allow free use of material to 

the public and to non-profit organizations for non-commercial purposes or for public projects 

by federal, state, or local agencies; or (3) use material itself for Forest Service projects on NFS

lands. The regulations also require that disturbance associated with mineral material sites is 

approved by the Forest Service in an operating plan that includes provisions to protect the 

environment and reclaim the surface in a timely manner.

Locatable Minerals

Locatable minerals are generally thought of as metals such as gold, silver, lead, zinc, 

molybdenum, and uranium but also include non-metallic minerals such as fluorspar, feldspar, 

and gem stones, and uncommon varieties of sand, stone, gravel, pumice, pumicite, and cinders 

such as high calcium limestone used for cement. Locatable minerals are appropriated through 

the location of mining claims under the General Mining Law of 1872, as amended. This law 

provides United States citizens a possessory right to these minerals, use of the surface for 

purposes reasonably incident to mining, and a right to reasonable access to these minerals 

across Federal land. 

Developing roads for locatable mineral exploration or development and the right to timber

from mining claims for mining purposes on those claims is part of the reasonable right of access

provided under the 1872 Mining Law, as amended. Therefore, as these rights are granted by 

statute, they are not subject to the prohibitions contained in any of the alternatives. Thus, none 

of the alternatives differ in projections for developments associated with locatable minerals.

Leasable Minerals

Leasable minerals are those minerals that can be explored for and developed under one of 

several federal mineral leasing acts. Leasable minerals in Colorado include energy mineral

resources such as oil, gas, coal, and geothermal. Moreover, for lands acquired or administered 

under the Weeks Act (PL 61-435) and the Bankhead-Jones Act (PL 75-210), the 1872 Mining Law 

does not apply and deposits of otherwise locatable minerals like gold and garnet are leasable.

The government‘s decision regarding whether to lease leasable mineral resources is

discretionary, meaning that leasing may or may not be allowed. However, once issued, a lease 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

118—Chapter 3. Affected Environment and Environmental Consequences

then becomes an irretrievable commitment of resource; a lease cannot be cancelled by the 

government, except by due process when the lessee does not meet the terms and conditions of 

the lease. The Bureau of Land Management (BLM) has the exclusive authority to dispose of 

leasable mineral resources on NFS lands. However, BLM must have the consent of the Forest 

Service before it can lease oil, gas, or geothermal resources. In the case of phosphate, BLM must 

seek Forest Service recommendations for measures to protect surface resources, but may lease 

without Forest Service consent. A federal lease conveys to the holder the right to explore and 

develop the leased commodity subject to lease terms, stipulations, and applicable regulations. 

Although it varies by commodity, surface use associated with the exploration and development 

of leasable minerals requires access and haul roads, open pits, facilities, power lines, pipelines, 

and communication sites. Efficient exploration and development of leasable minerals is 

generally not possible without the ability to build new roads or reconstruct existing roads 

where needed. In the case of oil, gas, and geothermal resources, industry has the capability to 

avoid disturbing sensitive surface resources by using directional drilling techniques. 

Affected Environment

Saleable Minerals

Sources for mineral materials are abundant and widespread throughout Colorado. Suitable 

material can be derived from glacial moraines, alluvium, talus, river benches, and other natural 

sources of loose material; or it can be quarried from rock outcrop. Because of the high cost of 

transportation, which often represents the majority of the cost for the material delivered to the 

project site, the largest sources with the most production are close to highways and major 

markets. Private lands more often meet these conditions then do NFS lands or at least sources 

on private lands are usually available so that production from NFS lands is not necessary.

The largest amount of mineral material use is driven by two distinctly different markets. One 

market is for building, construction, and landscaping materials needed for developing 

communities. To meet these needs, typically one or more mineral material sites with large 

reserves are developed, usually around the periphery of the community. Sites next to already 

existing highways and railroads are preferable but construction of transportation infrastructure 

solely for the purpose of developing good mineral material sites is not uncommon. The other 

market for mineral materials is for the construction and maintenance of roads and highways. In 

this situation, mineral material sites are developed along and in close proximity to the road 

corridor. Sites are generally smaller in size, more numerous, and dispersed along the course of 

the road. In this case, mineral materials are developed as the result of the need for the road 

rather than a road being constructed for the need of the mineral material deposit.

State-wide production of mineral materials in Colorado was reported at 83.88 million tons for

the year 2006 (Cappa et al. 2007). In comparison, mineral material disposal from Colorado‘s 

national forests for 2006 totaled 525,800 tons for that same year (Forest Service annual 

production report for FY 2006). Thus the total average annual production of mineral materials 

from NFS lands represents less than one percent of the total mineral material production for all 

of Colorado. Although a specific breakdown of amounts of mineral materials generated from 

IRA‘s is not available, mineral material contributions from IRA‘s to the total NFS production is 

small and most likely used for public road projects (free use) or local Forest Service use where 

roads already exist or are being constructed for some purpose other than mineral material 

development. This lack of commercial interest is likely due to: IRA‘s being generally remote 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—119

from where mineral materials are needed, terrain too rugged for developing such a low value 

commodity, and widespread availability of other mineral material sources outside of IRA‘s.

Additionally, the Forest Service encourages commercial operations on NFS land, such as oil and 

gas operations, to obtain their mineral material from private sources whenever possible.

Locatable Minerals

Base and precious metals usually occur in varying proportions in Colorado deposits and 

include mainly gold, silver, lead, zinc, and molybdenum. Most major Colorado mining districts 

for these locatable minerals lie in a zone called the Colorado mineral belt that extends from 

Boulder County southwest almost to the corner of the State (USDI Bureau of Mines, 1984).

There are a few scattered, well known districts and mineral deposits occurring to the southeast 

of the Colorado mineral belt including Creede, Cripple Creek, and Summitville. Another 

important mineral belt is the Uravan mineral belt containing deposits of uranium and 

vanadium. It is an eastward convex mineral belt occurring near the lower western border of 

Colorado.

Valuable deposits of locatable mineral resources potentially exist in Colorado‘s inventoried 

roadless areas. Mineral related activities are occurring and would continue to occur in 

inventoried roadless areas where valuable deposits exist. While it is not possible to predict 

where and when development would occur, the existence of active mining claims within a 

given roadless area is an indicator of both potential for a valuable mineral deposit and for 

future mineral related activity.

The analysis for this EIS uses point count data of mining claims. These data have an accuracy 

only to the nearest surveyed or protracted section. Type, size, and location of the claims within 

any given section are unknown from these data. This means that for roadless areas with 

boundaries that cut through sections rather than follow section lines, it is not possible to know 

which side of the roadless area boundary the claims lie. Therefore, any information on the 

number of claims affected would be an approximation. A more accurate measure from these 

data would be the acres within those sections that contain mining claims that lie within roadless 

areas. These acres shall be referred to as the ―acres of interest‖.

Based on a point count of year 2005 mining claim data extracted by the USGS (Causey 2007) 

from BLM‘s LR2000 database, approximately 75 percent of the roadless areas (IRA and CRA 

combined) in Colorado do not contain active mining claims. Of the remaining 25 percent, there 

are an estimated 2,000 active mining claims to potentially valuable deposits of locatable 

minerals. This is 21 percent of the total 9,445 active mining claims in Colorado in 2005. Acres of 

interest where these mining claims occur represent only 2.2 percent of the total combined IRA 

and CRA area (102,000 acres out of 4,653,100 acres). Of those 2,000 active mining claims, about 

30 percent occur within the Whetstone IRA (Whetstone CRA) on the GMUG, 17 percent in the 

Hoosier Ridge IRA (Hoosier Ridge CRA) on the White River, and 11 percent in the Hermosa 

IRA (Hermosa CRA) on the San Juan. The remaining 42 percent of active mining claims in 

roadless areas are less concentrated. The number of claims within roadless areas is subject to 

change as new claims are staked and others are allowed to lapse. The existence of these claims 

in a roadless area indicates where there is some potential for roads and other development to 

occur.

Locatable mineral activity generally fluctuates with the rise and fall of metal prices. The recent 

rise in metal prices has resulted in increased interest in Colorado‘s mineral resources. However, 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

120—Chapter 3. Affected Environment and Environmental Consequences

most renewed development and production occurs in areas of past mineral production. These 

areas typically already contain roads and private patented land. Thus, a significant increase in 

mineral development and production in inventoried roadless areas is not in the foreseeable 

future.

One exception is the surface use of mill site claims in the Whetstone IRA (Whetstone CRA) in 

support of the development of a nearby molybdenum deposit on patented land, although a 

proposal has not yet been submitted. If the price of metals continues to rise, there could be a 

corresponding increase in prospecting and exploration activity in roadless areas; however, an 

increase in prospecting and exploration does not result in a similar increase in development and 

production as most exploration efforts rarely result in the discovery of a mineable deposit.

Furthermore, road construction and tree-cutting are not as necessary for locatable mineral

prospecting and exploration as they are for development and production.

Leasable Minerals – Coal

This sub-section presents information and effects on accessibility to coal resources on National 

Forest System (NFS) lands within the analysis area. This analysis presents estimated projections 

of activities that might occur in the analysis area. The analysis presents only effects on 

accessibility to coal resources for national forest units on which coal resource development is 

likely to occur in the analysis timeframe of 15 years. The only unit for which coal resource 

development is anticipated is the GMUG National Forests.

Only a small number of IRAs and corresponding CRAs in Colorado have potential for existence 

of coal resources. A very small number have existing coal leases, and those all occur on the 

GMUG National Forests. Depending on the alternative, potential for future development could 

be limited based on the assumption that once a Colorado Roadless Rule is in effect, road 

construction and reconstruction necessary to develop coal resources might only be allowed on 

existing leases, or in a specific area on the GMUG National Forests.

General Information about the Federal Coal Program

The Forest Service participates with the USDI- BLM, the USDI- Office of Surface Mining 

Reclamation and Enforcement (OSM), and the State of Colorado Division of Reclamation 

Mining and Safety (DRMS) in managing coal resource development on NFS lands in the State. 

The Forest Service acts under the authorities defined in the Mineral Leasing Act of 1920, as 

amended by the Federal Coal Leasing Amendments Act of 1976 for coal exploration licenses 

and coal leases. The Surface Mining Control and Reclamation Act of 1977 gives the Forest 

Service, as the surface managing agency (also referred to as the federal land management 

agency), a review and/or concurrence role in the OSM and DRMS coal mine permitting process.

Coal exploration licenses are issued by the BLM on specific lands nominated by industry 

through an application process. Where NFS lands are involved, the Forest Service provides 

BLM with conditions for use and protection of forest lands. Coal exploration licenses are issued 

with a 2-year term. Coal exploration drill sites and associated access roads are temporary, and 

are typically on the landscape for two years or less. 

The Forest Service and BLM consider lands for coal leasing as they are nominated by industry 

through the application process. The Forest Service conducts a site-specific NEPA leasing 

analysis to determine whether to consent to BLM leasing the lands, and to identify stipulations 

for protection of non-coal resources. Similar to oil and gas leases, special stipulations on the 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—121

federal coal lease are modifications (additions) to the standard terms of a lease that establish 

binding conditions on surface use. For underground mining, special coal lease stipulations 

generally relate to protecting surface resources from effects of underground mine subsidence, 

and often include timing and surface use restrictions for certain resource conditions. Once the 

Forest Service has consented to leasing and identified lease stipulations, the BLM then offers, 

sells, and issues coal leases on NFS lands. Coal leases are issued for 20 year initial terms, and are 

in effect until formal relinquishment (initiated by the lease holder) occurs. 

Mining operations on federal coal leases can only occur when a lease is part of an approved coal 

mining permit. Coal mine permitting in Colorado is managed by the DRMS with oversight from 

the OSM, which has the final authority for approving permit actions. Where NFS lands are 

involved at the time a federal lease is brought forward for inclusion in a mining permit, or 

when surface uses (such as roads, methane drainage wells, surface facilities) are proposed, the 

Forest Service has the responsibility to 1) ensure that the permit action is consistent with the 

Forest Plan, 2) designate the post-mining land use, and 3) include adequate protection measures 

for surface resources on NFS lands. The Forest Service responds to the State and/or OSM with 

specific measures (conditions) to protect surface resources within the agency‘s jurisdiction, or 

concurrence for the permit action as applicable. Depending on the scope of a permit action, the 

OSM may conduct a NEPA analysis.

Coal Resource Occurrence

Five national forest units in Colorado acknowledge that coal resources may exist within their 

boundaries; the Pike-San Isabel NFs, the Routt NF, the San Juan NF, the White River NF and the 

GMUG NF (forest plans, various dates). Areas where coal resources overlap NFS lands were 

assessed in forest plans using data from the U.S. Geological Survey (USGS), Colorado 

Geological Survey and the DRMS.

Table 3-15 shows an assessment of where coalfields/regions with potentially minable coal

resources might occur on NFS lands in the State. Several IRAs and CRAs on NFS lands in the 

State overlap with some of these coalfields/regions. The USGS (2001) assessed the coal 

resources in Colorado as being potentially minable, or applicable for other uses. For the 

purposes of this analysis, only areas identified to have potentially minable coal resources were 

examined.

The Forest Service does not currently have sufficient site-specific information to estimate the 

amount of coal resources that may occur in IRAs or CRAs on the Pike-San Isabel, Routt or 

White River National Forests. According to information provided by the San Juan Forest for 

preparation of a forest plan revision, an estimated 1.5 billion tons of coal reserves may exist in 

the Durango Known Recoverable Coal Resource Area (this overlaps with the Pagosa Springs 

coalfield) in IRAs, CRAs, and non-roadless lands on the Forest. On the GMUG NF, there is 

currently insufficient site-specific information to estimate the amount of coal resources in the 

Carbondale, Crested Butte and Tongue Mesa coalfields. The GMUG NF estimates that about 1.6 

billion tons of in-place coal reserves occur in IRAs, CRAs and non-roadless areas in the 

Somerset and Grand Mesa coalfields. About 1.2 billion tons of these reserves are estimated to 

occur in IRAs and CRAs.

Coal Leasing and Exploration Licensing Status:

Table 3-15 also shows the occurrence of coal exploration licenses and/or leases on NFS lands in 

the State. This information was provided by the BLM, or obtained from the LR2000 database. As 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

122—Chapter 3. Affected Environment and Environmental Consequences

of November 2009, there were about 14,000 acres of land under lease for coal development on 

IRAs, CRAs and non-roadless lands in the Somerset Coalfield on the GMUG NF. 

About 7,100 of the 14,000 currently leased acres are either in IRA and/or CRAs. About 3,100 of 

the currently leased acres are in IRAs only; about 2,800 acres of the currently leased acres are 

where IRA and CRA are in common and 1,200 acres in current leases fall into CRA only. There 

were no approved coal exploration licenses in roadless areas in November 2009. There were no 

leases or exploration licenses in place on the Pike-San Isabel, Routt, San Juan, or White River

National Forests. 

Table 3-15. Potentially Minable Coal Resources by National Forest, IRA and CRA in Colorado, with 

coalfield (where applicable).

National 

Forest Coalfield/Region CRA(s) IRA name (if different)

Existing 

Leases or 

Exploration 

Licenses

Foreseeable 

Coal Activity

GMUG Carbondale Huntsman Ridge, 

Tomahawk, MunseyErikson

Drift Creek, 

Raggeds

No None

Crested Butte Castle and Whetstone Beaver, 

Castle, 

Whetstone 

Mountain

No None

Tongue Mesa Cimarron Ridge Cimarron No None

Grand Mesa Currant Creek and Kannah 

Creek

Priest 

Mountain

No Yes

Somerset Flatirons, Sunset, Pilot 

Knob, Beckwiths, 

Flattops/Elk Park

West Elk, 

Springhouse 

Creek, 

Priest 

Mountain

Yes in 

Flatirons 

Sunset and 

Pilot Knob

Yes in 

Flatirons, 

Sunset and 

Pilot Knob

Pike-San 

Isabel

Trinidad Spanish Peaks No None

Routt Green River 

Region

Pagoda Peak, Morapos A, 

Morapos B, Chatfield,

Nipple Peak South

No None

San Juan Pagosa Springs HD Mountains No None

White River Carbondale Assignation Ridge No None

Gallo Hill No None

McClure Pass No None

Notes: Information on coalfields or coal region was taken from Carroll (2005); Information on locations of potentially mineable 

coal resources was taken from USDI Geological Survey (2001), and individual forest plans (various dates). Information on 

existing coal leases and exploration licenses were provided by BLM. 

Current Coal Development

Coal from the federal leases on the GMUG NF is extracted exclusively with underground 

mining methods. Three underground mines (West Elk, Bowie #2, and Elk Creek) produce coal

from private lands and leases on federal lands. Coal is mined underground and transported to 

the surface and processing facilities at the mine sites by conveyor. Collectively, the three 

existing mines currently produce about 15 million tons per year, which accounts for about 40 

percent of the coal production in Colorado (Colorado Division of Reclamation, Mining and 

Safety 2009).

The coal resources currently being mined in Colorado meet the definition of compliant and 

super-compliant coal reserves according to the Clean Air Act. The coal has high energy value 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—123

(Btu), low sulphur; ash and mercury content, and is thus desirable for use in electric generation 

plants. The bulk of the coal is shipped to the Eastern US (Carroll 2005).

Coal will continue to be mined using underground mining methods. Changes in technology 

including improvement in roof support may contribute to more efficient mining during the 

analysis timeframe; however these are not expected to impart dramatic changes (USDI BLM

2005). In 2007, the Energy Information Administration (EIA) called for a 5 percent per year 

increase in coal production at Western mines as a result of increasing demand (USDOE 2007b).

The EIA‘s 2009 report calls for a slower rate of increase (USDOE 2009). Either way, it is expected 

that demand for Western coal, such as that produced from these mines will continue or increase 

slightly over the analysis timeframe.

Past and Current Road Construction

Coal-related road construction currently only occurs on the GMUG NF, because it is the only 

unit on which coal activity is occurring. No coal activity is presently occurring on the Pike-San 

Isabel, Routt, San Juan or White River National Forests. 

Approximately 75 miles of roads have been constructed or reconstructed since the 1960s in the 

West Elk IRA on the GMUG NF for the purposes of coal exploration, methane drainage and 

monitoring activities. An additional 1 mile of road has been approved, under the interim 

directives, for coal exploration in the Springhouse Creek IRA. Since 2001, 20 of the 75 miles have 

been constructed to drill methane drainage wells. Methane drainage well reclamation and 

access road decommissioning occurs continually following practices of contemporaneous 

reclamation, i.e. a facility and access roads are reclaimed or decommissioned as soon as they are 

no longer needed. Approximately 65 of the 75 miles have been decommissioned and reclaimed. 

Some coal-related road construction also occurred in the past on the White River National 

Forest, however specific data are not available. Those road miles have also been 

decommissioned and reclaimed.

Existing coal-related road construction that has occurred on coal leases or exploration licenses 

in roadless areas since 2001 has been consistent with applicable forest plan direction, rules and 

regulations, including the 2001 Roadless Rule or interim directives, as applicable to the 

timeframe when the road construction was approved. 

Decommissioning by obliteration has been effective in restoring disturbed lands to the postmining land use (livestock grazing and wildlife habitat) according to Forest Service conditions 

brought forward to the DRMS for the mine permit. Based on experience in the West Elk IRA, 

the decommissioning and subsequent reclamation is well established two to three years after 

reclamation (example photos in Colorado Roadless Rule EIS project record). 

Projections for Coal Leases, Exploration Licenses and Development

No coal-related activity is presently occurring or foreseen on the Pike-San Isabel, Routt, San 

Juan, or White River National Forests in the 15-year analysis timeframe. However, coal 

exploration and development is expected to continue on the GMUG NF in the Somerset 

coalfield, and some activity in the Grand Mesa coalfield is expected in the analysis timeframe. It 

is expected that 6 or 7 coal exploration licenses would be brought forward for lands with 

potentially minable coal reserves in the next 15 years. Similarly, it is expected that a leasing 

application would occur about every 3 to 4 years on these lands in the next 15 years, amounting 

to about 4 leasing actions. Estimations are based on the frequency of exploration license and 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

124—Chapter 3. Affected Environment and Environmental Consequences

lease applications submitted to BLM in the last decade. No activity is foreseen on the remaining 

coalfields on the GMUG NF during the analysis timeframe.

Given the current leasing situation and production rate, the 3 existing mines have combined 

reserves that will support about 22 years of mining, with a range per mine between about 4 and 

12 years (USDI BLM 2009).

Projections for Road Construction and Reconstruction

This analysis assumes that roads would be necessary pursuant to issuance of coal exploration 

licenses to exercise the rights granted by a coal lease (whether existing or future). Road 

construction or reconstruction would be needed for exploration licenses so that coal reserve 

data required prior to leasing could be collected. Further, it is assumed that without roads, safe 

and economic development of coal resources under lease could not occur. Road construction 

and reconstruction may be precluded on portions of coal leases or exploration licenses in 

roadless areas where lease stipulations or license conditions limit surface use for the protection 

of other resources. The projections are only pertinent to the GMUG NF, as it is the only unit 

where coal activity is occurring, and for which coal activity is projected. No activity is projected 

for the Pike-San Isabel, Routt, San Juan or White River National Forests.

Typical coal-related surface uses include exploration drilling and associated road construction, 

methane drainage (vent) well drilling with associated access roads, on-going resource 

monitoring facilities, mine infrastructure facilities and life-of-mine roads. Certain coal-related 

surface facilities and associated roads may exist on the landscape for many years (20- 30) in the 

case of maintenance and monitoring of ventilation shafts or other facilities; however, there are 

no projected new roads for the purposes of surface facilities. Other roads would be of shorter 

term (less than two, or three to five years) in the case of exploration holes or methane drainage 

(vent) wells, and other short term uses.

Road construction or reconstruction to support exploration drilling occurs in conjunction with 

both coal leases and coal exploration licenses. Exploration roads are temporary, and typically on 

the landscape for less than two years. Road construction for exploration was projected using a 

rule of thumb that about four exploration holes per 640-acre section would be needed in 

unexplored areas. For analysis purposes, it was assumed that about 1.5 miles of road would be 

needed per section for exploration.

Recent experience with existing coal leases (all of which are on the GMUG NF) suggests that 

road construction and/or reconstruction will be needed to support construction of methane 

drainage wells, which have been necessary for removing methane (an explosive gas) from the 

mines. These wells are often part of a mine operator‘s Mining Safety and Health Administration 

(MSHA) – approved ventilation plan, and are needed to meet MSHA requirements for safe 

methane levels in underground mines to ensure worker safety. In general, between 10 and 20 

methane drainage well locations per 640-acre section have been constructed at the existing 

mines. For the purpose of this analysis, it was assumed that about three miles of road per 

section would be needed for methane drainage purposes.

Using these assumptions, road construction/reconstruction is projected as shown in Table 3-16. 

It is important to note these projections are estimates, and were made without benefit of mine 

designs or plans. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—125

Table 3-16. Projected Road Construction/Reconstruction in Coal Analysis Area by Alternative, 15-

years. 

Alternative 1 Alternative 2 & 4 Alternative 3 

Road construction and 

reconstruction would be 

allowed in IRAs on coal

leases in effect prior to 

effective date of rule; and in 

CRAs that are not within 

IRAs according to forest plan

management direction

Road construction and 

reconstruction could occur 

in CRAs within the North 

Fork Coal Mining Area; and 

in the IRAs that are not 

within the CRAs according to 

forest plan management 

direction

Road construction and 

reconstruction could occur 

in IRA and CRA according to 

forest plan management 

direction

IRA only 2 miles temporary roads 2 miles temporary roads 2 miles temporary roads

IRA/CRA in 

common

5 miles temporary roads 44 miles temporary road

38 miles forest road

24 miles temporary road

CRA only 9 miles temporary or forest 

road 6 miles temp road 9 miles temporary or forest road 

Total by 

alternative 

for 15 year

7 within IRAs;

16 total miles

50 within CRAs;

52 total miles

64 within IRAs;

73 total miles

Total by 

alternative 

annually

1 mile 3 miles 5 miles

Note: Estimates rounded to nearest mile

Road construction activity related to coal exploration or for other surface uses typically occurs 

intensively for one to several years, and then slows. There are typically gaps of time where no 

road construction occurs. Therefore, because initial road construction normally occurs over a 

concentrated period and subsequent use can occur over a range of subsequent years (from less 

than one year to 10 or more), projections for coal are presented over a 15-year period, rather 

than in yearly averages. Nevertheless, an estimated annual average is also presented in the table 

above. Roads used for coal exploration or surface uses are typically decommissioned as soon as 

they are no longer needed according to practices of contemporaneous reclamation. Some roads 

may remain on the landscape for the duration of mining in a particular area or lease, with the 

duration dependent on mine plans and monitoring needs.

Leasable Minerals – Oil and Gas

All national forests in Colorado have some areas with at least minimal geologic potential for 

natural gas and/or oil occurrence. However, only three forests have sizable areas in major 

proven natural gas-producing geologic basins, and consequently have high potential for 

primarily natural gas occurrence and development. Most of the areas that have potential for oil 

and gas occurrence are available for leasing under existing leasing decisions and forest plans.

This sub-section describes the differences in the ways natural gas and oil resources would be 

managed in the analysis area among alternatives

Roadless areas with potential for oil and/or natural gas occurrence and relatively high levels of 

leasing have experienced slower development rates than adjacent lands largely due to 

challenging accessibility and complex permitting procedures with a corresponding high cost of 

development. Despite having high, and in some cases proven, production potential, these areas 

are costlier to develop than lower elevation areas with less rugged terrain, milder weather, a 

higher level of pre-existing access, and fewer environmental challenges. Consequently, the 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

126—Chapter 3. Affected Environment and Environmental Consequences

roadless areas with high oil and gas occurrence and development potential described in this 

report are in some of the few remaining onshore areas of the United States with substantial 

known energy resources left to be developed.

Projections of oil and gas road miles, wells, and production that could occur in IRAs and CRAs 

in the next 15 years were estimated based on existing information in particular, BLM 

Reasonable Foreseeable Development Scenarios (RFDs) and assumptions and methodologies 

described in the resource specialist report contained in the project record and hereby 

incorporated by reference.

Estimated projections of oil and gas wells, roads, and production are not predictions, as there is 

a very high level of uncertainty about whether wells might be drilled and, if so, where they 

might be drilled. Projections of wells and road miles are highly speculative estimations and 

represent only what could happen – not what will happen – under the four scenarios 

represented by the proposed action and three alternatives. Projections do not represent any 

kind of binding limit on the number of future wells, but generally represent a maximum 

development scenario.

Estimated projected oil and gas road miles, wells, associated disturbance, and production in 

IRAs and CRAs vary slightly among the four alternatives. Table 3-17 summarizes the 

differences among the four alternatives in projected oil and gas road miles, number of wells, 

total acres of disturbance, and production in the analysis area.

Table 3-17. Comparison of estimated projections of oil and gas road miles, road acres, wells, 

pads, pad acres, and production in IRAs and CRAs under the four alternatives, and in IRAs 

and CRAs combined under the four alternatives. Road mile estimates in the table include 

assumed co-located pipelines.

Projected Activities Alternative 1 Alternatives 2 and 4 Alternative 3

IRAs Other CRAs Other IRAs &CRA’s

Miles of road 

(nearest mile) 130 14 139 5 165

Number of Wells 659 27 681 5 783

Total acres of 

disturbance 1,074 201 1,134 141 1,318

Estimated ultimate 

recovery

949 BCFG

52,500 BO

97 BCFG

0 BO

1,028 BCFG 

49,000 BO

18 BCFG

3,500 BO

1,154 BCFG

126,000 BO

Note: BCFG = billion cubic feet of gas and BO = barrels of oil

Nineteen IRAs with more than 640 acres under lease are on the GMUG, White River, and San 

Juan National Forests. These 19 IRAs had about 154,200 acres leased as of September 2009.

Roads would be allowed on leases covering about 131,200 acres, and roads would be prohibited 

on leases covering about 22,600 acres.

There are 20 CRAs with more than 640 acres under lease on the GMUG, White River, and San 

Juan National Forests. These 20 CRAs had about 159,300 acres leased as of September 2009.

Roads would be allowed on leases covering about 136,700 acres, and roads would be prohibited 

on leases covering about 22,700 acres.

Leasable Minerals – Geothermal

Geothermal resources are underground reservoirs of hot water or steam created by heat from 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—127

the earth. Geothermal steam and hot water can be utilized when they occur naturally on the 

surface of the earth in the form of hot springs, geysers, mud pots, or steam vents. Geothermal 

resources also can be accessed through drilling wells. The heat energy produced from wells can 

be used for generating electricity or for ―direct uses‖, such as heating greenhouses, homes, 

commercial buildings, or aquaculture operations or for dehydrating vegetables. Geothermal is a 

―clean‖ energy source in that its utilization does not result in greenhouse gases or other 

undesirable emissions. 

Geologic indicators of geothermal resource potential – heat flow, volcanism, recent faulting, and 

continental rifting – are present in Colorado (USDOE 2007a). However, the extent of Colorado‘s 

geothermal resource potential has yet to be assessed fully, and there are no definitive data 

indicating where and to what extent geothermal resources might occur in roadless areas. High 

heat flow values in the central part of the State are assumed to overlap, at least in part, with 

roadless areas. Volcanism, recent faulting, and continental rifting in various areas around the 

State also are assumed to overlap in part with roadless areas.

Currently, there is one geothermal lease application on the GMUG National Forest. The area of 

interest is not in an IRA or CRA. There are no other leases, lease applications, operations, or 

applications for operations on NFS lands in Colorado. The BLM-Forest Service programmatic 

EIS (USDI BLM and USDA Forest Service, 2008) addressed National Forest System lands that 

have potential for geothermal resources. The programmatic EIS provides the basis for future 

geothermal leasing availability analyses and decisions on NFS lands in Colorado and other 

states.

Saleable Minerals: Environmental Consequences

Alternative 1 – 2001 Roadless Rule

The 2001 Rule does not withdraw inventoried roadless areas from the development of mineral 

material sites. However, it does prohibit road construction or reconstruction associated with 

developing new mineral material sites within inventoried roadless areas. This effectively 

precludes the sale and disposal of mineral materials from sites well within inventoried roadless 

areas for the purposes of developing nearby communities and infrastructure. Under this 

alternative, no roads are foreseen to be constructed or reconstructed for the purpose of 

developing saleable minerals in IRA‘s. However, they could be developed in the areas in the 

analysis area that are not in the IRA‘s.

It is possible that new mineral material sites or expansion of existing sites could occur within 

inventoried roadless areas to provide material for new road construction or reconstruction 

associated with any of the exceptions under the 2001 rule. Such mineral material sites would 

have to be developed along an existing road or adjacent to a road being built pursuant to one of 

the exceptions to the prohibitions. In some cases, a few hundred feet of road could be expected 

to get material from a nearby deposit to the road that is under construction or reconstruction if 

sources of mineral materials outside of the inventoried roadless areas are not feasible. 

Because there is likely to be little interest in the use of mineral materials from IRAs in Colorado, 

the effects on the production of this resource in IRA‘s under the 2001 rule provisions should be 

minimal.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

128—Chapter 3. Affected Environment and Environmental Consequences

Alternative 2 – Colorado Roadless Rule (Proposed Action)

Like the 2001 rule alternative, the Colorado Rule does not withdraw the roadless areas from the 

development of mineral material sites, but effectively precludes their sale and disposal by 

prohibiting the construction or reconstruction of roads for that purpose. Therefore, the effects 

from the Proposed Action are the same as they are for alternative 1 in this regard. No roads are 

foreseen to be constructed or reconstructed for the purpose of developing saleable minerals, and 

therefore, no new material sources off of CRAs for nearby community needs is expected. 

The differences between alternatives 2 and 4 and alternative 1 as to the effects on salable 

minerals are minor. The difference is that more actual roadless areas are added while 

substantially altered areas are removed, and areas around ski resorts are removed. This change 

would have little impact on salable minerals in that mineral materials can already be accessed in 

the substantially altered areas, and the roadless areas and ski areas were already areas where 

the likelihood of mineral material development was low.

Under this alternative, the effects on saleable mineral production would be less than they are 

under the 2001 rule alternative.

Alternative 3 – Forest Plans (No Action)

Under this alternative, like the other alternatives, inventoried roadless areas are not withdrawn 

from mineral material development. Unlike the other alternatives, this alternative does not have 

a wide-spread prohibition against new road construction or reconstruction. Permissibility of 

road construction depends upon management area allocations that range from allowing no 

additional road construction to allowing road construction with no additional restrictions 

(temporary roads are encouraged, however). This alternative maintains flexibility for future 

mineral material development needs. If the need becomes great enough to develop mineral 

materials from a particular roadless area that does not allow additional road construction, an 

amendment to the plan can still be formulated to accommodate the need. 

Even if road construction is allowed for development of a mineral material resource in some 

roadless areas, the remoteness of roadless areas and the widespread availability of mineral 

material sources outside of roadless areas create a reasonable expectation that only a minimal 

volume of mineral materials would come from the analysis area. Assuming the demand for 

mineral materials remains at current levels; low volumes of mineral materials would be 

produced from the analysis area, the principal uses being for Forest Service projects or for the 

limited instances when roads are constructed. The only exception is that there may be a greater 

need for mineral materials to support the increased amount of road construction expected for 

oil and gas lease exploration and developments under this alternative than is under the other 

alternatives.

Under this alternative, the effects on saleable mineral production would be less than they are 

under the other three alternatives.

Alternative 4 – Colorado Roadless Rule with Public Proposed Upper Tier Acres

Under this alternative, the effects on saleable mineral production would be the same as 

alternative 2.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—129

Locatable Minerals – All Alternatives: Environmental Consequences

Locatable mineral resource activities are non-discretionary. The public has a statutory right to 

come onto public domain land to prospect, explore, and develop locatable mineral resources, 

and the Forest Service cannot prohibit this activity on these NFS lands. Therefore, none of the 

proposed alternatives would affect the statutory right of reasonable access to prospect, explore, 

and develop NFS lands open to mineral entry and location.

Rules and procedures for the use of the surface of NFS lands in connection with locatable 

mineral operations are provided in regulations found at 36 CFR 228, Subpart A. Construction or 

reconstruction of roads for locatable mineral exploration or development is part of the 

reasonable right of access provided under the General Mining Laws.

Under all alternatives, an estimated average of less than 1⁄4 mile per year of road construction or 

reconstruction is projected to occur in roadless areas during the next 15 years for all locatable 

mineral related activities. 

The amount of road construction or reconstruction associated with the small volume of mineral 

materials produced from roadless areas during the next 15 years is assumed to be little to none 

in that this production would come from areas with roads already in place or would be 

associated/included with the construction of roads for some purpose other than mineral 

material production. Construction of roads to develop sources of mineral materials from 

roadless areas for local community development is unlikely due to the abundance of this 

resource outside of roadless areas. No roads are projected for the purpose of developing 

mineral material sites within any of the alternatives for the next 15 years.

Leasable Minerals – Coal: Environmental Consequences

For the purposes of this analysis, effects are based on overall  ̳accessibility‘ to coal resources, in 

which  ̳accessibility‘ is linked to the ability to construct (or reconstruct) roads for exploration or 

lease development purposes, which subsequently affects the accessibility to coal reserves. It was 

assumed that where road construction or reconstruction would be prohibited, that mining

would be severely limited to the point that mining the reserves would be uneconomic.

The development of coal for energy produces greenhouse gasses through the expenditure of 

fossil fuels during development and processing, and also through emissions from longer-term 

extraction, transportation, and processing facilities. Prohibitions on extraction of these resources 

within CRAs would likely shift production to areas outside of roadless areas, and for demand in 

the eastern U.S., to other western U.S. sources. It is unlikely that reduced mineral extraction in 

roadless areas related to any alternatives would result in a significant change to total 

atmospheric greenhouse gas concentrations, due to the substitution of other fossil energy 

sources. Methane, a gas produced in underground coal mines and removed for safety reasons, 

is a potent greenhouse gas and capturing or flaring gas produced from the existing, as well as 

future, coal leases could be an important contribution to greenhouse gas reduction. 

Table 3-18 at the end of this section includes estimates of the accessible coal resources by 

alternative for the whole analysis area. These and other effects are further discussed in the 

following sections. 

Alternative 1- 2001 Roadless Rule

For alternative 1, road construction or reconstruction in IRAs would be limited to areas under 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

130—Chapter 3. Affected Environment and Environmental Consequences

lease prior to the effective date of the Colorado Rule. Road construction and reconstruction 

would not be permitted on IRA lands in leases let after that date. Road construction and 

reconstruction could occur on newly identified roadless acres (i.e. CRAs) that are not within 

IRAs, and would be managed according to forest plan direction. As of November 2009, only the 

GMUG NF had any coal leases in place. About 5,900 acres of the 14,000 acres currently under 

lease are in IRA, and substantially altered acres of IRA. There are also about 1,200 acres of lands 

currently leased, and an additional 1,500 acres of currently unleased lands in CRA that are not 

within IRA that would be accessible under this alternative.

Only currently leased coal resources within IRAs in the Somerset Coalfield on the GMUG NF 

would be accessible. No coal resources in IRA elsewhere on the GMUG NF, or on other forests 

would be accessible under this alternative. Coal resources on lands outside of IRAs would 

remain accessible according to forest plan direction, including some leased coal resources in 

CRAs in the Somerset Coalfield, and unleased coal resources in CRAs in the Grand Mesa 

Coalfield on GMUG NF.

Effects of alternative 1 on coal leasing and development include the following estimated 

projections of activities on the GMUG NF over the 15-year analysis period:

About 16 miles of temporary or forest road construction is projected. About 7 miles of 

this road construction would be on the 5,900 acres of existing leases in IRA which such 

activity would be allowed. About nine miles of this road construction are projected on 

newly identified roadless acres (i.e. CRAs) that are either currently leased or unleased.

About six of these projected miles would be on currently leased lands, and three miles 

on unleased lands.

All road construction would be included in a separate site-specific analyses pursuant to 

NEPA and be done in a manner that minimizes effects to surface resources, prevents 

unnecessary or unreasonable surface disturbance, and complies with lease stipulations, 

forest plan direction, regulations, and laws. Roads would be decommissioned by 

obliteration when no longer needed for the purposes of the lease. Most roads would be 

in place for approximately three to five years, and would then be decommissioned.

Continued access to about 108 million tons of recoverable coal reserves in IRA that are 

currently under lease. This accessible tonnage represents about seven years of 

production based on the current mining rates for the three mines currently producing 

coal from these leases.

Access to about 2,700 acres of coal resources in newly identified roadless acres (i.e. CRA 

that are not within IRA). Of these acres, about 1,200 of them are currently under lease, 

and contain about 22 million tons of recoverable coal reserves. The remaining 1,500 acres 

are currently unleased but would be accessible for exploration, and would provide 

access to an estimated 27 million tons of coal reserves.

Decommissioning and obliteration of at least 6 miles of road constructed in the 15 year 

analysis timeframe. Other roads would likely be constructed and decommissioned 

consistent with coal lease, license, or permit terms in this same timeframe.

Effects of road prohibitions on development of coal resources under alternative 1 include the 

following: 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—131

Lost opportunities for exploration and development of federal coal resources and 

potential bypassing of economic federal coal resources in areas within IRAs not leased 

by the effective date of the Colorado Rule.

o These areas include all identified coalfields/regions on the GMUG NF (except 

the areas of leases effective prior to date of a Colorado Rule as described above), 

and the Pike-San Isabel, Routt, San Juan, and White River National Forests. The 

extent of these coal resources are unknown, therefore the quantity of coal the 

road prohibitions might affect cannot be estimated. 

o These include un-leased federal coal resources on about 31,000 acres of the 

GMUG NF in IRAs that overlap with the Somerset and Grand Mesa coalfields.

Restrictions on road construction would prohibit exploration and would in turn 

dramatically limit the ability of the coal industry to meet BLM coal data 

requirements when coal lease applications in and outside of (adjacent to) IRAs 

are submitted to the BLM.

Limits on the overall longevity of the existing mines operating on the GMUG NF, and 

bypassing of federal coal resources due to prohibitions on road construction that may be 

needed to support mining. Estimated effects on longevity of existing mining operations 

are discussed in the Economics section. 

Limits on placing facilities to manage coal mine methane. Methane capture 

opportunities would use existing coal mine roads, or new roads built on coal leases in 

place prior to the date of the Rule, or on an oil and gas lease effective prior to the date of 

the Rule if methane is captured pursuant to a gas lease. Use of existing coal roads for 

methane capture could result in the roads remaining on the landscape for a longer 

period of time.

Alternative 2 – Colorado Roadless Rule (Proposed Action)

Under alternative 2, road construction or reconstruction in CRAs could be approved pursuant 

to existing and future coal leases, and on future coal exploration licenses, in the North Fork coal 

mining area on the GMUG NF. About 4,025 acres of the CRA lands in the North Fork coal 

mining area are currently under lease. Road construction and reconstruction for the purposes of 

coal exploration or as needed pursuant to a coal lease could occur on existing leases, and on 

about 15,600 acres of currently unleased lands in CRA in the North Fork coal mining area, for a 

combined access to about 20,000 acres. Road construction and reconstruction for coal 

exploration and in conjunction with future leases would be prohibited in all other CRAs.

On lands within the CRAs that are not currently under lease, only coal in the North Fork coal 

mining area in the Somerset coalfield on the GMUG NF would be accessible. No coal resources 

within CRAs elsewhere on the GMUG NF or within CRAs on other forests would be accessible 

under this alternative. Coal resources outside CRAs, including those in substantially altered

acres would remain accessible according to forest plan direction. This would include about 

5,000 acres of unleased coal reserves in IRAs that are not in CRAs; 300 acres of coal reserves in 

IRAs not in CRAs that are within the North Fork coal mining area, and 3,100 acres of leased 

lands in IRAs that are not in CRAs.

The North Fork coal mining area includes certain lands in the Somerset coalfield where 

potentially minable coal resources overlap with CRAs. The boundaries of this area were derived 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

132—Chapter 3. Affected Environment and Environmental Consequences

by overlaying coal resource occurrence data with CRA boundaries. An assumption was that 

coal resources lying deeper than 3,500 feet below the land surface would not be economical to 

develop. For this part of the analysis, coal resource potential was evaluated using more detailed 

data from the USGS, Colorado Geological Survey and BLM that were compiled by the GMUG 

NF (USDA 2006). The boundaries of these intersected areas were brought to the closest section 

line or subdivision thereof to facilitate future use of standard legal land description.

Effects of alternative 2 on coal leasing and development, include the following projected 

activities in the North Fork coal mining area over the 15-year analysis period based on road 

construction and reconstruction allowed under this alternative.

Continued access to develop coal in existing leases, which includes about 4,000 acres of 

CRA in the North Fork coal mining area, and 3,100 acres in IRA not in CRA, with 

collective access to about 130 million tons of recoverable coal reserves.

About 50 miles of coal-related temporary road construction and reconstruction within 

CRAs. It is projected that there could be an additional 2 miles of coal-related temporary 

road construction and reconstruction on IRA acres that are not part of a CRA. The road 

construction primarily would be for coal exploration and/or methane drainage 

purposes and roads are expected to be on the landscape for 3 to 5 years. Roads would be 

constructed in a manner that minimizes effects to surface resources, prevents 

unnecessary or unreasonable surface disturbance, and complies with lease stipulations, 

forest plan direction, regulation and laws. The roads would be administrative only, 

closed to the public and open only to coal operators and their contractors, to the Forest 

Service and other Federal and State agencies with jurisdictional authority over mining, 

and emergency personnel. When no longer needed, these roads would be 

decommissioned by obliteration, and reclaimed and restored to natural conditions as 

specified in the applicable lease, license, or permit. Coal mine permit conditions would 

call for reclaiming disturbed lands to support the post-mining land use, which would be 

based on forest plan direction.

At least 6 miles of road decommissioning in the 15 year analysis timeframe. Other roads 

would likely be constructed and decommissioned consistent with coal lease, license, or 

permit terms in this same timeframe.

Access to about 15,600 acres of unleased lands with an estimated 285 million tons of 

recoverable coal resources within CRAs in the North Fork coal mining area in the 

Somerset coalfield.

Access to about 5,300 acres of unleased land with about 97 million tons of recoverable 

coal resources that are in the substantially altered acres outside the CRA.

Within CRAs, coal mine methane capture operations would be restricted to using 

existing coal mine roads. Coal mine roads used to access sites of wells used for methane 

capture may be in use longer than if methane were vented to the atmosphere. Methane 

capture is desirable compared to venting or flaring due to the fact that methane is a 

potent greenhouse gas. The use of captured methane would also substitute for other 

fossil fuels, and thereby eliminate the environmental impacts, including greenhouse 

gases, associated with the production and transport of those fuels. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—133

Any coal mine road no longer needed for methane venting or capture would be 

decommissioned by obliteration and reclaimed and restored to natural conditions as 

specified in lease, license or permit conditions. Permit conditions call for reclaiming 

disturbed lands to support the post-mining land use, which would be based on forest 

plan direction.

Coal resources in substantially altered roadless areas on any forest unit would be 

managed according to applicable forest plan direction under this alternative. Data are 

insufficient to estimate quantities. 

Effects of road prohibitions on development of coal resources under alternative 2 include the 

following: 

Lost opportunities for exploration and development of federal coal resources and 

potential bypassing of economic federal coal resources not within the North Fork coal 

mining area, and not leased as of the effective date of the rule. These areas include all 

identified coalfields/regions on the GMUG NF (except the North Fork coal mining area), 

and the Pike-San Isabel, Routt, San Juan, and White River National Forests. The extent of 

these coal resources are unknown, therefore the quantity of coal the road prohibitions 

might affect cannot be estimated.

Alternative 3 – Forest Plans (No Action)

Under alternative 3, road construction or reconstruction could be approved on existing and 

future coal leases and coal exploration licenses in IRAs as well as the entire analysis area with 

coal resource potential according to management direction in existing forest plans. Each forest 

would review specific lands prior to leasing or exploratory activity for consistency with the 

applicable forest plan. 

Effects of alternative 3 on coal leasing and development include the following projected 

activities in IRAs during the 15-year analysis period. 

In general, about 46,000 acres of land in the Pagosa Springs coalfield is available for coal

leasing if applications are received. Some of the Pagosa Springs coalfield is in roadless 

areas on the San Juan National Forest. These lands are in a variety of management area 

prescriptions, all which allow for leasing with protections for specific resources, and 

either, allow road construction, limit or restrict road construction in some areas, or 

require no surface occupancy for leases that are in roadless areas.

Ability to consider lands in IRAs in the Trinidad coalfield on the Pike-San Isabel 

National Forest for coal leasing if applications are received. These lands would be 

accessible under current forest plan direction, and road construction would be allowed. 

Ability to consider lands in IRAs in the Carbondale coalfield on the White River

National Forest if leasing applications are received. The lands in this coalfield are in a 

variety of management area designations, some of which allow road construction, and 

others which do not. There are also some management designations that restrict mineral 

development. 

Ability to consider lands in IRAs in the Green River coal region on the Routt National 

Forest if leasing applications are received. The lands in this coal region are in a variety of 

management area designations some of which allow road construction, and others 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

134—Chapter 3. Affected Environment and Environmental Consequences

which do not. There are also some management designations that restrict mineral 

development.

Various coal exploration and development activities on the GMUG NF, as follows:

o Continued access to develop coal in existing leases, which includes about 5,900 

acres of IRAs, and 1,200 acres of CRAs not within IRAs, with collective access to 

about 130 million tons of recoverable coal reserves.

o Approximately 64 miles of temporary or forest road construction and 

reconstruction on about 31,000 acres of IRAs in the Somerset and Grand Mesa 

coalfields. About 9 miles of road construction or reconstruction on about 2,700 

acres that are not in IRAs but are in the analysis area. This road construction is 

expected to be needed principally for coal exploration and/or methane drainage 

for mining pursuant to a coal lease. These lands are in a variety of management 

area prescriptions which allow road construction; however, one management 

area specifically calls for obliterating temporary roads in one season after use, 

another management area calls for minimizing mineral disturbance in riparian

areas and timely reclamation to restore productivity comparable to that before 

disturbance. Roads would be constructed and decommissioned consistent with 

forest plan standards and guidelines, and to support the post-mining land use. 

This would include constructing the minimum standard road needed to support 

project traffic; closing new roads to public motorized use; decommissioning 

roads and returning the lands to resource production within one year of 

cessation of activities; managing road use for wildlife habitat needs, and 

involving the State wildlife agency in planning road use in winter range areas.

o Access to an estimated 595 million tons of unleased recoverable coal resources in 

the analysis area, including 568 million tons in IRA, and about 27 million tons in 

the remainder of the analysis area.

o At least 6 miles of coal-related road decommissioning within the 15 year analysis 

timeframe. Other roads would likely be constructed and decommissioned 

consistent with coal lease, license, or permit terms in this same timeframe.

o Access to coal in the Carbondale, Crested Butte and Tongue Mesa coalfields. 

These lands are in a variety of management area prescriptions which allow road 

construction; however, one management area specifically calls for obliterating 

temporary roads in one season after use, and another calls for minimizing 

mineral disturbance in riparian areas and timely reclamation to restore 

productivity comparable to that before disturbance.

Alternative 4 – Colorado Roadless Rule with Public Proposed Upper Tier

Since there are no proposed upper tier acres that overlap with current or projected coal leases, 

the effects would be the same as alternative 2.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—135

Table 3-18. Summary of Effects for Coal Resources, Grand Mesa-Uncompahgre-Gunnison 

National Forest 

Resource

Alternative 1 –

2001 Roadless 

Rule

Alternatives 2

and 4 – CO 

Roadless Rule

Alternative 3 –

Forest Plan Comments

Coal analysis area: 39,600 

acres

36,900 within 

IRAs

31,200 within 

CRAs

39,600 in 

analysis area

Somerset and Grand Mesa coal

fields

Leased acres in analysis 

area: 7,100 acres 

5,900 in IRAs 4,000 in CRAs 7,100 in analysis 

area

32,500 estimated coal resources 

unleased in analysis area

Unleased acres in analysis 

area: 32,500 acres

31,000 in IRAs 27,200 in CRAs 32,500 in 

analysis area

Acres of accessible coal

resources in alternative’s 

roadless areas

5,900 (all 

currently leased)

19,625 – in North 

Fork coal mining

area (4,025 

acres currently 

leased)

36,900 (5,900 

acres are 

currently leased)

These are acres leased in IRA in 

alternative 1; leased and unleased 

acres within CRAs in the North 

Fork Coal Mining area in 

alternative 2; and leased and 

unleased acres in IRA for 

alternative 3.

Estimated accessible 

recoverable coal resources 

in roadless areas (tons)

108 million 360 million 675 million

Estimated production time 

from accessible resources 

in roadless areas

7 years 24 years 45 years Based on current production rate 

of 15 million tons per year from 3 

mines.

Acres of accessible coal

resources in analysis area 

not in the alternative’s 

roadless areas

2,700 8,405 (3,100 

acres currently 

under lease)

2,700 For alternative 1 and 3, includes 

1,200 acres of leased lands in 

CRA, and 1,500 acres unleased 

land in CRA. For alternative 2, 

includes 3,100 acres of leased and 

5,305 acres unleased coal

reserves in IRA not in CRA.

Estimated accessible

recoverable coal resources 

in analysis area not within 

the alternative’s roadless 

areas (tons)

49 million 154 million 49 million For alternative 1 and 3, includes 22 

million tons on the 1,200 acres of 

leased lands in CRA, and 27 

million tons on the 1,500 acres 

unleased land in CRA.

Estimated production time 

from accessible resources 

in analysis area not within 

the alternative’s roadless 

areas. 

3 years 10 years 3 years Based on current production rate 

of 15 million tons per year from 3 

mines.

Estimated total coal

resources accessible by 

alternative (tons)

157 million 514 million 724 million

Estimated recoverable coal

resources potentially 

rendered inaccessible in 

roadless areas due to 

rulemaking

31,000 acres

568 million tons

11,570 acres

212 million tons

None Specific data available for 

Somerset and Grand Mesa 

coalfields. Insufficient data for 

remaining coalfields.

Projected Road construction 

in alternative

16 miles total;

7 within IRAs

52 miles total;

50 within CRAs

73 miles total;

64 within IRAs
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

136—Chapter 3. Affected Environment and Environmental Consequences

Leasable Minerals – Oil and Gas: Environmental Consequences

General Effects

Road construction and reconstruction for oil and gas development would be allowed under all 

alternatives in IRAs and CRAs in conjunction with oil and gas leases that are issued before the 

effective date of the Colorado Roadless Rule with terms allowing road construction and 

reconstruction. 

Future leases would not allow road construction or reconstruction under alternatives 1, 2 and 4.

Future leases under alternative 3 would be subject to individual forest plans which are revised 

on an ongoing basis, so that alternative 3 would allow more oil and gas development than 

alternatives 1, 2 and 4, which allow roads for existing leases only.

Estimated effects of roadless area designations and prohibitions on road construction and 

reconstruction and on the development of oil and gas resources over the 15-year analysis 

timeframe under alternatives 1, 2, and 4 include the following.

Roads associated with oil and gas activity, including drilling, development, and 

production, would not be allowed in any of the roadless areas that have no existing 

leases (no leases issued prior to the effective date of the Colorado Roadless Rule), are not 

available or analyzed for leasing, or are available for leasing but with No Surface 

Occupancy, or Controlled Surface Use (specific to roads) stipulations.

There are existing oil and gas leases in IRAs and CRAs. Projected oil and gas activity in 

conjunction with existing leases in 34 of those roadless areas with high development 

potential could result in up to an estimated 144 miles of new road construction and 

reconstruction., along with up to an estimated 686 wells with 1,275 total acres of 

disturbance.

Though unlikely, there could be some non-quantified low level of activity, including 

roads, in conjunction with existing leases in roadless areas with low development 

potential.

Estimated effects of roadless area designations and prohibitions on road construction and 

reconstruction on the development of oil and gas resources under alternative 3 would vary as 

development and production would be subject to individual forest plan. Any additional 

opportunities for exploration and development of oil and gas resources in all roadless areas 

with potential for resource occurrence and not under lease prior to the effective date of the 

Colorado Roadless Rule would be foregone in alternatives 1, 2 and 4 for the 15-year analysis 

timeframe.

The development of oil and gas for energy produces greenhouse gases through the expenditure 

of fossil fuels during development and processing, and also through emissions from longerterm extraction, transportation, and processing facilities. Prohibitions on extraction of these 

resources within Colorado Roadless Areas would likely shift oil and natural gas production to 

areas outside of roadless areas with the same associated impacts to the environment in terms of 

greenhouse gases. It is unlikely that reduced oil and gas production in roadless areas related to 

any of the alternatives would result in a significant change to total atmospheric greenhouse gas 

concentrations, due to the substitution of other sources of oil and gas or other fossil fuels. The 

use of natural gas for energy produces fewer greenhouse gases than the use of coal. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—137

Alternative 1- 2001 Roadless Rule 

Under alternative 1 oil and gas development in IRAs over the 15-year analysis timeframe is 

most likely to occur in IRAs on the GMUG, San Juan, and White River National Forests in 

conjunction with existing leases and where there currently is development and production in 

and/or adjacent to IRAs.

Table 3-19 lists IRAs with existing leases and illustrates the extent to which existing leases in 

IRAs allow surface occupancy, including roads. The table distinguishes between leases with 

terms allowing surface occupancy (including road construction and reconstruction) and leases 

with terms that prohibit surface occupancy (including roads). This distinction provides a 

general idea of which IRAs may have oil and gas roads and development activity. Map 7 in the

Map Packet illustrates Existing Oil & Gas Leases, Wells & Inventoried Roadless Areas on the 

GMUG and White River National Forest; Map 8 is the same for the San Juan National Forest. 

Table 3-19. Acres leased in IRAs as of September 20091. Leased acres with terms allowing surface 

occupancy and road construction or reconstruction are distinguished from leased acres 

with terms prohibiting surface occupancy, including road construction or reconstruction.

IRAs in boldface are those considered most likely to have oil and gas development activity 

and associated roads in conjunction with leases issued as of the effective date of the 

Colorado Roadless Rule.

Forest IRA 1 Acres leased

Leased acres 

with terms 

allowing 

surface 

occupancy

Leased acres 

with terms 

prohibiting 

surface 

occupancy

GMUG Battlement Mesa 2 8,800 100 8,700

Clear Creek 22,700 22,700 0

Drift Creek 4,100 4,100 0

Hightower 1,900 1,900 0

Priest Mountain 4,000 4,000 0

Raggeds 2,100 2,100 0

Salt Creek 1,000 1,000 0

Springhouse Creek 17,600 17,600 0

Manti-La Sal Roc Creek 3 2,800 2,800 0

Pike-San Isabel 256Rare2 3 8,100 8,100 0

San Juan HD Mountains 13,500 12,000 1,500

South San Juan 3 2,200 2,200 0

White River Baldy Mountain 6,000 6,000 0

East Divide/Four Mile Park 8,900 8,900 0

East Willow 4,600 4,600 0

Housetop Mountain 2 8,300 0 8,300

Mamm Peak 11,900 7,900 4,000

Reno Mountain 9,700 9,700 0

Thompson Creek 16,000 16,000 0

Total 154,200 131,700 22,600

Acres rounded to nearest 100 acres, totals may not add due to rounding.

1

IRAs with fewer than 640 acres under lease are not listed, as they are considered to have such a small percentage of the 

roadless area leased that there would be essentially no potential for development and associated roads in the IRA. 

2 IRAs with low development potential due to No Surface Occupancy stipulations on leases.

3

IRAs with low development potential due to less favorable positions in oil and gas basins, relatively small lease areas, distance 

from proven production, and/or unsuccessful attempts at establishing production in or near the IRAs.

Nineteen IRAs with more than 640 acres under lease are primarily on the GMUG, White River, 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

138—Chapter 3. Affected Environment and Environmental Consequences

and San Juan National Forests. These 19 IRAs had about 154,200 acres leased as of September 

2009. Roads would be allowed in conjunction with leases covering about 131,700 acres, and 

roads would be prohibited in conjunction with leases covering about 22,600 acres.

For effects analysis purposes, 14 IRAs (Table 3-19, IRAs in boldface) are considered to have high 

potential for oil and gas roads and development activity over the 15-year analysis timeframe. Of 

the 19 listed IRAs with existing leases, three – Roc Creek on the Manti-La Sal National Forest, 

256 Rare2 on the Pike San Isabel National Forest, and South San Juan on the San Juan National 

Forest – are considered to have low development potential (Table 3-19). Oil and gas wells and 

roads are not projected in these IRAs. However, projections are uncertain estimates, and given 

the entrepreneurial nature of oil and gas exploration, it is possible that there could be some 

level of activity associated with existing leases in these IRAs. Two additional IRAs – Battlement 

Mesa on the GMUG National Forest and Housetop Mountain on the White River National 

Forest – have high development potential based on geologic factors, high level of leasing, and 

proximity to existing development. However, No Surface Occupancy lease stipulations would

prohibit future development in these IRAs.

The 308 IRAs that do not have existing leases are assumed to have low to moderate potential for 

oil and gas occurrence and low to no potential for development. The quantified extent of 

potential oil and gas production from these IRAs has not been estimated for this analysis.

Potential production from these IRAs is assumed to be considerably less than that projected for 

the IRAs identified as having high potential for oil and gas occurrence and development.

Any lands leased in an IRA, after the effective date of the Colorado Roadless Rule, would 

prohibit road construction or reconstruction but would otherwise be available for development 

as described in future programmatic leasing analyses or a site-specific analysis prepared 

pursuant to NEPA.

Alternative 2 – Colorado Roadless Rule (Proposed Action)

Under alternative 2 road construction and reconstruction for oil and gas development would be 

allowed in CRAs only in conjunction with oil and gas leases that are issued before the effective 

date of the Colorado Roadless Rule and whose terms allow road construction and 

reconstruction. Waivers, exceptions, or modifications to stipulations prohibiting road 

construction or reconstruction would not be granted. Future oil and gas leasing would be 

allowed per forest plans and leasing availability decisions, but road construction and 

reconstruction in conjunction with those leases would be prohibited. Oil and gas development 

in CRAs over the 15-year analysis timeframe is most likely to occur in CRAs on the GMUG, San 

Juan, and White River National Forests in conjunction with existing leases and where there 

currently is development and production in and/or adjacent to CRAs.

Table 3-20 lists CRAs with existing leases and illustrates the extent to which existing leases in 

CRAs allow surface occupancy, including roads, under alternative 2. The table distinguishes 

between leases with terms allowing surface occupancy and road construction and 

reconstruction in conjunction with a lease, and leases with terms that prohibit surface 

occupancy, including roads, in conjunction with a lease. This distinction provides a general idea 

of which CRAs may have oil and gas roads and development activity. Map 9 in the map packet 

illustrates existing oil and gas leases, wells & CRAs on the GMUG and White River National 

Forest; Map 8 does the same for the San Juan.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—139

Table 3-20. Acres leased in CRAs as of September 20091. Leased acres with terms allowing 

surface occupancy and road construction or reconstruction are distinguished from leased 

acres with terms prohibiting surface occupancy or road construction or reconstruction.

CRAs in boldface are those considered most likely to have oil and gas development 

activity and associated roads in conjunction with leases issued as of the effective date of 

the Colorado Roadless Rule.

Forest CRA 1 Acres leased

Leased acres 

with terms 

allowing 

surface 

occupancy

Leased acres 

with terms 

prohibiting 

surface 

occupancy

GMUG Battlements 2

4,000 0 4,000

Clear Fork 15,300 15,300 0

Currant Creek 800 800 0

Flat Tops/Elk Park 1,400 1,400 0

Horsefly Canyon 2,100 2,100 0

Huntsman Ridge 5,200 5,200 0

Pilot Knob 17,200 17,200 0

Sunnyside 2 4,200 0 4,200

Tomahawk 2,100 2,100 0

Turner Creek 6,900 6,900 0

Manti-La Sal Roc Creek 3

2,800 2,800 0

Pike-San Isabel Rampart East 3

10,400 10,400 0

San Juan HD Mountains 21,900 18,900 3,100

White River Baldy Mountain 6,100 6,100 0

East Divide/Four Mile 

Park 8,600 8,600 0

East Willow 4,700 4,700 0

Housetop Mountain 28,300 0 8,300

Mamm Peak 12,00 9,000 3,100

Reno Mountain 9,700 9,700 0

Thompson Creek 15,600 15,600 0

Total 159,300 136,700 22,700

Acres rounded to nearest 100 acres, totals may not add due to rounding

1 CRAs with fewer than 640 acres under lease (including the South San Juan CRA on the San Juan National Forest) are not 

listed, as they are considered to have such a small percentage of the roadless area leased that there would be essentially no

potential for development and associated roads in the CRA. 

2 CRAs have low development potential due to No Surface Occupancy stipulations on leases.

3 CRAs have low development potential due to less favorable positions in oil and gas basins, relatively small lease areas, 

distance from proven production, and/or unsuccessful attempts at establishing production in or near the IRAs.

There are 20 CRAs with more than 640 acres under lease on the GMUG, White River, and San

Juan National Forests. These 20 CRAs had about 159,300 acres leased as of September 2009.

Roads would be allowed in conjunction with leases covering about 136,700 acres, and roads 

would be prohibited in conjunction with leases covering about 22,700 acres.

For effects analysis purposes, 15 CRAs (Table 3-20, CRAs in boldface) are considered to have 

high potential for oil and gas roads and development activity in the next 15 years. Of the 20 

listed CRAs with existing leases, two (Roc Creek on the Manti-LaSal National Forest and 

Rampart East on the PSI National Forest) are considered to have low development potential. Oil 

and gas wells and roads are not projected in these CRAs. However, projections are uncertain 

estimates, and it is possible that there could be some level of activity associated with existing 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

140—Chapter 3. Affected Environment and Environmental Consequences

leases in these two CRAs. Three additional CRAs – Battlements and Sunnyside on the GMUG 

National Forest and Housetop Mountain on the White River National Forest – have high 

development potential based on geologic factors, high level of leasing, and proximity to 

development. However, No Surface Occupancy lease stipulations would prohibit future surface 

disturbance in these CRAs.

Under alternative 2, CRAs that do not have existing leases are assumed to have low to moderate 

potential for and gas occurrence and low to no potential for development. The quantified extent 

of potential oil and gas production from these CRAs has not been estimated for this analysis.

Potential production from these CRAs is assumed to be considerably less than that projected for 

the CRAs identified as having high potential for oil and gas occurrence and development.

Any lands leased in a CRA, after the effective date of the Colorado Roadless Rule, would 

prohibit road construction or reconstruction but would otherwise be available for development 

as described in future programmatic leasing analyses or a site-specific analysis prepared 

pursuant to NEPA.

Alternative 3 – Forest Plans (No Action)

Under alternative 3 (roadless area management under forest plan direction), road construction 

and reconstruction for oil and gas development would be allowed in roadless areas in 

conjunction with existing and future oil and gas leases whose terms allow road construction 

and reconstruction. Future oil and gas leases could be offered, sold, and issued under the 

direction of forest plans and oil and gas leasing availability decisions.27 Road construction and 

reconstruction would be prohibited in conjunction with existing and future leases where lease 

stipulations prohibit surface occupancy or roads. Waivers, exceptions, or modifications to 

stipulations prohibiting surface occupancy on existing leases would be considered (not 

necessarily granted) at the time operations are proposed, if such are requested.

Oil and gas development in roadless areas over the 15-year analysis timeframe is most likely to 

occur in roadless areas that have high potential for oil and gas occurrence and development on 

the GMUG, San Juan, and White River National Forests. Oil and gas development is most likely 

to occur in these areas where there currently is development and production in and/or adjacent 

to roadless areas in conjunction with existing and future leases in those areas. Oil and gas 

leasing with subsequent development could also occur in currently unleased roadless areas 

where lands are available for leasing under forest plans and leasing availability decisions.

Development could occur on future leases where lease terms allow surface occupancy and 

roads.

Table 3-21 lists roadless areas with existing leases, and illustrates the relative extent to which 

existing and future leases in roadless areas with potential for development would allow surface 

occupancy, including roads, under alternative 3. The table makes a distinction between the 

following: acres leased and unleased but available for leasing with terms allowing surface 

occupancy, including road construction and reconstruction, and acres leased and unleased but 

available for leasing with terms that prohibit surface occupancy, including roads, in conjunction 

with a lease. 

 

27 The Forest Service is required to analyze NFS lands for oil and gas leasing and make decisions designating 

specific lands available to be leased and stipulations that would apply to leasing before authorizing BLM to offer 

NFS lands for lease. (36 CFR 228.102)
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—141

Only the GMUG and White River National Forests have any substantive potential for oil and 

gas roads and development in roadless areas, both in conjunction with existing leases and in 

conjunction with leases issued after the effective date of the Colorado Roadless Rule under 

alternative 3. Potential for oil and gas roads and development in conjunction with leases issued 

after the effective date of the Colorado Roadless Rule (alternative 3) on the San Juan National 

Forest (HD Mountains roadless area) is unknown because there is no current designation of 

lands available for leasing. Lands potentially available for lease are currently under analysis, 

and a decision on what lands would be available for leasing, and what stipulations would apply 

to any lands designated as available, has not yet been made.

Map 10 in the map packet illustrates existing oil & gas leases, wells & CRAs on the GMUG and 

White River National Forest; Map 8 does the same for the San Juan. There is low potential for 

development in roadless areas outside of those areas on the GMUG, White River, and San Juan 

National Forest listed in Table 3-21.

Nineteen roadless areas with more than 640 acres are under lease on the GMUG, White River, 

and San Juan National Forests. These roadless areas have about 268,500 acres leased or available 

for leasing as of September 2009. Roads would be allowed in conjunction with existing and 

future leases covering about 173,100 acres, and roads would be prohibited in conjunction with 

existing and future leases covering about 95,400 acres.

For effects analysis purposes, 14 roadless areas (Table 3-21, roadless areas in boldface) are 

considered to have high potential for oil and gas roads and development activity associated 

with existing and future leases over the 15-year analysis timeframe. Of the 19 listed roadless 

areas with existing leases, three (Roc Creek on the Manti-La Sal National Forest, 256 Rare2 on 

the Pike-San Isabel National Forests, and South San Juan on the San Juan National Forest) are

considered to have low development potential. Oil and gas wells and roads are not projected in 

these roadless areas. However, projections are uncertain estimates, and it is possible that there 

could be some level of activity associated with existing and future leases in these three roadless 

areas. Two additional roadless areas – Battlement Mesa on the GMUG National Forest and 

Housetop Mountain on the White River National Forest – have high development potential 

based on geologic factors, high level of leasing, and proximity to development. However, No 

Surface Occupancy lease stipulations would prohibit future development in these CRAs.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

142—Chapter 3. Affected Environment and Environmental Consequences

Table 3-21. Acres leased and acres available for leasing under forest plans and oil and gas leasing 

availability decisions as of September 2009. Leased acres and acres available but not 

leased are distinguished as follows: Acres with terms allowing surface occupancy, 

including road construction or reconstruction in conjunction with a lease, and acres with 

terms prohibiting surface occupancy, including road construction or reconstruction in 

conjunction with a lease. IRAs in boldface are those considered most likely to have oil and 

gas development activity and associated roads in conjunction with existing leases and 

future leases issued under direction of forest plans and leasing availability decisions.

Forest Roadless Areas 1 Acres 

leased

Acres 

available 

(includes 

leased acres)

Leased acres 

and acres not 

leased but 

available, with 

terms allowing 

surface 

occupancy

Leased acres 

and acres not 

leased but 

available, with 

terms 

prohibiting 

surface 

occupancy

GMUG Battlement Mesa 2 8,800 36,000 500 35,500

Clear Creek 22,700 42,800 37,500 5,300

Drift Creek 4,100 9,300 8,700 600

Hightower 1,900 4,600 4,000 500

Priest Mountain 3

4,000 43,200 32,700 10,500

Raggeds 4

2,100 13,300 12,300 1,100

Salt Creek 1,000 11,000 1,400 9,700

Springhouse Creek 17,600 17,500 17,600 0

Manti-La Sal Roc Creek 52,800 0 0 0

Pike-San Isabel 256Rare2 58,100 0 0 0

San Juan 6 HD Mountains 13,500 0 0 0

South San Juan 2,200 0 0 0

White River Baldy Mountain 6,000 6,000 6,000 0

East Divide/Four Mile 

Park

8,900 8,900 8,900 0

East Willow 4,600 7,100 7,100 50

Housetop Mountain 28,300 12,700 0 12,700

Mamm Peak 11,900 25,300 8,100 17,200

Reno Mountain 9,700 12,400 12,400 100

Thompson Creek 16,000 18,400 16,100 2,300

Total 154,200 268,500 173,100 95,400

Acres rounded to nearest 100 acres, totals may not add due to rounding.

1 Roadless areas with fewer than 640 acres under lease are not included, as they are considered to have such a small percentage

of the roadless area leased that there would be essentially no potential for development and associated roads in the roadless

area. 

2 Roadless areas have low development potential due to No Surface Occupancy stipulations on leases.

3 About 51,700 acres of Priest Mountain Roadless Area is designated not available for leasing.

4 About 3,100 acres of Raggeds Roadless Area is designated not available for leasing.

5 Roadless areas have low development potential due to less favorable positions in oil and gas basins, relatively small lease 

areas, distance from proven production, and/or unsuccessful attempts at establishing production in or near the roadless areas.

6

San Juan National Forest currently is conducting analysis for oil and gas leasing availability, so for purposes of this report, no 

lands are shown as being available for leasing. Once the leasing decision is issued, there may be additional lands designated as 

available for lease in the HD Mountains and South San Juan roadless areas.

Table 3-22 shows 115 roadless areas that are available for leasing, but have no existing leases or 

less than 640 acres leased in an individual roadless area. These areas are considered to have 

some level of potential for oil and gas occurrence, but low to no development potential. No oil 

and gas development activity or road construction or reconstruction is projected in these 

roadless areas. However, because projections are uncertain estimates, it is possible that there 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—143

could be some level of oil and gas activity and roads associated with future leases. Unleased 

lands in roadless areas on the San Juan National Forest are not included in Table 3-22 because 

the forest is in the process of considering lands to make available for leasing. Once the leasing 

decision is issued, there may be additional lands in the HD Mountains and South San Juan 

roadless areas designated as available for lease.

Outside of the areas of the GMUG and White River National Forests in the Piceance Basin, very 

few roadless area lands are available for leasing with surface occupancy allowed, and only a 

small fraction of IRA lands have existing leases. All other roadless areas not listed in Tables 3-22 

and 3-23, or shown as leased or available for leasing on the oil and gas map on the Colorado 

Roadless Rule website are considered to have little to no recognized potential for oil and gas 

occurrence and no potential for development. 

Roadless areas that are available for leasing but do not have existing leases are assumed to have 

low to moderate potential for occurrence of oil and gas and low to no potential for 

development. The quantified extent of potential oil and gas production from these roadless 

areas has not been estimated for this analysis. Potential production from these roadless areas is 

assumed to be considerably less than that projected for the roadless areas identified as having 

high potential for oil and gas occurrence and development. All other roadless areas (not 

available or not analyzed for availability) are considered to have low to no potential for 

development.

Opportunities for exploration and development of oil and gas resources in roadless areas would 

be limited only by direction in forest plans and oil and gas leasing availability decisions. Forest 

plan direction and leasing availability decisions prohibit roads for oil and gas operations in a 

limited number of roadless areas in areas with potential for oil and gas resource occurrence.

Any lands lease in a roadless area, after the effective date of the Colorado Roadless Rule, could 

prohibit road construction or reconstruction, based on forest plan direction, as described in

future programmatic leasing analyses or a site-specific analysis prepared pursuant to NEPA.

Alternative 4 – Colorado Roadless Rule with Public Proposed Upper Tier

The effect under alternative 4 would be identical to alternative 2. Some existing leases occur on 

upper tier acres identified by the public. Upper tier designation would have no effect on road 

construction or reconstruction prohibitions as roads would be authorized under existing leases.

New leases in both standard and upper tier areas would prohibit road construction or 

reconstruction, but would otherwise be available for development as described in future 

programmatic leasing analyses or a site-specific analysis prepared pursuant to NEPA.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

144—Chapter 3. Affected Environment and Environmental Consequences

Table 3-22. Roadless areas with lands available for leasing in areas with low potential for 

development as of September 2009. This table also describes the extent to which available 

lands have surface occupancy allowed or prohibited. ―NSO‖ indicates No Surface 

Occupancy stipulations applied to leases. IRAs with high potential for oil and gas

development and existing leases are listed in Table 3-19.

Forest 1 Roadless area Nature of Availability

Arapaho-Roosevelt Gold Run NSO

Indian Peaks Adjacent Area Small portion available, NSO

James Peak Small portion available, NSO

Never Summer Adjacent Area NSO

Troublesome Mostly NSO

GMUG Johnson Creek Portion available, 1⁄2 NSO, 1⁄2 surface occupancy allowed

Roubideau Portion available, NSO

Tabeguache Portion available, NSO

Ute Creek Small portion available, surface occupancy allowed

West Elk Portion available, surface occupancy allowed

Rio Grande Alamosa River Portion available, NSO

Beaver Mountain 3⁄4 NSO, 3⁄4 surface occupancy allowed

Bennet Mountain/Blowout/Willow 

Creek/Lion Point/Greenie Mountain

NSO

Bristol Head Small portion available, 1⁄2 NSO, 1⁄2 surface occupancy 

Butterfly allowed NSO

Chama Basin 1/3 available, NSO

Conejos River/Lake Fork Mostly NSO

Cotton Creek NSO

Crestone NSO

Cumbres NSO

Deep Creek/Boot Mountain Most available, 1⁄2 NSO, 1⁄2 surface occupancy allowed

Dorsey Creek NSO

Four Mile Creek Very small portion available, NSO

Fox Creek Portion available, NSO

Fox Mountain NSO

Gibbs Creek NSO

Kitty Creek NSO

La Garita Wilderness Mostly NSO

Lake Fork Portion available, 1⁄2 NSO, 1⁄2 surface occupancy allowed

Lower East Bellows Mostly NSO

Middle Alder NSO

Miller Creek NSO

Pole Creek NSO

Pole Mountain/Finger Mesa Small portion available, NSO

Sawlog NSO

Snowshoe Mountain Very small portion available, NSO

Spruce Hole/Sheep Creek NSO

Sulphur Tunnel NSO

Summit Peak/Elwood Pass NSO

Tewksberry NSO

Tobacco Lakes Small portion available, NSO

Trout Mountain/Elk Mountain NSO

Ute Pass Small portion available, NSO

Wightman Fork/Upper Burro Small portion available, NSO
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—145

Forest 1 Roadless area Nature of Availability

Willow Mountain Portion available, NSO

Routt Kettle Lakes NSO

Grizzly Helena NSO

Dome Peak Small portion available, mostly NSO

Elkhorn Surface occupancy allowed

Shield Mountain NSO

Nipple Peak North Surface occupancy allowed

Nipple Peak South NSO

Sugarloaf North Surface occupancy allowed

Sugarloaf South Mostly NSO

Black Mountain Large areas of NSO

Barber Basin About 1/3 NSO

Morrison Creek Very small portion available

Bushy Creek Mostly available, small portion NSO

Chatfield About 1⁄2 NSO, 1⁄2 surface occupancy allowed

Bunker Basin NSO

Pagoda Peak NSO

White River Adam Mountain Surface occupancy allowed

Assignation Ridge Mostly NSO

Basalt Mountain A Surface occupancy allowed

Basalt Mountain B Surface occupancy allowed

Berry Creek Surface occupancy allowed

Big Ridge to South Fork A Mostly NSO

Big Ridge to South Fork B Surface occupancy allowed

Boulder Surface occupancy allowed

Buffer Mountain Surface occupancy allowed

Burnt Mountain Surface occupancy allowed

Crystal River Surface occupancy allowed

Deep Creek Portion available, part NSO, part surface use allowed

Dome Peak Surface occupancy allowed

East Vail Surface occupancy allowed

Fawn Creek/Little Lost Park Surface occupancy allowed

Freeman Creek Surface occupancy allowed

Gallo Hill Surface occupancy allowed

Game Creek Surface occupancy allowed

Grizzly Creek Surface occupancy allowed

Hardscrabble Surface occupancy allowed

Hay Park Surface occupancy allowed

Hunter Part available, surface use allowed

Little Grand Mesa Surface occupancy allowed

Lower Piney Surface occupancy allowed

Maryland Creek Surface occupancy allowed

McClure Pass Surface occupancy allowed

Meadow Mountain A Surface occupancy allowed

Meadow Mountain B Surface occupancy allowed

Morapos A NSO

North Elk Surface occupancy allowed

North Woody Surface occupancy allowed
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

146—Chapter 3. Affected Environment and Environmental Consequences

Forest 1 Roadless area Nature of Availability

Pagoda Peak NSO

Piney Lake Surface occupancy allowed

Porcupine Peak Surface occupancy allowed

Ptarmigan A Surface occupancy allowed

Ptarmigan Hill A Surface occupancy allowed

Red Dirt A Surface occupancy allowed

Red Dirt B Surface occupancy allowed

Red Mountain Surface occupancy allowed

Ryan Gulch Surface occupancy allowed

Salt Creek Surface occupancy allowed

Sloan Peak Surface occupancy allowed

Spraddle Creek B Surface occupancy allowed

Sweetwater A Surface occupancy allowed

Sweetwater B Surface occupancy allowed

Tenderfoot Mountain Surface occupancy allowed

West Brush Creek Surface occupancy allowed

West Lake Creek Surface occupancy allowed

Wildcat Mountain Surface occupancy allowed

Wildcat Mountain B Surface occupancy allowed

Wildcat Mountain C Surface occupancy allowed

Williams Fork Surface occupancy allowed

Willow Surface occupancy allowed

Woods Lake Part available, surface occupancy allowed

1 Pike-San Isabel National Forest is not included because leasing availability data were not available. However, Pike-San Isabel 

has very few, if any, roadless areas with any kind of development potential. San Juan National Forest is not included because the 

oil and gas leasing availability decision-making process is underway.

Leasable Minerals – Geothermal: Environmental Consequences

Currently there are no geothermal leases within an IRA or CRA and therefore there likely 

would be no development of geothermal resources under alternatives 1, 2 and 4. Future leasing 

of geothermal resources would be allowed but road construction would be prohibited and 

therefore limit the potential for any future development.

Alternative 3 would allow development of geothermal resources in roadless areas to the extent 

that forest plans would allow for such activities in roadless areas, including roads. Specific 

geothermal assessment information is insufficient to quantify or even qualify the extent and 

location of possible development.

Cumulative Effects

Saleable Minerals

Under all of the alternatives considered in detail there is minimal direct and indirect effects to 

saleable minerals and would not result in a significant cumulative effect.

Locatable Minerals

No direct or indirect effects to locatable minerals are anticipated from any of the alternatives 

and therefore would not result in a significant cumulative effect.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—147

Leasable Minerals – Coal

Population growth would continue to drive demand for coal resources for use in electric power 

generation. Road prohibitions under alternative 1 would restrict access to known reserves of 

compliant and super-compliant coal, contributing to less overall availability of ―clean‖ coal to 

meet demand. Under alternative 1, coal production from existing mines could dissipate in about 

20 years, as remaining unleased reserves would be inaccessible for exploration and surface uses 

related to mining. Under alternatives 2 and 4, roads allowed for developing known coal 

reserves in the North Fork coal mining area would facilitate an estimated potential 365 million 

tons of recoverable coal reserves to be developed and contribute to supply needed to meet 

demand. However, road prohibitions in Colorado Roadless Areas outside the North Fork coal 

mining area would contribute to an undetermined quantity of coal not being explored or 

developed, contributing to a known resource base being unavailable to meet demand. Under 

alternative 3, access to leased coal reserves and other coal resources in roadless areas 

throughout the State would contribute to supply needed to meet demand. Alternative 4 would 

have the same effect as alternative 2 because no upper tier acres overlap with current or project 

coal leases.

When comparing the direct and indirect effects of other actions that overlap both 

geographically and temporally there would be no significant cumulative effect to coal resources 

from any of the alternatives analyzed in detail. 

Leasable Minerals – Oil and Gas

Demand for natural gas is projected to increase 0.2 percent per year through 2030 (USDOE 

2009). Domestic demand for oil is projected to remain steady through 2030. Production of 

natural gas and oil from NFS lands will contribute to supply needed to meet demand. The fossil 

energy resource most likely to contribute to supply from Colorado roadless areas is natural gas.

When comparing the direct and indirect effects of other actions that overlap both 

geographically and temporally there would be no significant cumulative effect to the 

development of oil and gas resources from any of the alternatives analyzed in detail. 

Leasable Minerals – Geothermal

Depending on applicable forest plan direction, access to these resources under all alternatives 

could allow some development that would contribute to energy supply, however, with road 

construction prohibitions associated with alternatives 1, 2 and 4 development is highly unlikely.

Any contribution to supply cannot be quantified due to minimal assessment of geothermal

resources in Colorado and corresponding lack of data and any effects could not be analyzed in a 

meaning manner. Therefore none of the alternatives would result in a significant cumulative

effect to geothermal resources.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

148—Chapter 3. Affected Environment and Environmental Consequences

SOIL, WATER & AIR RESOURCES

Introduction

The Physical Resource analysis evaluates the potential environmental consequences on soil, 

water and air. These resources have measurable characteristics that can be assessed in light of

the prohibitions and exceptions for tree-cutting, sale or removal; road 

construction/reconstruction; discretionary mineral activities as well as natural processes. Highquality or undisturbed soil, water, and air are important roadless area characteristics; therefore 

the analysis evaluates the potential consequences on these three components.

Soil: Affected Environment

This analysis evaluates potential effects of the alternatives on the soil resource, focusing on key 

differences in foreseeable activities under each rulemaking alternative. Changes in soil 

conditions typically have interrelated effects on vegetative productivity and water quality; the 

analyses of effects on other resources are described in separate sections.

Soil is a fundamental component of the environment. Soil health has been defined as ―capacity 

of a specific kind of soil to function within natural or managed ecosystem boundaries, to sustain 

plant and animal productivity, maintain or enhance water quality, and support human health 

and habitation‖ (Karlen et al. 1997). 

Soil within the potentially affected roadless areas in Colorado is generally in a satisfactory 

condition. Roadless areas in Colorado have many different soil types because of the wide ranges 

in: geologic parent material, elevation, precipitation, topography, and geologic time during 

which soil formation has been taking place. Some soil types are relatively more prone to 

accelerated surface erosion, due primarily to inherent soil properties and terrain features such 

as slope. Erosion hazard on most of the soils in the analysis area can be characterized as low to 

moderate, with the moderate rating being dominant. High erosion hazards are associated with 

soils on slopes greater than 40 percent. 

Soil: Environmental Consequences 

All Alternatives

Tree-cutting, sale or removal; road construction/reconstruction; and use of linear construction 

zones can affect soil productivity by compacting soils, increasing erosion, displacing soils, 

releasing carbon dioxide, depleting nutrients, increasing overland flow in areas of high amounts 

of precipitation and soil disturbance, and reducing soil strength. Most of the changes in soil 

conditions would be limited to relatively small, localized areas. Construction of permanent 

roads or other long-term infrastructure such as communication sites or oil and gas drilling pads 

is considered a dedicated use. 

During project-level analysis, areas sensitive to surface erosion are identified and appropriate 

mitigation measures are used to reduce surface erosion and sediment production. New road 

location or facility construction would be done to minimize placement on highly sensitive soil. 

Roads would typically not be located on steep slopes (over 40 percent) where landslides are 

more common. Resource protection measures, such as those in the Forest Service regional 

watershed conservation practices handbook and other best management practices including 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—149

post-project rehabilitation of disturbed soil, would be applied during any ground disturbing 

activities to minimize soil loss. Erosion is a naturally occurring event; the objective is to retain 

erosion rates following project implementation that approximate pre-existing background rates. 

Implementation of a well-prepared surface erosion and sediment control program in 

conjunction with tree-cutting, road construction, or linear construction zones can mitigate the 

potentially degrading impacts of surface erosion. Under all alternatives, roads decommissioned 

would have a beneficial effect on soil resources by restoring infiltration and vegetative cover, 

thus reducing soil erosion. In those areas that need ground cover, disturbed sites would be 

revegetated after the project is completed. 

Other ongoing ground-disturbing activities in roadless areas are known to contribute to 

localized impacts on soil quality but are not measurably different under any of the alternatives. 

Examples include: prescribed fire and wildland fire, hard-rock mining, livestock grazing, and 

recreational use. Whether or not the permitted acres of ski areas remain within the roadless 

areas under an alternative, the extent of new ski area roads and facilities is projected to be 

minimal over the next 15 years. 

The potential for adverse impacts on the soil resource in roadless areas would differ slightly 

among the alternatives based on acres disturbed by projected road construction or 

reconstruction, tree removal, linear construction zones, or other ground disturbing activities. 

Alternatives 1, 4, and 2 have restrictions on tree-cutting and road construction to facilitate treecutting for hazardous fuels treatments (in the order listed with alternative 1 being the most 

restrictive). Restrictions may result in a greater risk of high-severity wildfires and larger fires 

(see Fire/Fuels section). The higher severity and larger fire size would result in increased 

adverse post fire effects due to erosion and slower vegetation recovery as compared to other 

alternatives. 

In general, impacts in any alternative would be limited in geographic extent and be distributed 

over many different roadless areas. Thus, the actual effects on soil quality would be minor and 

of short duration. 

Alternative 1 – 2001 Roadless Rule

This alternative would have the least potential for accelerated rates of erosion or landslides in 

roadless areas caused by tree-cutting activities and road construction, or reconstruction due to 

the prohibitions on these activities. Very few permanent roads or major facilities would be 

expected to be built in the roadless areas with little to no permanent loss of the productive 

capacity of the land. The use of linear construction zones is not limited in this alternative. There 

is an increased risk of a high-severity wildfire event over the other three alternatives, which 

could increase soil erosion or landslides.

The limited miles of road construction, tree-cutting, sale or removal and linear construction

zones in IRAs would be scattered among many different roadless areas. Only a fraction of these 

activities would occur on high erosion hazard soils and mitigation measures would be 

implemented to minimize soil erosion. 

Maintaining restrictions on new road construction in the substantially altered areas would 

further help to maintain desirable soil conditions in the roadless areas, even though tree-cutting 

activities would continue to occur along existing roads in those areas. The 409,500 acres of 

unroaded areas outside IRAs would continue to incur the same soil effects that are currently 

occurring, and potential soil impacts may increase if roads are built in those areas in the future. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

150—Chapter 3. Affected Environment and Environmental Consequences

Alternative 2 – Colorado Roadless Rule (Proposed Action)

Alternative 2 would result in slightly higher risk then alternatives 1 or 4 but less than 

alternative 3, of affecting the soil resource but the soil resource would remain in a functioning 

condition, with no significant loss of long-term soil productivity. 

Activities in this alternative are limited in geographic extent and would be distributed over 

many different roadless areas. Trees would be cut for the reduction of wildfire risk in the CPZ

with limited temporary road construction. Coal mining would be limited to the North Fork coal 

mining area. The 15-year projection for coal mining and related temporary road construction is 

greater than alternative 1, less than 3 and the same as alternative 4. As this activity is completed, 

these areas would be reclaimed. The use of linear construction zones is limited to three 

exceptions under alternative 2. The upper tier acres would essentially have no new road 

construction and limited individual trees cut. 

Not including the substantially altered areas in CRAs under alternative 2 is projected to result 

in some miles of new road construction in those areas over the next 15 years, which would not 

occur under alternative 1. The addition of 409,500 acres of unroaded areas into CRAs would 

reduce the potential for road-related impacts on soil quality in those areas. Impacts of road 

construction would be mitigated to a large extent. Nearly all the roads constructed in the CRAs 

would be decommissioned. Very few forest roads are projected to be constructed in the CRAs in 

the next 15 years that result in a permanent loss of soil productivity.

Alternative 3 – Forest Plans (No Action)

This alternative would result in a higher risk of adversely affecting soil resource in the analysis 

area compared to the other alternatives. This is because of the additional ground disturbing 

acreage in IRAs projected to be used for tree-cutting and removal activities, road construction, 

and oil, gas and coal development activities. There is an increased risk of localized and shortterm soil impacts, including a higher risk of road-related soil erosion, because there would be 

more acres of soil disturbance in this alternative. The forest roads projected to be built in the 

IRAs would result in those acres being permanently converted to a non-vegetated state, with an 

associated loss in soil productivity on those acres. Soil quality impacts on the 409,500 acres of 

unroaded areas not included in IRAs under alternative 3 would be the same as described for 

alternative 1. Like alternative 1, there would be a higher potential for adverse soil quality 

impacts from future road construction or reconstruction and other development activities in 

these unroaded areas. However, overall the soil resource impacts would not substantially differ 

from the other alternatives, and long-term soil productivity in IRAs would be expected to be 

maintained at a satisfactory level. 

Alternative 3 allows for tree-cutting and road construction to facilitate tree-cutting for 

hazardous fuels treatments, dependent on forest plan direction. The ability to treat areas 

without limitation as to the distance from the at-risk communities or purpose (i.e. watershed

protection rather than municipal water supplies only) may result in reduced fire severity and 

adverse fire effects. The potential for post-fire accelerated erosion and other wildland firerelated impacts to soil quality in roadless areas is reduced under this alternative. 

Alternative 4 – Colorado Roadless Rule with Public Proposed Upper Tier

Alternative 4 would result in slightly higher risk then alternative 1 but less than alternatives 2 

or 3, of affecting the soil resource. The soil resource would remain in a functioning condition, 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—151

with no significant loss of long-term soil productivity. 

The environmental consequences of this alternative are similar to alternative 2. The difference 

between the two alternatives is the extent of the upper tier acres within CRAs. Because of over 2 

million additional upper tier acres, less tree-cutting and road construction is projected than 

alternative 2. The potential for accelerated rates of erosion or landslides in roadless areas caused 

by tree-cutting activities and road construction, or reconstruction is less than alternative 2 but 

there is an increased risk of a high-severity wildfire event over alternative 2, which could 

increase post-fire soil erosion or landslides.

Water: Affected Environment

Water Quality

Colorado is a headwaters state. Four of the great rivers in the United States have their origins in 

the Rocky Mountains of Colorado: the Colorado, Platte, Arkansas, and Rio Grande. There are 

seven major river basins in Colorado: Arkansas, Rio Grande, San Juan, Colorado, Green, Platte, 

and Republican. Each major river basin contains many distinct watersheds, which are mapped 

by the U.S. Geological Survey and referenced with 8-digit hydrologic unit codes (maps available 

at www.water.usgs.gov). The 5th–level (hydrologic unit code) watersheds range from 40,000 to 

250,000 acres in size and 6th-level sub-watersheds typically range from 5,000 to 40,000 acres. 

Water quality is generally good in roadless areas due to their location, often located either in the 

headwaters of stream systems or immediately down slope of relatively undisturbed areas such 

as wilderness. Streams and lakes are better protected in large, relatively undeveloped areas 

where management activities are limited. Changes to water quality or quantity from activities 

that occur within a roadless area is most evident at the 6th-level sub-watershed scale and may 

not be evident at the 5th-level watershed scale or river basin scale because of the interaction of 

pollutants coming from other activities in the larger watershed.

The seven major river basins in Colorado contain approximately 252,300 acres of lakes, 

reservoirs, and ponds (waterbodies). Only 3,700 acres of these waterbodies are on NFS lands 

and a small percentage of those occur in the roadless areas. Colorado contains approximately 

95,500 miles of rivers and streams (Table 3-23). Approximately 17% of the waterbody acreage in 

Colorado and approximately 13% of the river and stream miles are listed as impaired in the 

State‘s 305(b) report (Colorado Department of Public Health and Environment, Water Quality 

Control Division 2008a). An impaired listing means it does not meet state or federal water 

quality standards for one or more critical pollutants. Based on these low percentages, the water 

quality of waterbodies and streams in Colorado is considered to be very good. 

Table 3-23 shows the distribution of stream miles within the seven major river basins, along 

with the stream miles listed as impaired in Colorado and in roadless areas (Colorado 

Department of Public Health and Environment, Water Quality Control Division 2008b). There is 

not a substantial difference in the number of impaired stream miles in IRAs or CRAs, so they 

are shown in the same column (as a range of miles where they differ slightly). 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

152—Chapter 3. Affected Environment and Environmental Consequences

Table 3-23. Streams and impaired streams in Colorado, and impaired stream miles in roadless 

areas, by river basin

River basin Total stream miles 1Impaired stream miles 1

Impaired stream miles in 

CRAS-IRAs 2

Arkansas 22,100 3,100 43

Rio Grande 10,100 300 0

San Juan 5,800 200 5 - 8

Colorado 19,300 4,100 23

Green 13,400 2,300 0

Platte 19,000 2,800 10

Republican 5,800 40 0

Total 95,500 12,840 83

Totals may not add due to rounding.

1

State of Colorado 2008 305(b) report (Colorado Department of Public Health and Environment, Water Quality Control 

Division 2008a).

2 State of Colorado 2006 303(d)-listed streams (Colorado Department of Public Health and Environment, Water Quality Control 

Division 2006) overlaid with GIS maps of IRAs and CRAs (Roadless Area GIS Database 2008) as modified by State of Colorado 

2008 and 2010 303(d) lists (Colorado Department of Public Health and Environment Water Quality Control Division 2008b, 

2010).

Table 3-24 displays the impaired streams in the roadless areas by national forest and the cause 

for the impairment. The major pollutants are selenium; other metals such as iron, zinc and 

copper; pathogens (fecal coliform and E. coli); and sediment. Pollutants causing impairments to 

aquatic life in lakes and reservoirs are unknown biologic stressors, mercury, selenium, pH, and 

dissolved oxygen saturation. Waterbody acres are not shown in the table because there are so 

few in the roadless areas. 

Table 3-24. Streams in the analysis area and impaired streams by national forest, and the cause 

for impairment

National forest

Total stream

miles 1

Impaired stream miles 

in CRAs-IRAs Cause of impairment 2

Arapaho-Roosevelt 500 3 Metals

GMUG 1,500 10 Selenium

Manti-La Sal 10 0 ---

Pike-San Isabel 800 43 Selenium, pathogens, metals

Rio Grande 700 0

Routt 700 7 Iron

San Juan 700 8 Metals

White River 900 13 Selenium, sediment metals

TOTAL 5,810 83

Totals may not add due to rounding

1 Roadless Areas GIS database- streams layer and IRA/CRA layers, April 2008). 

2 State of Colorado 2006 303(d) listed streams (Colorado Department of Public Health and Environment Water Quality Control 

Division 2008a; Roadless Areas GIS Database, April 2008; Colorado Department of Public Health and Environment Water 

Quality Control Division 2008b).

The roadless areas on the Pike-San Isabel National Forests have the greatest number of 

impaired stream miles. These miles are primarily in the Pikes Peak East CRA (East Pikes Peak 

IRA) and Pikes Peak West CRA (West Pikes Peak IRA) roadless areas and are impaired by 

either selenium or pathogens. A major source of selenium in streams is from irrigation of high 

selenium soils downstream from National Forest System lands. Sources of pathogens can be 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—153

wildlife, livestock, and/or humans—from dispersed recreation, from storm water discharges in 

developed areas, or from poorly functioning sanitation facilities such as failing septic tanks. 

Historical mining activities are likely the primary source of metal causing impairment. Black 

Gore Creek in the East Vail CRA/IRA is impaired by sediment primarily from Interstate 70 

road de-icing sand. 

For waterbodies listed as impaired, Section 303(d) of the Clean Water Act requires the 

calculation of a Total Maximum Daily Load (TMDL), the maximum amount of a pollutant that a 

waterbody can receive and still safely meet water quality standards. For those State-listed 

impaired stream segments occurring in roadless areas, the table below details their TMDL 

status by river basin. Additional details are in the EIS record. 

Table 3-25. Status of Total Maximum Daily Loads for Impaired Waterbodies in Roadless Areas

River Basin

Delisted in 

2008

Completed 

TMDLs in 

2008/2009

Draft TMDLs 

Completed 

in 2008/2009

Draft 

TMDL in 

works

Delisted 

in 2010

TMDLs 

with No 

Info

Arkansas 4 7 0 1 7 4

Rio Grande 0 4 0 0 4 0

San Juan 0 0 0 1 1 0

Colorado 0 7 2 6 7 2

Green 0 0 0 0 1 0

Platte 0 4 0 1 4 5

Republican 0 0 0 0 0 0

Total 4 22 2 9 24 11

Water Supply

Water is used for a variety of purposes including public water supply, agriculture, industrial 

uses (including mining), recreation, and support of aquatic life. Roadless areas are composed 

mostly of mountainous terrain that receives the highest amounts of precipitation in the State. 

Approximately 68% of the water yield in Colorado originates on NFS lands and much of this is 

from within the roadless and wilderness areas (Brown et al. 2005). More than 95% of the 

roadless areas in Colorado overlap one or more source water assessment areas, watersheds 

identified by the State around public surface and groundwater supply sources (Colorado 

Department of Public Health and Environment, Water Quality Control Division 2004 and 

2008a). The Forest Service is required to manage public supply watersheds for multiple uses 

recognizing the domestic water supply needs, and to use only proven techniques in managing 

these watersheds (36 CFR 215.9 and Forest Service Manual 2542). Numerous reservoirs, 

diversions, ditches, tunnels, and other water conveyance facilities located in roadless areas are 

important for storing and delivering water supplies to downstream users. Water conveyance 

structures change the stream flow regime.

There are no sole source aquifers or drinking water sources in the IRAs or CRAs that are subject 

to §149 of the Safe Water Drinking Act. The Environmental Protection Agency (EPA) has the 

authority for this program and has not designated such sole source aquifers in Colorado. 

Climate change also has occurred and is continuing to occur (USDA Global Change Program 

Office 2001). Climate change is expected to result in a gradual warming trend that would affect 

hydrologic systems within Colorado. There would continue to be less precipitation and more 

drought conditions anticipated in the future (Saunders et al. 2008). Climate change is expected 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

154—Chapter 3. Affected Environment and Environmental Consequences

to result in decreased winter snowpacks, more winter precipitation as rain rather than snow, 

earlier snowmelt, and reduced summer low flows (Saunders et al. 2008). These climatic trends 

would be expected to increase the size and magnitude of wildland fire events, and the 

magnitude of insect-disease outbreaks, which would affect hydrologic functions, water yield, 

and water quality in roadless area watersheds. 

Water: Environmental Consequences

Activities that result in soil compaction, erosion, loss of vegetation cover and excess water 

runoff can cause excess sediment and other pollutants to more easily enter waterbodies 

degrading water quality. The most common sources of potential water quality impacts in the 

analysis area that vary by alternative are: tree-cutting activities; road 

construction/reconstruction; linear construction zones; and oil-gas or coal operations. Other 

sources of potential water quality impacts do not vary measurably by alternative such as: offhighway vehicle use, livestock grazing, hard-rock mining, biking, and dispersed camping. 

Potential impacts from management activities on NFS lands are mitigated (avoided, reduced, or 

minimized) by following best management practices (BMPs) designed to control nonpoint 

sources of pollutants and meet Clean Water Act standards for water quality (Forest Service 

Manual 2532). Water quality impacts are also mitigated through application of the Forest 

Service regional watershed conservation practices handbook (FSH 2509.25). This handbook is 

recognized in Colorado‘s nonpoint source management program as a technical reference and 

guidance document for planning and implementation of Colorado‘s BMPs (Colorado 

Department of Public Health and Environment, Water Quality Control Division 2005). Some 

activities authorized in roadless areas are subject to permit requirements outlined in sections 

401, 402, and 404 of the Clean Water Act. Permits may be required for such actions as road 

construction, mining and oil and gas development.

Leasable and Locatable Minerals

Oil and gas development activities are subject to Colorado Oil and Gas Conservation 

Commission (COGCC) rules (2 CCR 404-1). Disposal of produced water from oil and gas

development is regulated by the State to protect water quality. Other activities, such as hardrock mining, are sometimes subject to State permits. All these permits and regulations mandate 

use of BMPs and monitoring to minimize discharge of pollutants to waterbodies. 

Road construction

Research has found that road construction and road use on national forests can adversely affect 

watershed geomorphology, hydrologic processes, stream sedimentation, and chemical pollution

(Gucinski et al. 2000; MacDonald and Stednick 2003). The longer a road feature remains in 

place, the greater is the potential for adverse effects to water quality resulting from that road.

All things being equal, a well-designed and located temporary road that is decommissioned 

after use would have less long-term adverse effects on water quality than a permanent forest 

road that is continually open and requires periodic maintenance.

Water Yield and Flooding

Water yield can be affected by large-scale changes in vegetation cover within a watershed. At 

least 20 to 30 percent of the basal area in a watershed needs to stop transpiring to generate a 

measurable increase in water yield (MacDonald and Stednick 2003). The hydrologic recovery 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—155

following large-scale removals of vegetation to pre-disturbance water yield levels can take as 

long as 60 years (MacDonald and Stednick 2003). 

The wide-spread mountain pine beetle epidemic that is killing pine species throughout 

Colorado is likely contributing to some temporary increases in water yield. The Rocky 

Mountain Regional Entomologist estimates that the majority of the lodgepole pine forests in 

Colorado will be killed by the beetles within the next five years (Cain 2008). The effect on water 

yield occurs when a tree dies whether or not it is removed from the site.

Large, high-severity, stand-replacing wildland fires are known to cause temporary increases in 

water yield and peak flows on NFS lands in Colorado. High-severity fires typically cause a loss 

of protective vegetative ground cover and may create a hydrophobic layer or ―seal‖ over the 

soil surface, resulting in substantial runoff of rainfall water. The short-duration, high-intensity 

rainstorms that follow a fire can produce high peak flows and flash floods changing channel 

structures and adversely affect water quality due to high sediment loads. During these post-fire 

rainstorms, a large quantity of rainwater is carried rapidly down burned slopes, carrying ash, 

topsoil, and small woody material into stream drainages. The risk of post-fire floods during 

summer convective storms is greatest in the first two or three years following the fire 

(MacDonald and Stednick 2003). 

Early season run-off events could be accentuated by impacts associated with climate change. 

Climate change understanding, at this point in time, does not allow for accurate, site-specific 

predictions for conditions such as flooding, and subsequent management responses. However, 

in general, warmer winters and changes in precipitation regimes may lead to increased 

flooding. 

All Alternatives

Water yield in Colorado would not be measurably altered by activities in any alternative. No 

alternative projects tree-cutting to the magnitude or extent, (e.g. exceeding the 20% basal area 

threshold), to cause a measurable change in water yield. Many roadless areas would continue to 

be affected by continued pine tree mortality, together with potential for high-severity wildland 

fires, resulting in future short-duration, localized increases in water yield. 

Where ground-disturbing activities occur, the potential for adverse impacts on water quality is 

increased from possible accelerated erosion and sedimentation entering nearby waterbodies. 

The extent and location of the ground disturbance with its duration on the ground are all factors 

in the potential impact of the disturbance on water quality. Most of the activities allowed in the 

alternatives would be scattered among many different roadless areas and watersheds, and 

limited to relatively small, localized areas. Many of the ground disturbing activities in the 

alternatives are of relatively short duration including linear construction zones or temporary 

roads. 

All projects are subject to the NEPA process and site-specific analysis to determine appropriate 

mitigation measures. With the application of mitigation measures and BMPs to each project, the 

potential would be very low for exceeding water quality standards. Activities are unlikely to 

contribute to further impairment of streams currently listed on the State 303(d) list. 

Project areas where vegetation is removed and soil is exposed are restored to natural vegetation 

cover after the project completion. Reduction of road density is one of the best watershed

restoration treatments that can be used to improve watershed and stream health. Road 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

156—Chapter 3. Affected Environment and Environmental Consequences

decommissioning treatments help disperse surface water runoff and eliminate the road as a 

source of stream sedimentation. Where slope re-contouring is used to decommission the road, 

subsurface water flow paths would be restored, further erasing the effect of the road. Projected 

decommissioning of existing roads in the analysis area is the same under all alternatives.

Alternatives 2 and 4 require decommissioning of all new road construction when no longer 

needed for the established purpose; however, this is generally the case in all alternatives. 

Oil and gas operations may generate large volumes of water throughout the life of the project. 

This produced water may or may not be of sufficient quality to be disposed of on the surface 

and may need to be re-injected into deep aquifers. Water produced by the project that is 

discharged into waterbodies is regulated by State discharge permits to ensure water quality

standards are met. There is an increased potential for chemical contamination of surface and 

groundwater by hydrocarbons or other substances (fracking compounds) used in oil and gas

production, although BMPs would be used to prevent chemical contamination from areas like 

drilling pits. Another potential source of chemical contamination is accidental spills, the risk 

increasing with the amount of oil and gas activity. Site-specific mitigation measures and 

regulatory requirements such as Clean Water Act permit requirements and COGCC rules 

would be used to adequately protect water quality during these activities. 

A high-severity wildland fire can result in an elevated risk of water quality impacts on 

municipal water supplies. In the event water quality for a municipal water supply is threatened 

from the effects of a high severity wildland fire, the Burned Area Emergency Response (also 

known as BAER) program (Forest Service Manual 2523) would be used to identify post-fire 

threats, critical values at risk and the need for emergency stabilization measures. Emergency 

stabilization measures are implemented as needed to moderate the intensity or severity of 

effects, reducing the risk to municipal water supplies and other critical values at risk. 

Alternative 1 – 2001 Roadless Rule 

This alternative projects the least amount of tree-cutting or road construction over the next 15 

years of the four alternatives. It has the least risk of potential adverse effects on water quality. 

Maintaining the substantially altered areas within IRAs with the general prohibition on new 

roads would further help to maintain desirable soil and water quality conditions in the IRAs. 

Tree-cutting would continue to occur along existing roads in those areas, but it would not be 

expected to result in adverse impacts on water quality. On the 409,500 acres of unroaded area

outside IRAs, there could be an increase in potential impacts on water quality from future land 

use activities that otherwise would be prohibited in IRAs. 

Alternative 1 poses a slightly increased risk of experiencing a high-severity wildland fire 

because of the low amount of fuel reduction projected to occur in IRAs. The risk of flash floods 

and increased sedimentation in streams is increased. Implementing the Burned Area Emergency 

Response program would reduce the risk to municipal water supplies and other critical values 

at risk. 

This alternative does not limit the use of linear construction zones. New water conveyance 

structures could be constructed or maintained using a linear construction zone. However, the 

lack of a road construction exception for this purpose could limit some new water conveyance 

structures from being located in IRAs. New water developments could occur in the 409,500 

acres not in IRAs that are guided by forest plan direction. It is likely this alternative would have 

the least risk for water quality effects from construction of new water conveyance structures 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—157

including reservoirs, or for changes in stream flow regimes due to new flow diversions or 

storage facilities of all the alternatives.

Alternative 2 – Colorado Roadless Rule (Proposed Action)

This alternative projects an increased level of both tree-cutting and road construction over

alternatives 1 and 4, but less than 3. There is a slightly greater risk of adverse impacts on water 

quality in CRAs. Removing the substantially altered acres and adding the acres of unroaded 

into the CRAs, slightly decreases the amount of roadless acres in this alternative from the IRA 

acres in alternatives 1 and 3. There would be a slight increase in the potential for water quality 

impacts on those lands where ground disturbing activities could occur. 

Alternative 2 has increased projections for coal mining and associated new roads in the North 

Fork coal mining area and would increase the potential for adverse water quality impacts in 

those CRAs. There would be an increased risk of higher sediment, chemical contamination and 

accidental chemical spills in streams within the North Fork coal mining area. Mitigation 

measures and BMPs would reduce the likelihood of significant impacts from large sediment 

loads or accidental chemical spills. Remediation actions are applied if such accidents occur. The 

potential for significant adverse impacts from sediment and chemical inputs from increased 

coal activities would be expected to be negligible. 

The risk of a high-intensity wildland fire in a roadless area resulting in water quality impacts on 

a municipal water supply would be decreased under alternative 2 relative to alternatives 1 or 4. 

More acreage would be treated to abate wildland fire hazards in CRAs to protect at-risk 

communities and municipal water supply sources. Implementing the Burned Area Emergency 

Response program would reduce the risk to municipal water supplies and other critical values 

at risk.

This alternative includes both a road construction exception (other than in the upper tier acres) 

and a linear construction zone exception for new water conveyance structures authorized 

pursuant to water rights granted by a pre-existing water court decree. All of the water 

conveyance structures that have a pre-existing water court decree within CRAs could be 

constructed but future structures within CRAs would be extremely limited because of the 

prohibition on road construction. Water quality effects, including changes in stream flow 

regimes, from the construction of new flow diversions, storage facilities (e.g. reservoirs) or 

water conveyance structures may be higher in this alternative than alternatives 1 or 4.

Alternative 3 – Forest Plans (No Action)

Alternative 3 projects the highest level of tree-cutting and road construction of the alternatives. 

There is a slightly greater risk of adverse impacts on water quality in CRAs. With effective 

mitigations, this alternative is not expected to cause water quality standards to be exceeded in 

the analysis area.

Alternative 3 has the greatest amount of projected oil, gas and coal operations and therefore has 

the greatest potential risk of adverse effects on water quality from those activities. Site-specific 

mitigation measures and regulatory requirements would be expected to adequately protect 

water quality during these activities. However, the risk of accidental chemical spills or 

increased sediment or chemical levels in streams would be the highest under this alternative. 

Alternative 3 poses a decreased risk compared to the other three alternatives of experiencing a 

high-severity wildland fire because of the flexibility and level of fuel reduction projected to 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

158—Chapter 3. Affected Environment and Environmental Consequences

occur in the analysis area. As in the other alternatives, in the event that water quality for a 

municipal water supply is threatened by the effects of a high severity wildland fire, the Burned 

Area Emergency Response program would be implemented.

Construction and maintenance of water conveyance structures would be guided by forest plan

direction in alternative 3. In most of the analysis area, there is no restriction or limitation and 

the potential for new water conveyance structures is greatest in this alternative. The potential 

for risks to water quality or to changes in streamflow regime in the analysis area would be 

greatest in alternative 3.

Alternative 4 – Colorado Roadless Rule with Public Proposed Upper Tier

The environmental consequences of this alternative are similar to alternative 2. However, there 

are over 2 million more upper tier acres in this alternative. Because of this, tree-cutting and road 

construction projections are less than alternative 2; reducing the risk of adverse impacts on 

water quality in CRAs. 

Coal mining development levels are the same as alternative 2. The risk of a high-intensity 

wildland fire in a roadless area resulting in water quality impacts on a municipal water supply

is increased from alternative 2 because of the smaller amount of projected fuel reduction 

treatments. Fewer water conveyance structures would be located within CRAs due to the lack 

of a road construction exception in the upper tier acres. A linear construction zone could be 

used on the upper tier acres. 

Air: Affected Environment

Air Quality

The Forest Service coordinates with the State of Colorado, the Environmental Protection Agency

and other agencies to prevent air quality impacts on Forest Service administered lands, in 

accordance with Clean Air Act, the Wilderness Act, and the Organic Act. Of the airsheds that 

overlap portions of roadless areas in Colorado, no areas are currently designated as ―nonattainment‖ for particulate matter (http://apcd.state.co.us; and 

http://www.epa.gov/oar/oaqps/greenbk/), which means they are in compliance with state 

and federal Clean Air Act standards for air quality and do not exceed thresholds for specific 

pollutants. All of the airsheds that overlap roadless areas in Colorado meet all air quality 

standards. 

There are eleven Class I airsheds located within a 10-mile radius of roadless areas. Class I areas 

must be managed to meet more stringent air quality levels compared to other areas. They are 

typically large wilderness areas and National Parks. Many of the roadless areas lie adjacent to 

these Class I areas. All currently meet state and federal air quality standards.

The eleven Class I airsheds do have existing visibility impairment over background levels and 

do not meet the national visibility goal of having no anthropogenic (human) caused visibility 

impairment (http://www.cdphe.state.co.us/ap/regionalhaze.html). The national visibility goal 

in the Clean Air Act is to achieve visibility conditions in Class I areas that are unimpaired by 

anthropogenic sources of air pollution or in other words to achieve natural background 

visibility conditions. Generally, monitoring data has not shown a discernible trend, although 

given the energy development in the West it is anticipated that the visibility impairment may 

increase. The Forest Service cooperates with the State of Colorado, the Environmental 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—159

Protection Agency, and the National Park Service in monitoring potential impacts on air quality 

to prevent any future and remedy any existing visibility impairment. 

A deciview is a measure of visibility impairment measured using a logarithmic scale similar to 

decibels for sound. In the regional haze rule definition of deciview, the Environmental 

Protection Agency states: ―A deciview is a haze index derived from calculated light extinction, 

such that uniform changes in haziness correspond to uniform incremental changes in 

perception across the entire range of conditions, from pristine to highly impaired‖ (40 CFR 

§51.301).

Table 3-26 shows the annual average, cleanest 20%, and haziest 20% natural background 

conditions for Colorado Class I areas (measured in deciviews). Comparing those to the annual 

average, cleanest 20%, and haziest 20% monitored (baseline) visibility conditions for the period 

2000 to 2004 shows that natural background visibility conditions in those Class I areas have not 

been met and that there is existing visibility impairment in those Class I areas. 

Table 3-26. Class 1 Area Visibility (measured in deciviews (dv))

IMPROVE 

Site Class I Area(s)

Annual 

Average 

Natural 

Conditions

Annual 

Average 

Baseline*

Clearest 

20% Natural 

Conditions

Clearest 

20% 

Baseline*

Haziest 

20% 

Natural

Haziest 

20% 

Baseline*

GRSA1 Great Sand -Dunes 3.47 8.27 1.24 4.5 6.66 12.78

MEVE1 Mesa Verde 3.33 8.13 1.06 4.32 6.83 13.03

MOZI1

Mount Zirkel

2.41 5.8 0.55 1.61 6.44 10.52

Flat Tops

ROMO1 Rocky Mountain

Rawah

3.29 7.79 0.53 2.29 7.24 13.83

WEMI1

Weminuche

La Garita

Black Canyon of 

Gunnison

3.23 6.49 1.02 3.11 6.24 10.33

WHRI1

Maroon Bells

West Elk

Eagles Nest

2.17 4.85 0.52 0.7 6.54 9.61

* From 2000-2004 monitoring data at IMPROVE sites (http://vista.cira.colostate.edu/improve/)

Air: Environmental Consequences 

All Alternatives

Air pollution sources from activities that could occur in roadless areas under the four 

alternatives include: fine particulate (dust) emissions from road construction and use of 

unsurfaced roads; volatile organic compounds and oxides of nitrogen from gasoline

combustion; soot, volatile organic compounds, oxides of nitrogen, and sulfur dioxide from 

diesel engines; various pollutant emissions from oil and gas extraction operations; and 

particulates and noxious compounds from smoke generated from prescribed burning. Some of 

these are greenhouse gas emissions, most notably carbon dioxide, but also methane and nitrous 

oxide. The less these activities occur in the alternatives, the less the risk of air pollution. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

160—Chapter 3. Affected Environment and Environmental Consequences

There is some trade-off between the particulates and noxious compounds from smoke from 

prescribed burning and those generated from wildfires. If prescribed burning occurs, the Forest 

Service would continue to consult with the Colorado Department of Public Health and 

Environment through the permitting processes prior to conducting prescribed burns in order to 

ensure that any effects to air quality are within state and federal air quality standards. Wildfires, 

on the other hand, may exceed air quality standards. 

Alternative 3 does allow for a higher level of oil and gas development than the other three 

alternatives, increasing the risk of air pollution. Forest projections, as detailed in the Analysis 

Framework and the Oil and Gas Resource Section, detail a slight increase under this alternative. 

Air analysis will occur when a development proposal is received by the Forest Service as part of 

the NEPA analysis. 

Based on the projected land management activities under the alternatives, atmospheric 

emissions within roadless areas are not anticipated to directly, indirectly, or cumulatively 

increase to a level that would be likely to exceed state or federal air quality standards. This is 

because the amount and geographic extent of impacts from dust particulate, volatile organic 

compounds, and other emissions from projected activities in roadless areas would be relatively 

low, localized, and of short duration. They would not likely accumulate in the lower 

atmosphere in significant concentrations or linger for long periods of time. In addition, those 

infrequent or short-duration emissions would not likely create visibility impairment or public 

health hazards in high-sensitivity areas such as schools, hospitals, airports, or residential areas. 

Differences in effects on air quality do not substantially differ among alternatives because there 

is little difference in the amount, scale, and type of activities that could create air pollution

among alternatives. All alternatives are expected to have minimal impact to air quality.

Soil, Water & Air Resources: Cumulative Effects

Cumulative effects on soil, water and air resources within roadless areas considers the effects 

from past, ongoing and reasonably foreseeable future activities that could, when combined with 

effects described for each alternative, create impacts that are judged to be detrimental or 

beneficial. This includes the activities and effects listed in Appendix E. The primary activities 

that could affect these resources in roadless areas include the existing roads and road uses; treecutting; livestock grazing; fire and fuels treatment; oil, gas and coal development; and 

recreation activity. All alternatives project a minimal amount of annual tree-cutting and road 

construction that are limited to a relatively few areas. Uses adjacent to roadless areas can have 

an effect as well as natural events including wildland fires, floods, windstorms, and insect and 

disease outbreaks. 

There is a wide body of knowledge about the effects of logging and forest roads on soil erosion.

Those studies indicate that ―... most erosion occurring on timber harvest areas was due to large 

mass wasting events found on a small fraction of the harvest sites (Rice and Lewis 1991). 

Researchers acknowledge that only a few of the logging or road construction sites accounted for 

most of the erosion, and avoiding or mitigating impacts on steep slopes and other erosive sites 

is key to reducing erosion on a cumulative basis. Studies find that repeated entry onto the same 

site for harvest can lead to detrimental loss of topsoil or excessive compaction and 

displacement. The Forest Service avoids activities on high erosion hazard soils, mitigates 

activities and generally does not re-enter forested stands for 20 years or more, thereby 

minimizing the potential for cumulative compaction or displacement. Considering the relatively 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—161

limited extent, magnitude, and duration of potential soil quality impacts under any of the 

alternatives with the project‘s mitigation measures, ground-disturbing activities are not likely to 

create any significant adverse impacts on the soil resource.

Water yield within roadless area watersheds is not anticipated to change as a result of any of the 

alternatives analyzed in this EIS; there would be no cumulative effect on water yield. Natural 

events including the large insect-disease outbreaks and wildland fires that cause tree mortality 

would continue to contribute to alterations in water yield in the affected watersheds. The 

potential for cumulative effects on water quality is based primarily on the amount of activity 

projected to occur. The direct and indirect effects on water quality from projected activities in 

roadless areas are unlikely to be detected beyond the sub-watershed scale because BMPs and 

other mitigation measures are used to mitigate effects. Downstream changes in water quality at 

the watershed scale would be more likely to result from activities downstream outside the 

roadless areas than from activities within the roadless areas. Alternative 1 would have the least 

potential for cumulative effects at the watershed scale, and alternative 3 would have the 

greatest potential, because of differences in the magnitude and extent of activities allowed in 

roadless areas under each alternative. The contributions from activities associated with the 

alternatives would not result in any significant cumulative effect when added to the water 

quality impacts from other past, ongoing, or foreseeable future activities in the same roadless 

area watersheds. 

The anticipated continued increases in population growth and associated human developments 

in Colorado would affect soil, water, and air quality in the watersheds and airsheds that overlap 

roadless areas. The demand is increasing for greater amounts of high-quality water for 

municipal, agricultural, and other purposes. Coupled with the increased demand for water 

supplies is an increased demand for water storage and conveyance facilities. Roadless areas 

located high in watersheds are attractive for future new development or expansion of existing 

facilities to take advantage of low evaporation rates and gravity distribution. As the population 

growth increases, the demand for raw materials—including timber, minerals, oil, gas and coal—

and for recreational and residential opportunities also goes up, increasing the potential for 

adverse effects on soil, water and air quality by creating land use changes and disturbances.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

162—Chapter 3. Affected Environment and Environmental Consequences

GEOLOGICAL AND PALEONTOLOGICAL RESOURCES

Geological Resources: Introduction

Geologic processes such as landslides, earthquakes, or volcanic hazards, and naturally 

occurring hazards such as asbestos-bearing rock, affect peoples‘ lives. To manage these safety 

hazards, the Forest Service can control or restrict uses in these areas. To enhance public 

understanding and appreciation of geological special interest areas, the Forest Service may 

develop interpretive sites to highlight examples of unique or interesting geology.

Geological Resources: Affected Environment

Karst and cave resources most commonly occur on areas underlain by limestone or marble.

Some of the values associated with karst and cave resources are their ability to store and 

transmit groundwater, their importance as subterranean wildlife habitats, their importance as 

cultural resource or paleontological sites, and their ability to provide interpretive sites or 

recreational opportunities for spelunkers or cavers. They can also present hazards, such as 

sinkholes, to resource use and development.

NFS lands are available for collecting rocks and minerals under its 36 CFR 228 mineral 

regulations, except on lands withdrawn to prohibit these activities.

Paleontological Resources: Introduction

On March 30, 2009, Congress passed the Omnibus Public Land Management Act of 2009. Title 

VI, subtitle D of this act is titled Paleontological Resources Preservation. It states that ―The 

Secretary shall manage and protect paleontological resources on Federal land using scientific 

principles and expertise. The Secretary shall develop appropriate plans for inventory, 

monitoring, and the scientific and educational use of paleontological resources ...‖ 

Paleontological resources are recognized as important both for their scientific and natural 

resource values, and in terms of the active protection required in their management. Preexisting policies regulate the collection and disposition of significant fossils until actual 

regulations are written for the management and protection of these resources. Vertebrate fossils 

are always considered significant whereas invertebrate or plant fossils generally are not unless 

they are of unusual rarity or quality. The Paleontological Resources Preservation Act (PRPA) 

allows the casual collection without a permit of common invertebrate and plant fossils for 

personal use and enjoyment. All other collection of fossils from NFS requires a permit. 

Paleontological Resources: Affected Environment

The Forest Service uses a Potential Fossil Yield Classification (PFYC) system to assist the 

management of fossil resources. PFYC is a planning tool wherein geological units, usually at the 

rock formation or member level, are classified according to the probability of yielding 

paleontological resources that are of concern to land managers. There are five potential levels 

ranging from not likely to contain recognizable fossil remains (Class 1) to highly fossiliferous 

geologic units at low risk of degradation (Class 4) or at high risk of degradation (Class 5).

Forest Service data show highly fossiliferous Class 5 rock units in Colorado‘s roadless areas.

(Class 4 units are not identified on a regional scale). While it is not possible to predict where 

significant fossils occur, the existence of Class 5 rock units within a given roadless area is an 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—163

indicator of the potential for significant fossils to occur.

Based on Forest Service PFYC data created in 2006, within the analysis area, Inventoried 

Roadless Areas (IRA) and Colorado Roadless Areas (CRA), contain an estimated 1,332,800 acres 

of Class 5 rock units. Thus, 32% of the approximately 4,135,000 total acres of Class 5 rock units 

on National Forest System land in Colorado occur within lands subject to this analysis. The IRA 

acres under alternative 1 and 3 contain approximately 29% of the approximately 4,135,000 total 

acres. The CRA acres in alternatives 2 and 4 also contain approximately 29% of the 

approximately 4,135,000 total acres but within a slightly different area than alternative 1.

Nearly two thirds of the affected PFYC Class 5 lands occur on just two of the Forests (GMUG 

with 433,240 acres and White River with 381, 315 acres). Most of the changes between the IRA 

acres of Class 5 rock units and the CRA acres of Class 5 rock units occur on three Forests, the 

GMUG loses 15,860 Class 5 acres that are within the IRAs but not within the CRAs but the San 

Juan and Pike San Isabel gain 15, 470 Class 5 acres within the CRAs that were not within the 

IRAs.

Geological and Paleontological Resources: Environmental

Consequences

All Alternatives

Management of the geologic and paleontological resources described in the Affected 

Environment section of this document does not require road construction or tree-cutting to 

implement, and therefore, are not predicted to result in any new road construction or 

reconstruction in roadless areas under any alternative. Accordingly, effects under any of the 

alternatives are expected to be the same.

For geological hazards, the construction of roads most likely would have negative effects.

Although we avoid unstable sites, roads can lead to more landslides than would occur 

naturally. Tree-cutting practices can also lead to more landslides if done improperly. Also, 

roads constructed across rock formations containing naturally occurring hazardous material, 

such as asbestos rock, would expose the public to this hazardous material. 

For paleontological resources, road construction can have both positive and negative impacts.

Roads constructed across highly fossiliferous rock units would have the potential to damage 

significant fossils. On the other hand, road construction could lead to the finding of significant 

fossil resources that otherwise would not have been discovered. Roads can also help facilitate 

the permitted collection and removal of fossil resources that can weigh hundreds of pounds, 

which are not easily removed by backpacking. In isolated areas, large vertebrate fossils eroding 

from the bedrock may go unfound, or if found, left to continued natural destruction through 

erosion as collection would be difficult without some form of vehicular access.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

164—Chapter 3. Affected Environment and Environmental Consequences

THREATENED, ENDANGERED, AND SENSITIVE PLANTS

Roadless areas generally contain natural landscapes that provide habitat for some of the rarest 

elements of the Colorado flora. This analysis evaluates the known or likely occurrences of 

threatened, endangered, candidate, and sensitive species and their overlap with roadless areas.

This analysis also examines the potential environmental consequences of the prohibitions and 

exceptions described elsewhere in this document. Separate sections of the EIS cover threatened 

and endangered (T&E) and sensitive fish and wildlife, and their habitats.

Threatened, Endangered, and Sensitive Plants: Affected Environment

Taken as a whole, T&E and sensitive plants in Colorado occur in a wide variety of habitats, 

ranging from aspen forests or piñon-juniper woodlands to wetlands or alpine tundra. Within 

these broad habitat types, T&E and sensitive plants are typically restricted to small areas having 

specific combinations of soil type, moisture regime, elevation range, and plant communities, 

among other factors. Some species (called endemic) grow nowhere else in the world except 

Colorado, where they may be restricted to a single mountain range, or even a single peak. Other 

plant species are rare in Colorado because they are at the edge of their geographic range, or are 

disjunct from their main area of distribution.

Nothing specific about habitat conditions within roadless areas makes them more likely to 

harbor T&E and sensitive plants than places outside roadless areas. However, because roadless 

areas are generally less altered by human activities compared to more intensively managed 

lands, T&E and sensitive plants in roadless areas are less likely to have been adversely affected 

by management activities or recreational pursuits enabled by roads. These areas may also have 

lower threats from invasive non-native plants.

Climate change can be expected to alter the distribution of plants and other species (Hansen et 

al. 2001; Intergovernmental Panel on Climate Change 2007). Some species will be more 

vulnerable to the effects of climate change than others (Millar et al. 2007). Alpine plants may be 

among those in the most precarious situations because they already exist at high elevations with 

little higher terrain available for them to migrate to; some are already on the highest peaks in 

Colorado and are isolated from other potentially suitable habitat. Pollinators may be more 

capable of migrating but may leave some plant species behind and become unable to produce 

viable seeds. Some of these changes are unlikely to occur to a measurable extent over the next 

15 years, but other changes have already been documented. For example, earlier snowmelt near 

Crested Butte, Colorado, has been found to result in earlier flowering of some subalpine plants 

(Inouye 2008). The earlier flowering dates subject these plants to frost, which results in 

significantly lower seed production. This reduced seed production can lead to in turn changes 

in plant community composition, which may alter habitat suitability for some plants and their 

pollinators. Additionally, changes in land use challenge the ability of plants to adapt to climate 

change (USDA Global Climate Change Office 2001).

Threatened, Endangered, and Proposed Species

This section discusses the plant species listed or proposed for listing under the Endangered 

Species Act (ESA) by the U.S. Fish and Wildlife Service. One plant species listed as threatened 

(U.S. Fish and Wildlife Service 1993) is known to occur within roadless areas: Penland‘s eutrema 

(Eutrema penlandii); see Table 3-27. No other plant species listed under the ESA are known or are 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—165

likely to occur in roadless areas in Colorado.

One plant species, which has been formally proposed for listing under the ESA (USDI Fish and 

Wildlife Service 2010), is known to occur in a roadless area: Debeque phacelia (Phacelia scopulina 

var. submutica); see Table 3-27. Proposed species are afforded some protection under the ESA.

This is the only plant species proposed for listing under the ESA that is known or is likely to 

occur in roadless areas in Colorado.

Two other plants listed under the ESA were previously thought to occur in roadless areas: Uinta 

Basin hookless cactus (Sclerocactus glaucus, also known as Colorado hookless cactus), a 

threatened plant, and Kremling milkvetch (Astragalus osterhoutii), an endangered plant. Current 

information shows that neither of these plants occurs within roadless areas.

Table 3-27. Occurrence of threatened and endangered plant species within roadless areas (IRAs 

or CRAs)

Species – common name,

scientific name (ESA Status) Habitat description

Roadless areas with 

T&E species occurrence

Penland’s eutrema

Eutrema penlandii (threatened)

Rooted in mosses on stream banks and in 

wetlands that remain wet all season in the 

alpine at elevations of 12,300 to 13,100 feet

Hoosier Ridge CRA and 

Silverheels IRA/ 

Silverheels CRA

Debeque phacelia

Phacelia scopulina var. 

submutica (proposed)

Sparsely vegetated, steep slopes; on expansive 

clays derived from the Atwell Gulch or Shire 

members of the Wasatch Formation at 

elevations of 4,700 to 6,200 feet.

Battlement Mesa IRA, not 

included in any CRA

Habitat for Penland‘s eutrema is treeless and narrowly restricted to the Mosquito Range, where 

the plant lives in alpine seeps on soils that remain wet year-round. For all of the alternatives, 

projections of foreseeable activities in roadless areas indicate that there is no likely potential for 

oil, gas, or coal development, new roads, linear construction zones or tree-cutting activities in 

the Penland‘s eutrema habitat found within roadless areas (IRAs or CRAs). 

Debeque phacelia is a tiny annual plant with habitat restricted to a small area in Garfield and 

Mesa counties in Colorado. The plant occurs on sparsely vegetated, steep slopes on clays 

derived from the Wasatch Formation, which have a high shrink-swell potential, and often have 

large cracks on the surface when dry. For all of the alternatives, projections of foreseeable 

activities in roadless areas indicate that there is no likely potential for oil, gas, or coal

development, new roads, linear construction zones, or tree-cutting activities in the Debeque 

phacelia habitat found within roadless areas (IRAs or CRAs).

Consultation with the U.S. Fish and Wildlife Service, in accordance with section seven of the 

ESA, has been initiated and will be ongoing during this proposed rulemaking action. As part of 

the section seven process, the estimated effects on federally listed plants from the preferred 

alternative will subsequently be documented in a biological assessment and submitted to the 

U.S. Fish and Wildlife Service for consultation, once a preferred alternative has been clearly 

identified (between the draft and final EIS).

Forest Service Sensitive Species

Forest Service sensitive species are those designated by a Regional Forester for which 

population viability is a concern (Forest Service Manual 2670.5). All roadless areas in Colorado 

are within the Forest Service‘s Rocky Mountain Region except the Roc Creek Roadless Area, 

which is in the Intermountain Region. No Intermountain Region sensitive plants are known or 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

166—Chapter 3. Affected Environment and Environmental Consequences

are likely to occur within the Roc Creek Roadless Area (Franklin 2008; Hubbard 2008; Smith 

2008), and no Rocky Mountain Region sensitive plants are known to be or are likely to be found 

in that area. Therefore, this analysis includes only those sensitive plant species listed in exhibit 

one of the Rocky Mountain Region‘s 2009 supplement to the Forest Service Manual 2672.11(4).

Forest Service sensitive species have special conservation status and protection requirements. 

Forest Service objectives for sensitive species include: (1) ensure that sensitive species do not 

become endangered or threatened by Forest Service actions; (2) maintain viable populations 

distributed throughout the species‘ geographic range on National Forest System (NFS) lands; 

(3) implement management objectives for populations and/or habitat; (4) develop and 

implement conservation strategies; and (5) coordinate management with state and federal 

agencies, tribes, and other cooperators (FSM 2670 and the Region 2 supplement to FSM 2670). 

The list of sensitive plant species includes consideration of plants that are ―candidate‖ species 

for listing under the ESA.

Inventories of sensitive plant species on NFS lands in Colorado are incomplete, especially in 

roadless areas. Per the data that is available, there are 43 sensitive plant species known or are 

likely to occur in the roadless areas in Colorado (Table 3-28). This estimate was based on 

analysis of spatial GIS map data and species occurrence information, using data from the 

Colorado Natural Heritage Program and information from the national forests. Less than one 

third of the existing roadless areas and about one fourth of Colorado Roadless Areas are known 

or are likely to support sensitive plants. Sensitive plant species that are not known or are not 

likely to occur in any roadless areas were eliminated from further analysis in this EIS.

Table 3-28 provides a list of sensitive plant species within the roadless areas, grouped by 

general habitats. The assignment of species to general habitats was primarily based on 

descriptions for each plant contained in the Colorado Rare Plant Field Guide (Spackman et al. 

1997) and conservation assessments produced by the Forest Service (available 2010 online at: 

http://www.fs.fed.us/r2/projects/scp/assessments). Because the general habitat categories 

used for these groups are not exclusive, it is important to note that some plants could be placed 

in more than one category. For example, plants that occur in alpine wetlands could be placed 

under either the alpine group or wetlands group. Some species may occur naturally in more 

than one type of habitat. Nevertheless, these general categories provide a broad overview of the 

range of habitats that support sensitive plants in roadless areas, and the relative distribution of 

species among these habitats. The wetlands and high-elevation alpine habitats in roadless areas 

contain the widest variety of sensitive plant species.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—167

Table 3-28. List and distribution of sensitive species by habitat groups within roadless areas

Habitat group Scientific name Common name

Alpine or subalpine Aliciella sedifolia* stonecrop gilia

Armeria maritima ssp. sibirica Siberian sea thrift

Braya glabella ssp. glabella smooth northern-rockcress

Draba exunguiculata* clawless draba

Draba grayana* Gray's draba

Draba smithii* Smith's draba

Festuca hallii plains rough fescue

Oreoxis humilis* Rocky Mountain alpineparsley

Parnassia kotzebuei Kotzebue's grass of Parnassus

Ranunculus karelinii ice cold buttercup

Wetlands, seeps, or wet areas Aquilegia chrysantha var. rydbergii Rydberg's golden columbine

Carex diandra lesser panicled sedge

Carex livida livid sedge

Drosera anglica English sundew

Drosera rotundifolia roundleaf sundew

Eriophorum altaicum var. neogaeum whitebristle cottongrass

Eriophorum chamissonis Chamisso's cottongrass

Eriophorum gracile slender cottongrass

Mimulus gemmiparus* Rocky Mountain monkeyflower

Primula egaliksensis Greenland primrose

Ptilagrostis porteri* Porter's false needlegrass

Rubus arcticus ssp. acaulis dwarf raspberry

Salix candida sageleaf willow

Salix serissima autumn willow

Sphagnum angustifolium sphagnum

Utricularia minor lesser bladderwort

Meadows or open areas Botrychium lineare narrowleaf grapefern

Botrychium tax. nov. "furcatum"* fork-leaved moonwort

Ipomopsis aggregata ssp. weberi scarlet gilia

Aspen or conifer forests Astragalus ripleyi Ripley's milkvetch

Cypripedium parviflorum lesser yellow lady's slipper

Penstemon degeneri* Degener's beardtongue

Potentilla rupincola* rock cinquefoil

Viola selkirkii Selkirk's violet

Piñon-juniper or shrublands Astragalus proximus Aztec milkvetch

Astragalus wetherillii Wetherill's milkvetch

Penstemon harringtonii* Harrington's beardtongue

Shale/clay barrens or other 

sparsely vegetated areas

Astragalus missouriensis var. humistratus* Missouri milkvetch

Cirsium perplexans* Rocky Mountain thistle

Lesquerella pruinosa Pagosa Springs bladderpod

Machaeranthera coloradoensis Colorado tansyaster

Neoparrya lithophila* Bill's neoparrya

Thalictrum heliophilum* Cathedral Bluff meadow-rue

* Endemic plants, occurring only in Colorado.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

168—Chapter 3. Affected Environment and Environmental Consequences

Fifteen of the sensitive plant species that are known or are likely to occur in roadless areas (IRAs 

or CRAs) are considered endemic because they occur only in Colorado28. Endemic species may 

be at higher risk of extinction due to their small number of populations and very limited 

geographic range.

Populations of one sensitive plant species occur in portions of IRAs (in alternatives 1 and 3) that 

are not included in CRAs (in alternatives 2 and 4):

plains rough fescue (Festuca hallii)

Three sensitive plant species occur in portions of CRAs (in alternatives 2 and 4) that are not 

included in IRAs (in alternatives 1 and 3). The first is endemic to Colorado:

Rocky Mountain monkeyflower (Mimulus gemmiparus)

Rydberg's golden columbine (Aquilegia chrysantha var. rydbergii)

Greenland primrose (Primula egaliksensis)

Forest Service Manual direction requires that potential adverse impacts to sensitive species be 

avoided or minimized to a point that they do not result in a loss of viability or create significant 

trends toward federal listing (FSM 2070.32, item #4). Management actions, such as road 

construction or tree-cutting, typically include mitigation measures that adjust locations of these 

activities to avoid populations of sensitive plants. However, agency manual direction does 

provide discretion to the line officer making the project-level decision to allow adverse impacts 

to sensitive species, provided that the decision does not result in loss of species viability or 

create significant trends toward federal listing of the species under the ESA.

In addition to policies that require actions to avoid or minimize harm to sensitive plants, 

projects may also be designed to have beneficial effects for sensitive plant populations. For 

example, projects implemented in roadless areas for forest health, fuel reduction, or other 

purposes could be designed to correct poor road alignment or existing soil erosion impacts on 

sensitive plants, or to reduce the risk of a high-severity wildfire that might eliminate a sensitive 

plant population and its seed bank. Thus, some management actions in roadless areas could 

benefit sensitive plants over the long term, even if there are short-term adverse impacts.

Of the 43 sensitive plant species known or likely to occur in roadless areas, five sensitive plant 

species grow in forest habitats (the aspen/conifer habitat group listed in Table 3-28) that might 

benefit from tree-cutting to reduce the risk of severe stand-replacing wildfires. It is possible that 

other sensitive plants may also benefit from reduced risk of severe wildfires, because wildfires 

could spread into or otherwise adversely affect other habitat groups as well. However, 

depending on where and how equipment is brought on-site for fuel reduction projects, there 

also could be increased risk of adverse impacts on sensitive plant species (for example, 

temporary road construction or skidder operations across shrublands or open areas near forest 

habitats). Similarly, road construction for oil and gas exploration or development could increase 

the risk to sensitive plants.

 

28 Aliciella sedifolia, Astragalus missouriensis var. humistratus, Botrychium tax. nov. "furcatum", Cirsium 

perplexans, Draba exunguiculata, Draba grayana, Draba smithii, Mimulus gemmiparus, Neoparrya lithophila, 

Oreoxis humilis, Penstemon degeneri, Penstemon harringtonii, Potentilla rupincola, Ptilagrostis porteri, Thalictrum

heliophilum.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—169

Threatened, Endangered, and Sensitive Plants: Environmental 

Consequences

All Alternatives

As mentioned in the Affected Environment section, there would be no adverse impacts to 

threatened, endangered, or sensitive plants in IRAs or CRAs from road construction or 

reconstruction, tree-cutting and removal activities, linear construction zones, or oil, gas or coal

development activities because none of these activities is projected to occur in any roadless 

areas where federally listed or proposed plants occur under any of the alternatives. For all of 

the alternatives, there are no projected activities that would occur in the IRAs/CRAs where 

Penland‘s eutrema and Debeque phacelia are found. Potential direct impacts on T&E or 

sensitive plants from future projects not foreseen in this analysis would be minimized by 

avoiding such plant populations through site-specific project analysis and design.

Under all of the alternatives, there is some risk of indirect impacts on federally listed or 

proposed plants from the spread of invasive non-native plants. The spread of invasive nonnative plants could increase as a result of road construction or reconstruction, tree-cutting and 

removal activities, linear construction zones, or oil, gas and coal development activities. Some 

invasive plants can spread from more distant activity areas (inside or outside of roadless areas) 

into habitat for threatened, endangered, or sensitive plants.

The potential risk of direct adverse impacts on sensitive plants under each alternative depends 

on whether those activities may occur within the specific areas where sensitive plant species 

occur. Such activities are assumed not to pose a risk in IRAs or CRAs where sensitive plants are 

not known or likely to occur. For each alternative, the potential risk of adverse effects on 

sensitive plants is tied to the differences in the likelihood of projected road construction, treecutting, linear construction zones, and oil, gas or coal development. These activities would pose 

some risk of injuring or killing sensitive plants, as well as indirectly rendering the habitat

unsuitable or promoting invasion by non-native plants. It is also assumed that there would be 

some risk of adverse impacts on sensitive plants related to inadvertent mistakes made during 

project implementation, the potential spreading of invasive plants, or other unintended 

consequences from management activities projected to occur over the next 15 years.

The spread of invasive plants may be an indirect effect of projected activities, which could 

adversely impact sensitive plants. The abundance and distribution of invasive, non-native 

plants would likely increase over time as a result of road construction, tree-cutting activities, 

linear construction zones, or oil, gas and coal development. This is because increased ground 

disturbance is known to enable expansion of existing infestations and because new populations 

could become established from seeds or root fragments carried by vehicles and heavy 

equipment operating on or off roads. Sensitive plants would be more likely than T&E or 

proposed plants to be affected by the spread of invasive non-native plants because there are 

more habitats in roadless areas for sensitive plants than for T&E or proposed plants. Some of 

the potential indirect impacts from invasive plants would be mitigated by implementation of 

the Forest Service‘s weed management and prevention programs (see Invasive Species section). 

However, over time, weeds could spread from activity areas into sensitive plant habitat, even if 

the activities are conducted at some distance from these habitats.

Authorized activities are designed and conducted to avoid habitat containing sensitive plant 

species when practical, or to at least avoid a loss of population viability over the species‘ 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

170—Chapter 3. Affected Environment and Environmental Consequences

geographic range (as described in the Affected Environment section). Nevertheless, under any 

alternative, there would be some level of risk of accidental damage to sensitive plants or their 

habitats during project implementation, or of indirect impacts from increases in invasive plant 

populations.

There would be low potential for beneficial effects on sensitive plants from by allowing 

management activities in roadless areas associated with improving ecosystem conditions. The 

projected activities under any of the four alternatives would not likely be of sufficient 

magnitude to measurably reduce soil erosion or the risk of severe wildfires within sensitive 

plant habitat.

Alternative 1 – 2001 Roadless Rule

Threatened and Endangered Species

Under this alternative, no projected activities occur in any IRA where federally listed or 

proposed plants occur. As discussed in the Environmental Consequences section for all 

alternatives, there is some risk of indirect impacts on federally listed or proposed plants from 

the spread of invasive non-native plants. The risk under alternative 1 is the lowest of the four 

alternatives because of the tighter restrictions on new road construction and other activities in 

the IRAs compared to the standard tier of 2 and 4. Continued management under alternative 1 

could benefit T&E or proposed plants because it restricts or limits new road construction and 

other management activities within IRAs.

Sensitive Species

Various types of activities are projected to be likely under provisions of the 2001 Rule in 

approximately 25% of the 101 IRAs where sensitive plants are known or are likely to occur (see 

Appendix D regarding projections). Under alternative 1, sensitive plants in the balance of the 

analysis area (outside of IRAs) would be managed under existing forest plans. This would 

include 19 locations in the newly identified roadless acres that are not within IRAs, some of 

which have projected activities.

The overall risk of adverse impacts on sensitive plants from management activities in roadless 

areas would be lower under alternative 1 compared to the other alternatives because of the 

lower number of management activities projected to occur in the IRAs that are known or are 

likely to support sensitive plants. Because of the lower projections of activities, alternative 1 

would result in less risk of adverse effects to sensitive plants from invasive plants than would 

be expected under alternatives 2, 3, or 4.

Overall, alternative 1 may adversely affect individual sensitive plants but it is not likely to result 

in a loss of viability for sensitive plant species on any national forest in Colorado, nor cause a 

trend toward federal listing for the sensitive plant species analyzed in this document. The 

programmatic biological evaluation in the EIS record will contain additional details about the 

potential effects on sensitive species, in accordance with policy requirements in FSM 2670.32.

Alternative 2 – Colorado Roadless Rule (Proposed Action)

Threatened and Endangered Species

Under this alternative, no projected activities would occur in any CRA where federally listed or 

proposed plants are found. As discussed in the Environmental Consequences section for all 

alternatives, there is some risk of indirect impacts on federally listed plants from the spread of 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—171

invasive non-native plants. The risk is higher under alternative 2 than alternatives 1 and 4 but 

lower than alternative 3 because of the amount of projected activities. Continued management 

under alternative 2 could benefit threatened or proposed plants more than alternative 3 because 

it restricts or limits new road construction, linear construction zones, and other management 

activities within CRAs, in general as well as on the upper tier acres.

Sensitive Species

The risk to sensitive plants would be higher under alternative 2 than alternative 1. Under this 

alternative, more of the roadless areas that contain sensitive plants are projected to have 

activities in them. Sensitive plants in the balance of the analysis area (outside of CRAs) would 

be managed under existing forest plans. This would include 15 areas that would no longer be 

managed as IRAs, more than half of which are projected to have activities like tree-cutting

and/or road construction over the next 15 years. Therefore, the risk of adverse impacts on 

sensitive plants would be higher under alternative 2 than under alternative 1.

Indirect adverse impacts on sensitive plants from the expected spread of invasive non-native 

plants would be similar to the impacts described for alternative 1. However, there would be a 

higher potential for such impacts under alternative 2 due to the greater number of projected 

activities over the next 15 years in the CRAs where sensitive plants are known or likely to occur.

Compared to alternative 1, the projected hazardous fuels treatments in CRAs under alternative 

2 would have a better chance of reducing the potential for high severity wildfires to eliminate a 

sensitive plant population and its seed bank. However, only about five of the 43 sensitive plant 

species in roadless areas are found in forests or similar habitats that would benefit from 

projected activities intended to reduce the risk of severe wildfires. The great majority of 

sensitive plant species in roadless areas would not benefit from projected activities intended to 

reduce fire hazards.

Overall, alternative 2 may adversely affect individual sensitive plants but is not likely to result 

in a loss of viability for sensitive plant species on any national forest in Colorado or cause a 

trend toward federal listing for the sensitive plant species analyzed in this document. The 

programmatic biological evaluation in the EIS record will contain additional details about the 

potential effects to sensitive species, in accordance with policy requirements in FSM 2670.32.

Alternative 3 – Forest Plans (No Action)

Threatened and Endangered Species

Under alternative 3, no projected activities would occur in any IRA where federally listed or 

proposed plants are found. As discussed in the Environmental Consequences section for all 

alternatives, there is some risk of indirect impacts on federally listed plants from the spread of 

invasive non-native plants. This risk is the highest of the four alternatives because the 

management under the forest plans is generally not as restrictive as the other three alternatives.

Sensitive Species

The effects on sensitive plants under alternative 3 would be essentially the same as those 

described for alternative 2. This is because under alternative 3, one third of the analysis area 

(IRAs and the balance of CRA acreage likely to support sensitive plants) is projected to include 

road construction, tree-cutting, linear construction zones, or oil, gas, or coal development 

activities under forest plans over the next 15 years. The estimated percentage of the analysis 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

172—Chapter 3. Affected Environment and Environmental Consequences

area supporting sensitive plants likely to experience the same types of projected activities under 

alternative 3 is virtually the same as alternative 2, with the indirect effects similar to those under 

alternative 2. The difference between alternatives 2 and 3 is probably not meaningful in terms of 

risk to rare plants. The risk is higher than under alternative 1.

The potential for beneficial effects to sensitive plants would be the same as described for 

alternative 2 and would affect only a small percentage of the habitats where sensitive plants are 

known or likely to occur in roadless areas. Most sensitive plants in IRAs do not occur in habitats 

where tree-cutting would reduce wildfire hazard.

Overall, alternative 3 may adversely affect individual sensitive plants but is not likely to result 

in a loss of viability for sensitive plant species on any national forest in Colorado or cause a 

trend toward federal listing for the sensitive plant species analyzed in this document. The 

programmatic biological evaluation in the EIS record will contain additional details about the 

potential effects on sensitive species, in accordance with policy requirements in FSM 2670.32.

Alternative 4 – Colorado Roadless Rule with Public Proposed Upper Tier

Threatened and Endangered Species

No projected activities occur in any CRA where federally listed or proposed plants occur under 

this alternative. As discussed in the Environmental Consequences section for all alternatives, 

there is some risk of indirect impacts on federally listed plants from the spread of invasive nonnative plants. The risk is higher than alternative 1 but lower than alternatives 2 or 3 because of 

the projected activities. Continued management under alternative 4 could benefit threatened or 

proposed plants because it restricts or limits new road construction, linear construction zones,

and other management activities within CRAs in general as well as on the upper tier acres.

Sensitive Species

The risk to sensitive plants would be lower under alternative 4 than alternatives 2 or 3 but 

greater than alternative 1. Due to the greater number of upper tier acres under this alternative 

than alternative 2, there are fewer projected activities. Sensitive plants in the balance of the 

analysis area (outside of CRAs) would be managed under existing forest plans. This would 

include 15 areas which would no longer be managed as IRAs, more than half of which are 

projected to have activities like tree-cutting and/or road construction over the next 15 years.

Indirect adverse impacts on sensitive plants from the expected spread of invasive non-native 

plants would be similar to the impacts described for alternative 1. However, there would be a 

higher potential for such impacts under alternative 4 due to the greater number of projected 

activities over the next 15 years in the CRAs where sensitive plants are known or likely to occur.

Compared to alternative 1, the projected hazardous fuels treatments in CRAs under alternative 

4 would have a better chance of reducing the potential for wildfires to eliminate a sensitive 

plant population and its seed bank. However, only about five of the 43 sensitive plant species in 

roadless areas occur in forests or similar habitats that would benefit from projected activities 

intended to reduce the risk of severe wildfires. The great majority of sensitive plant species in 

roadless areas would not benefit from projected activities intended to reduce fire hazards.

Overall, alternative 4 may adversely affect individual sensitive plants but is not likely to result 

in a loss of viability for sensitive plant species on any national forest in Colorado or cause a 

trend toward federal listing for the sensitive plant species analyzed in this document. The 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—173

programmatic biological evaluation in the EIS record will contain additional details about the 

potential effects to sensitive species, in accordance with policy requirements in FSM 2670.32.

Environmental Consequences Summary

Table 3-29 displays the overall relative risks to T&E and sensitive plants associated with each of 

the alternatives, which reflects the previous narrative discussions. Although linear construction 

zones are limited in alternatives 2 and 4, their projected use is similar in all alternatives except 

for an increased use in alternative 3.

Table 3-29. Relative risk to rare plants under each alternative due to projected activities and 

associated threats from weed invasion or fragmentation

Activity or threat Relative risk to T&E plants Relative risk to sensitive plants

Coal development None anticipated None anticipated

Oil and gas development per se None anticipated None anticipated

Road construction None anticipated Alt 1 < Alt 4 <Alt 2 = Alt 3

Linear construction zones None anticipated Alt 1 = Alt 2 = Alt 4< Alt 3

Tree-cutting None anticipated Alt 1 < Alt 4 <Alt 2 = Alt 3

Invasive species Alt 1 < Alt 4 <Alt 2 = Alt 3 Alt 1 < Alt 4 <Alt 2 = Alt 3

Fragmentation* None anticipated Alt 1 < Alt 4 <Alt 2 = Alt 3

Abbreviations and symbols: Alt means “alternative”; < means “less than”; = means “essentially equal”.

* See discussion of fragmentation under Cumulative Effects.

Threatened, Endangered and Sensitive Plants: Cumulative Effects

There are a number of past, present and reasonably foreseeable programs, activities, or events 

in roadless areas and on lands of all ownerships immediately surrounding them that are likely 

to affect T&E and sensitive plants. These primarily include tree-cutting, livestock grazing, road 

work, oil, gas, or coal development, climate change, and land conversion (for example, home 

construction on private lands outside roadless areas). These actions may adversely affect T&E 

and sensitive plants, their habitats, or their pollinators, and may contribute to habitat

fragmentation for the plants or their pollinators. Some of these actions may also provide 

beneficial effects, such as mimicking natural disturbance regimes to which such plants are 

adapted, or controlling erosion. These activities and other activities considered for this 

cumulative effects analysis are described more fully in the cumulative effects in Appendix E.

Fragmentation of T&E or sensitive plant species‘ habitat can result from the combined effects of 

a wide array of ongoing, future, or past management actions in and around roadless areas. 

Habitat fragmentation has been cited frequently as a concern for wildlife, and its impact on 

plants can vary widely depending on the species‘ breeding system, capacity for migration, and 

other factors (Lienert 2004). Although some plant species are able to persist in very small 

populations over long periods of time, there is also evidence for the disruption of plant–

pollinator relationships in fragmented landscapes (Harris and Johnson 2004). The causes may 

include a lack of nesting sites for insect pollinators or reduced pollinator visits to small plant 

populations, which can lead to lower seed production, with subsequently reduced seedling 

recruitment and eventually smaller plant populations or local extirpation of populations. 

Habitat fragmentation can also affect plant populations through a loss of genetic diversity 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

174—Chapter 3. Affected Environment and Environmental Consequences

within populations (USDA Forest Service and University of California 2006).

The Rocky Mountain Region of the Forest Service generally updates its sensitive species list 

every two years to account for new information. During an update, species are considered for 

sensitive status based on factors ranging from geographic distribution and abundance, to 

population trend and life history characteristics. There are currently more than 100 plant species 

for which insufficient information has been available to determine whether or not designation 

as sensitive species by the regional forester is merited. Information will likely be collected and 

evaluated in order to resolve the status of these species over the next 15 years. It is reasonable to 

assume that some will warrant sensitive status, while others will not. Those designated 

sensitive during the next 15 years that are known or likely to occur within roadless areas would 

likely be addressed during project-level analysis.

The effects of all these past, present, and reasonably foreseeable activities, plus climate change, 

would likely combine with the effects previously described for each of the roadless rulemaking

alternatives to raise the risk to T&E or sensitive plants. These adverse cumulative effects cannot 

be quantitatively described in this programmatic evaluation. However, many human activities 

occurring in and adjacent to roadless areas would be likely to further (cumulatively) increase 

the risk of invasive plant spread or inadvertent impacts on T&E or sensitive plants in roadless 

areas. For example, continuing population growth and land development adjacent to roadless 

areas, plus recreation activities within roadless areas, taken together with increases in climatic 

extremes and warming trends, pose an increased risk of additive adverse impacts to T&E or 

sensitive plants in roadless areas. Based on the discussion of direct and indirect effects, the risk 

of adverse cumulative effects would be somewhat lower under alternative 1 because the total 

amount of ground-disturbing activity would be less under that alternative than under the other 

alternatives.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—175

AQUATIC SPECIES AND HABITAT

This analysis evaluates potential effects of the alternatives on aquatic (water-based) habitat and 

species. The aquatic species evaluated in this analysis include fish, aquatic macroinvertebrates 

(such as crayfish and insect larvae), and aquatic mammals (such as the American beaver)..

This analysis is organized to emphasize threatened and endangered species, Forest Service 

sensitive species, and management indicator species (MIS), and their associated habitats. This 

approach covers the full range of habitats potentially affected by differences among the 

alternatives analyzed in this EIS. The analysis focuses on the most significant differences in the 

potential for environmental consequences (effects) among the four roadless area management 

alternatives. 

Aquatic Species and Habitat: Affected Environment

The fishery resources and associated aquatic habitat in Colorado are a result of evolution, 

migration, climatic changes, and influences from non-native settlers. The Continental Divide 

forms a ―barrier‖ between fish migrations from the western United States and the Mississippi 

drainage to the east. Periodic changes in climate and topography have resulted in isolation, 

movement and subsequent evolution of the current native fish found in the State. There are a 

wide range of aquatic habitats and species in the roadless areas in Colorado, which range from 

approximately 3,000 to 14,000 feet in elevation. Relatively few fish species are able to survive 

the varying and often harsh conditions associated with the mountain streams in the higher 

elevations of the roadless areas in Colorado. This is due to reductions in temperature, stream

size, nutrient input and the ―growing season‖ in streams at higher elevations. Historically, 

native fish populations were greatest in the mid to large size streams in lower elevations in 

Colorado, with headwater streams containing relatively fewer fish populations. 

The results of historic logging practices in the Colorado Rockies have negatively influenced 

current aquatic habitat conditions (Allan 1995). However, past commercial timber harvesting in 

the roadless areas has been limited because of the lack of road access. Management activities 

have occurred more frequently and extensively in the lower elevations of the roadless areas in 

Colorado. Historic management activities in the larger rivers and lower elevation streams in 

Colorado included stocking of non-native fish species, mining, road construction, and other 

activities. De-watering of streams has resulted in a loss of habitat and native fish species, and it 

is unlikely that they can be restored to their pre-settlement condition (Behnke 2002). As a result 

of the numerous human activities along these larger, lower elevation streams, these areas are 

typically not considered for restoration efforts (USDI Fish and Wildlife Service 1998).

Historically, aquatic habitat quality was inversely proportional to elevation in the Colorado 

Rockies; however, the influence of human settlements and land uses has changed this 

relationship (Wohl 2001). The largest impacts on aquatic habitats have been occurring where 

streams are adjacent to human population centers, roads, and other human activities. 

Recreational and land management activities are generally concentrated at the lower to mid 

elevation portions of roadless areas that are more accessible (Winters et al. 2004). Therefore, 

while historically the highest quality aquatic habitats in Colorado would have occurred at the 

lower elevations, aquatic habitat has been degraded from proximity to human population 

centers, roads, and other activities that occur more frequently in the lower elevations. Higher 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

176—Chapter 3. Affected Environment and Environmental Consequences

elevations in Colorado provide the highest quality aquatic habitats for protection and 

restoration of native aquatic species and their habitat. 

Native fish species populations have declined from their historic levels on all national forests in 

Colorado, even those further from large population centers in part due to water developments, 

such as dams, and road crossings restricting movements (Winters and Staley 2008). 

Non-native fish species such as rainbow, brook, and brown trout have affected native trout 

populations in Colorado (Behnke 2002). Colder water temperatures limit the expansion of those 

non-native trout species into upper elevation streams in the roadless areas in Colorado (Vincent 

and Miller 1969), which is one reason why higher elevation roadless areas are often selected for 

native species reintroduction projects. These high-elevation streams may also serve as refugia if 

stream temperatures rise with climate change. Restrictions on road construction and treecutting may reduce fragmentation and sedimentation on high-elevation streams, conserving 

suitable habitat for native cold-water species under moderate climate change scenarios.

Managing for native fish species must be balanced with the high recreational and economic

value of non-native fish species. While fishing pressures have greatly contributed to the 

reduced range of native trout, roadless areas generally do not contain roads open to public 

vehicular use. Therefore, there is a reduced risk of over-fishing in roadless areas. 

This analysis examines the activities that are identified as part of the Roadless Rule alternatives 

for Colorado and their associated risks. Road construction, linear construction zones and treecutting activities are prohibited with few exceptions in three of the four alternatives. 

Threatened, Endangered and Sensitive Species

Threatened, endangered (T&E) and proposed species are evaluated in accordance with 

requirements set forth under Section 7 of the Endangered Species Act (ESA), in the Code of 

Federal Regulations (50 CFR 402), and in Forest Service Manual 2670.31-2672.42. The ESA 

―candidate‖ species are discussed as Forest Service sensitive species later in this section; they 

are automatically included on the regional list of sensitive species.

Based on ESA requirements, the Forest Service initiated informal consultation with the U.S. Fish 

and Wildlife Service on this proposed rulemaking action, and continued consultation 

throughout the development of rulemaking. 

The greenback cutthroat trout is federally listed as a threatened species that occurs in roadless 

areas. The yellow fin trout was historically found in the Arkansas River basin on the Pike-San 

Isabel National Forest, is presumed extinct, and will not be analyzed further in this analysis. 

There are no fish species identified as proposed under ESA, and there is no designated critical 

habitat for T&E fish in Colorado. 

Forest Service sensitive species are species identified by a Regional Forester for which 

population viability is a concern, as evidenced by significant current or predicted downward 

trends in population numbers or density, or in habitat capability that would reduce a species‘ 

existing distribution (Forest Service Manual 2670.5). The Forest Service policy for sensitive 

species is to conserve sensitive species so that they do not become T&E species and their 

habitats remain well distributed throughout their geographic range on NFS lands (Forest 

Service Manual 2670.22). The list of sensitive species includes federal candidate species. 

Table 3-30 lists the threatened and sensitive species that are likely to occur in roadless areas by 

national forest.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—177

Table 3-30. Threatened, endangered or sensitive fish species that occur or are likely to occur in 

roadless areas in Colorado

Common name Scientific name Major river 

drainage(s) National forest occupied Status(TES)

Greenback 

cutthroat trout

Oncorhynchus 

clarki stomias

Arkansas and

South Platte Arapaho-Roosevelt, Pike-San Isabel Threatened

Rio Grande

cutthroat trout

Oncorhynchus 

clarki virginalis Rio Grande Rio Grande Sensitive (+candidate)

Colorado River

cutthroat trout

Oncorhynchus 

clarki pleuriticus Colorado

Grand Mesa, Uncompahgre, 

Gunnison, Manti-La Sal, Routt, San 

Juan, White River

Sensitive

(+candidate)

Flannelmouth 

sucker

Catostomus 

latippinis Colorado Grand Mesa, Uncompahgre, Gunnison, San Juan, White River

Sensitive

(+candidate)

Bluehead sucker Catostomus 

discobolus Colorado Grand Mesa, Uncompahgre, Gunnison,, San Juan, White River Sensitive

Mountain sucker Catostomus 

platyrhynchus Colorado

Grand Mesa, Uncompahgre, 

Gunnison,, Routt, San Juan, White 

River

Sensitive

The three native trout species listed in Table 3-30 (one threatened and two sensitive) represent 

some of the very few fish that are historically found in high elevation portions of Colorado. 

These native cutthroat trout currently inhabit only a small fraction of their historic range. In the

past, most mountainous streams in Colorado that were not impeded by natural barriers and 

elevated stream temperatures harbored populations of native cutthroat (Behnke 2002). Through 

a variety of human influences, including stocking of non-native trout and habitat fragmentation

and reduction, these trout populations are now primarily limited to areas such as wilderness, 

roadless, national parks, and other relatively remote areas of the State. More recently, human 

activities have introduced invasive species, such as the whirling disease parasite, other diseases, 

and possibly mollusks, such as the New Zealand mud snail, which threaten the sustainability of 

native fisheries. In the less altered, higher elevation stream systems in roadless areas, the 

whirling disease parasite does not appear to be well established. 

Populations of all three native suckers that are listed as sensitive species appear to be declining. 

Bluehead and flannelmouth suckers generally tend to inhabit larger stream and river habitats, 

while mountain suckers are found sporadically throughout the western slope of Colorado in 

small streams. All three of these suckers are apparently being out-competed and hybridized by 

more common western white suckers (Catostomus commersoni) and longnose suckers (Catostomus 

catostomus) that have been introduced west of the Continental Divide. While scientists are only 

beginning to understand the exact mechanism for this replacement, it appears that competition, 

hybridization, habitat fragmentation and stocking have contributed to this problem. Although 

these fish have minimal recreational or human food value, they contribute to biodiversity and 

play an important ecological role in these aquatic ecosystems of Colorado. 

Other T&E Fish

In addition to T&E and sensitive fish species that may be directly influenced by the activities 

that vary by alternative in the roadless areas, there are four endangered fish species that occur 

downstream of NFS lands in the Colorado River and some of its larger tributaries that could be 

indirectly affected by those same activities in the roadless areas shown in Table 3-31. These 

residents of relatively large river systems have become increasingly rare, mostly due to 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

178—Chapter 3. Affected Environment and Environmental Consequences

dramatic changes in hydrology, water quality, and habitat conditions (Sublette et al. 1990). 

Water quantity changes on NFS lands in Colorado and other states have been closely monitored 

by the U.S. Fish and Wildlife Service to ensure any future development would not negatively 

affect these fish. Although these fish do not occur in rivers in Colorado, they could be affected 

by the combination of different activities that are likely to occur in the roadless areas that may 

affect their habitat conditions. In addition to the T&E species shown in Table 3-31, there are 

sensitive species and MIS of fish that also occur in some of the rivers downstream from the 

roadless areas. 

Table 3-31. Federally listed fish found downstream of the roadless areas in Colorado that could be 

influenced by upstream activities on NFS land

Common name Scientific name Federal status

Razorback sucker Xyrauchen texanus Endangered

Bonytail chub Gila elegans Endangered

Colorado pike minnow Ptychocheillus lucius Endangered

Humpback chub Gila cypha Endangered

Special Aquatic Habitats

There are aquatic habitats in many of the roadless areas in Colorado that have been identified as 

being ecologically important as well as ―rare.‖ In particular, fens (peat-forming wetlands) are 

considered irreplaceable, because they have taken thousands of years to form, and contain 

many unique forms of flora and fauna (Winters et al. 2004). Fens act as carbon sinks, are 

typically produced at the toes of slopes, and are often associated with high elevation glaciated 

valleys. Other wetlands are also important habitats for many species and have been reduced in 

Colorado by as much as 50 percent of their historic extent through numerous management 

activities (Dahl 1990). In some areas in Colorado, conversion of riparian forest and shrub

dominated ecosystems to unvegetated and grass dominated habitat has resulted in a loss of 

important habitat for a variety of plants and animals (Dahl et al. 1991). 

Management Indicator Species

MIS are species used as indicators of the effects of management activities on specific habitat

types or features and are identified in forest plans developed under the 1982 National Forest 

Management Act Planning Rule. Forest plans for the national forests in Colorado identify six 

MIS species of fish (trout), one mammal (American beaver), and an array of benthic (bottomdwelling) macroinvertebrates (such as insects, mollusks, or crayfish); see Table 3-32. While 

native species would be ideal to use as MIS, aquatic biologists are faced with several problems 

when attempting to use native species. These issues include the fact that most native species 

were eliminated from most of their original range; have very general ecological requirements; 

do not respond directly to management activities (e.g. western white suckers); are limited in 

their distribution; or are not well understood and may be considered a ―nuisance‖ in some 

situations (e.g. American beaver). For these reasons, non-native trout are often chosen as MIS in 

Colorado and meet the National Forest Management Act 1982 regulations. In addition to being 

well distributed and often well studied, non-native trout species represent an economic benefit 

to Colorado as an important game species. 

American beaver was previously discussed as an MIS in the Terrestrial Species and Habitat 

section due to the fact that it lives on both land and in water. It is a species that plays an 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—179

important ecological role and has a major influence on aquatic ecosystems and the species of 

plants and animals within them (Wohl 2001). Historically, beaver dams played an even more 

important role in reducing the effects of flooding and increasing the extent and quality of 

aquatic habitats. Today, as roads encroach on numerous stream systems, beavers are often 

perceived as a ―nuisance‖ as the water backed up from their dams spreads across floodplains 

and roads.

Table 3-32. Aquatic management indicator species for national forests in Colorado

Forest Common name Scientific name

Arapaho-Roosevelt brook trout Salvelinus fontinalis

brown trout Salmo trutta

greenback cutthroat trout Oncorhynchus clarki stomias

Colorado river cutthroat trout Oncorhynchus clarki pleuriticus

GMUG all trout (multiple species)

Manti-La Sal benthic macroinvertebrates (multiple species)

Pike-San Isabel brook trout Salvelinus fontinalis

greenback cutthroat trout Oncorhynchus clarki stomias

Rio Grande Rio Grande cutthroat trout Oncorhynchus clarki virginalis

brook trout Salvelinus fontinalis

brown trout Salmo trutta

rainbow trout Oncorhynchus gairdneri

Routt common trout (multiple species)

American beaver Castor canadensis

San Juan cutthroat trout (multiple species)

brook trout Salvelinus fontinalis

brown trout Salmo trutta

rainbow trout Oncorhynchus gairdneri

American beaver Castor canadensis

White River all trout (multiple species)

American beaver Castor canadensis

benthic macroinvertebrates (multiple species)

Population declines in MIS would be expected if there are limitations on the ability for 

populations to interact due to habitat fragmentation from roads and other activities. The MIS or 

sensitive species population viability would not be significantly affected on any of the national 

forests, assuming that appropriate mitigation and best management practices would be applied 

at the project level. 

Inventoried Roadless Areas and Colorado Roadless Areas

Table 3-33 shows the total perennial stream miles on each national forest unit in Colorado, 

along with the change in those stream miles that would be under roadless area protections in 

CRAs compared to IRAs. There is a net decrease of 57,600 acres in CRAs from IRAs. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

180—Chapter 3. Affected Environment and Environmental Consequences

Table 3-33. Change in stream miles in roadless areas between the IRA and CRA boundaries, 

for each national forest unit in Colorado

National forest Total stream miles in IRAs Total stream miles in CRAs Net difference

Arapaho-Roosevelt 493 470 -23

GMUG 1,473 1,106 -367

Manti-La Sal 13 12 -1

Pike-San Isabel 767 804 +37

Rio Grande 650 610 -40

Routt 733 725 -8

San Juan 716 722 +6

White River 910 901 -9

Total 5,756 5,350 -406

Source: Roadless Areas GIS database, May 2008

There are a high percentage of IRAs on some of the national forests containing T&E and 

sensitive species. This is particularly true for the Arapaho-Roosevelt; GMUG; Routt; San Juan; 

and White River National Forests. A relatively high percentage indicates these areas function as 

―strongholds‖ for native populations and/or are native trout reintroduction areas. There is a 

relatively low percentage of IRAs on the Pike-San Isabel and Rio Grande National Forests 

containing T&E and sensitive species. On the Pike-San Isabel this is mostly due to nearby large 

population centers and other land use activities that limit the ability to reestablish native 

greenback populations despite recovery efforts. On the Rio Grande this may be due to relatively 

less effort put into recovery of Rio Grande cutthroat trout compared to other native trout 

species. 

For this programmatic level of analysis, an assumption was made that if a T&E or sensitive fish

species occupies a stream within a roadless area, the activity projected as likely to occur in that 

roadless area would occur within that watershed where the fish population occurs. The number 

of perennial stream miles on each national forest was used to evaluate the change in habitat

between alternatives and for analyzing potential risk to the MIS. The risk of potential impact on 

aquatic resources is presumed to increase in roadless areas that contain T&E or sensitive 

fisheries and have a likelihood of additional roads and other management activities. Appendix 

D of this EIS, entitled Road Construction and Tree-cutting Projections, displays the relative 

likelihood of new roads and tree-cutting activities in each roadless area by alternative. 

Aquatic Species and Habitat: Environmental Consequences 

All Alternatives

This general effects discussion provides the background for understanding the environmental 

consequences that are subsequently described in more detail for each alternative. It is intended 

to minimize the need to reiterate effects of activities associated with the roadless area 

management alternatives by providing a general discussion of potential effects of road 

construction and reconstruction, tree-cutting and removal activities on aquatic species and their 

habitats. The potential effects for the use of linear construction zones are short-term. They are 

used only for the time it takes to install a linear facility and then the disturbed area is reclaimed 

as prescribed in the authorization. The activities differ by alternative and would potentially

affect aquatic species or habitat. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—181

The effects of livestock grazing, recreational activities, prescribed burning, fire suppression, 

road maintenance, ski area operations, mining hardrock minerals, existing oil and gas leases 

and other authorized activities expected to continue to occur in roadless areas that do not 

significantly differ by alternative are not analyzed, except as part of the cumulative effects 

analysis at the end of this section. While large ski resorts are known to alter natural 

hydrological cycles and increase traffic congestion and land use activities that can impair water 

quality and aquatic species, the projected activities in roadless areas related to ski area 

development are not anticipated to vary by alternative within the analysis period, despite the 

differences in IRA and CRA boundaries in relation to those ski areas. Therefore, the effects of 

ski area developments on aquatic habitat and species in roadless areas do not warrant detailed 

discussion in this EIS. 

The alternatives allow for development of oil and gas production on areas leased prior to the 

date of the rule. There is very little difference in projected oil and gas activities which include, 

pipelines, well heads, pumping stations, power generating stations, electrical transmission lines, 

fluid storage facilities, and roads, all of which can have effects on aquatic habitat and species.

Alternative 3 projects only a slight increase in development and based on projections could 

result in an increase in potential effects to aquatic habitat and species from oil and gas 

development scenarios.

In all alternatives, there is a relatively small amount of ground-disturbing activity likely to 

occur in or close to aquatic habitat in roadless areas, and best management practices and other 

mitigation measures would be applied where needed to minimize impacts on aquatic habitat. 

As human populations continue to grow adjacent to roadless areas, there would be increasing 

demand for management activities on NFS lands, such as conducting wildland fire hazard

reduction treatments.

Effects of Road Construction, Reconstruction and Use 

The broad view of the ecological effects of roads reveals a multiplicity of effects; it also suggests 

that it is unlikely that the consequences of roads will ever be completely mitigated or 

remediated (Trombulak and Frissell 2000). Roads can degrade native aquatic (including riparian

and wetland) ecosystems by altering natural drainage patterns, promoting ground-disturbing 

processes (e.g., mass wasting), and providing conduits for invasive, non-native organisms and 

pathogens. Roads have facilitated the consumptive (fishing) use of native species. The degree to 

which a road will negatively affect aquatic habitat is strongly associated with the specific road 

design, placement, construction practices, uses, and other factors. Roads can have a big 

influence on riparian areas and wetlands even where roads are located a distance away. While 

the localized effect of an individual road-stream crossing may not have a substantial adverse 

effect, the cumulative effect of road networks and multiple crossings increases the potential for 

major adverse effects to aquatic habitats (USDA Forest Service 2000b). In addition, there will 

always be unwanted illegal, user-created roads that must be removed.

Road-related impacts on water quality and aquatic habitat include the following (Elliot 2000, 

Elliot and Hall 1997, Elliot et al. 1996, Furniss et al. 1991, Morrison et al. 1995a, Waters 1995, 

USDA Forest Service 2000b):

Sedimentation and organic material in aquatic systems from road surfaces or cut/fill 

slopes can lead to increases in turbidity and water temperature, and decreases in 

dissolved oxygen concentrations, which can lead to decreased fish spawning success 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

182—Chapter 3. Affected Environment and Environmental Consequences

and alterations in the health of macroinvertebrate communities.

Chemical contaminants entering aquatic systems from vehicle oils, grease, fuel, and 

antifreeze can alter water chemistry parameters such as conductivity, acidity, and 

alkalinity, and can negatively affect riparian and wetland plant and animal species 

(direct mortality or decreased fitness).

Contaminants associated with road dust abatement treatments and de-icing of paved 

roads (including salts and sand) can enter adjacent aquatic and wetland ecosystems.

Road construction and use can remove, displace, or destroy riparian and wetland

vegetation ; and vehicles can crush aquatic organisms and associated plant communities. 

Road construction and use can compact riparian soils and change characteristics of 

riparian vegetation.

Roads can disrupt and reroute surface and subsurface water flows, which can alter the 

composition and abundance of riparian and wetland plant communities.

Road drainage features such as culverts can fragment aquatic habitats by creating 

barriers to all or some species life history stages.

Road construction and use can reduce rates of primary production by algae, 

phytoplankton, and riparian and wetland plants.

Road sediment input can result in a reduction or loss of preferred fish spawning 

substrate size classes by increasing the percentage of fine grained materials on the 

streambed and covering the gravels.

Stream channel form and function can be adversely modified by roads, particularly at 

stream crossings. Roads adjacent to or crossing streams can affect stream channels in 

many ways, including altering channel geometry and profiles; altering substrate 

armoring at stream crossings; changing substrate size distribution at culverts and lowwater fords; altering substrate embeddedness and bed aggradation from sediment input; 

and decreasing average pool depth and abundance.

Roads can facilitate the spread of pathogens and diseases such as whirling disease and 

bacterial kidney disease in aquatic systems.

Roads can contribute to reducing the distribution and abundance of aquatic plants and 

organisms due to increased fishing and collecting activities.

Another important effect from road construction and use, as well as other land management 

activities that differ by alternative, is the resulting increase in invasive and/or non-native plant 

and animal species in riparian and aquatic systems. Invasive species often cause declines in 

native species abundance and diversity. This includes invasive or non-native aquatic organisms 

(e.g. fish, amphibians, crustaceans, mollusks, and insects), which are known to be a pervasive 

impediment to maintaining intact natural aquatic ecosystems (Rahel 2000). Invasive plant 

species can aggressively out-compete native species and are known to alter stream flow and 

water temperature regimes; reduce vegetative groundcover; alter bank stability and increase 

sediment inputs; alter nutrient and organic matter inputs; and overall, alter macroinvertebrate 

and fish habitat and populations (Sheley and Petroff 1999). Invasive animal species are known 

to cause dilution of native gene pools and depletion of populations by hybridization, predation, 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—183

and competition; reduction of native populations by non-native pathogens; reduction in 

reproductive success in native species (e.g. crayfish consuming eggs); and disruption of food 

chains and alterations in nutrient cycling (e.g. change in the relative abundance of zooplankton 

versus phytoplankton).

Roads authorized by the Forest Service can be designed, constructed and managed to reduce or 

eliminate some of the negative impacts on aquatic, riparian, and wetland ecosystems listed 

above. Forest Service road engineering standards include requirements for reducing impacts on 

soil and water quality. Additional mitigation, proactive management (e.g. riparian planting) 

and best management practices would protect aquatic habitat and species from the direct effects

of new roads. 

A beneficial effect of the presence of roads in roadless areas is that they provide easier access to 

remote locations so that natural resource managers can collect data and implement aquatic

habitat restoration projects. Roads can be closed to motorized use by the general public to 

prevent access for recreation uses that bring in non-native pathogens, reduce populations by 

fishing and introduce toxins. 

Effects of Tree-Cutting and Removal Activities

The amount of tree-cutting and removal activities projected to occur in roadless areas varies by 

alternative and can influence aquatic habitat and species. Many trout species spawn and rear in 

forested watersheds, often utilizing small streams with linkages to adjacent forests (Chamberlin 

et al. 1991). Where these habitats are occupied by threatened and endangered trout, such as 

species of inland cutthroat trout, land use activities like tree harvests can have implications for 

their persistence. Tree-cutting with wood product removals in the roadless areas can cause a 

hierarchy of effects to aquatic habitat and species (modified from Chamberlin et al. 1991), such 

as biophysical changes in the water, energy, nutrients and sediment; structural changes in soil, 

vegetation, stream networks, and channel morphology; habitat changes in water depth and 

velocity, water quality, streambed composition, riparian vegetation, and amount of woody 

material in streams; and aquatic biota changes in food web integrity, abundance, and 

composition of producers and consumers. 

Tree-cutting with removal (harvesting) activities typically involve site preparation, skid trails, 

landings, and temporary roads, which alter the vegetation and soil where those activities occur. 

Inappropriate harvest practices have been known to result in a number of negative 

consequences to aquatic species and habitat (Davies and Nelson 1994, Garman and Moring 

1994, Hartman et al. 1996, Holtby 1988, Kedzierski and Smock 2001, Scrivner and Brownlee 

1989), often due to the modification of upslope or streamside vegetation. Silviculture practices 

with the greatest potential for causing erosion and stream sedimentation are road construction, 

tractor skidding, and site preparation. These activities can contribute to surface, gully, and large 

mass soil movements. Negative effects from tree-cutting tend to increase when activities occur 

on environmentally sensitive terrain with steep slopes composed of highly erodible soils (Lee et 

al. 1997). Generally, as the number of acres of harvest and ground disturbance increase, soil 

erosion rates increase (Stednick 2000), as does the potential for other impacts.

Tree-cutting and removal activities vary widely in magnitude and intensity, and therefore in 

resulting consequences. Projected tree-cutting activities for fuel reduction purposes anticipated 

to occur in roadless areas would involve thinning and/or removing groups of dead and dying 

trees that are a result of insect or disease infestations and contribute to wildland fire severity. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

184—Chapter 3. Affected Environment and Environmental Consequences

Cutting larger acreages can affect water yield, water temperature and nutrient loading (Windell 

et al. 1986). 

Most potential effects could be minimized or avoided by avoiding major ground-disturbing 

activities in or connected to water bodies, riparian areas, and wetlands. These and other Best 

Management Practices would mitigate potential effects to aquatic habitat and species from 

erosion and other water quality effects. 

Tree-cutting, with or without wood product removals, when adjacent to streams, can have other 

effects on aquatic systems, because the activity (Chamberlin et al. 1991):

Alters hydrologic functions; reduces the amount of precipitation captured and 

evaporated from the forest canopy; alters snow accumulations and the rate at which 

snow melts, which adds to the amount of surface runoff; alters the overall timing or 

magnitude of water runoff events; and can lead to channel scour and fish embryo 

mortality.

Increases erosion and sediment in streams, causing reduced oxygen levels in spawning 

gravels, and increases the number and extent of riffles.

Changes stream channel structure and sediment storage capacity by loss of root strength 

in the channel banks, removing sources of large woody debris, and altering the 

frequency of channel-modifying flows and sediment supply. A decrease of woody 

material in the stream can lead to reduced cover, loss of habitat complexity, and loss of 

large, deep pools critical to fish (McIntosh et al. 1994).

Increases stream temperature by removing shade along streams; this in turn can increase 

the abundance of non-native warm-water species, increase susceptibility to disease, 

increase food production, and delay egg development for some aquatic biota.

Reduces macroinvertebrate and fish diversity, such as through increases in stream

sediment, turbidity, or temperatures (Bisson et al. 1992; Hartman et al. 1996); increases 

physiological stress or reduces favorable conditions for native cool-water fisheries 

(Barton et al. 1985).

Changes the physical and ecological structures and functions of nearby wetlands, the 

effects of which can persist for decades (Batzer et al. 2000).

Removes streamside vegetation, resulting in changes to water quality in terms of 

temperature, suspended sediment, and nutrients.

Changes wetland and riparian structure and function; areas between wetlands and 

uplands are particularly sensitive to hydrologic changes associated with harvesting 

(Dube et al. 1995); harvest activities can also reduce the abundance of amphibians and 

other wetland fauna (Perison et al. 1997).

As was discussed with the road-related effects, tree-cutting and removal activities would 

similarly increase the prevalence of invasive aquatic plant and animal species, which in turn 

would result in declines in native species abundance and diversity.

Tree-cutting and removal activities projected to occur in roadless areas could have beneficial 

effects, particularly if treatments reduce the magnitude and size of severe wildland fire events 

in those areas. Proper planning could reduce the potential of wildfire while not having impacts 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—185

on aquatic, riparian and wetland ecosystems.

The amount of prescribed fire in roadless areas is not anticipated to substantially vary by 

alternative, and prescribed fire would not likely substantially affect aquatic habitat due to 

mitigation measures that would be applied to minimize adverse effects. 

With the emphasis on use of best management practices and other protective measures in the 

design and implementation of tree-cutting activities, the effects can often be mitigated to some 

extent. Proactive management (e.g. riparian planting) and best management practices would 

protect aquatic habitat and species from the direct effects of tree-cutting activities. 

Cumulatively, however, tree-cutting activities within a watershed can have pronounced and 

lasting effects on aquatic habitat (Chamberlin et al. 1991).

Extent and Duration of Effects

For aquatic habitats, the effects of disturbances associated with road construction and treecutting could extend well beyond those areas directly affected, given the influence that upslope 

areas and upstream reaches have on the condition of downstream habitat (Chamberlin et al. 

1991). Generally the disturbance associated with linear construction zones would not extend 

beyond the area directly affected due to the short-term nature of their use. 

The duration of effects, or recovery time, depends on a variety of factors. Site productivity, 

rainfall, and length of growing season influence the rate and success of vegetation regrowth. 

Some of the other factors influencing the duration of physical effects on a watershed and 

associated stream channels include: the type, location, extent, and duration of an activity; 

magnitude of adverse effects; dominant hydrologic and geomorphic processes within the 

watershed; overall watershed condition; and effectiveness of mitigation and reclamation 

activities. The duration of biological effects can extend beyond the recovery time for the 

physical environment and can be irreversible if a species is extirpated from the watershed.

Alternative 1 – 2001 Roadless Rule

Under alternative 1, the 2001 Roadless Rule provisions would continue to provide limitations 

on road construction in IRAs, which constrains the feasibility of implementing future leases for 

oil, gas, and coal development and several other management activities within most of the 

IRAs. The potential for impacts on aquatic species and habitat in IRAs would be less than for 

the other three alternatives. 

The existing roads in IRAs would continue to contribute to impacts on aquatic habitat. The 

main threat to T&E species, sensitive species, and MIS would be from the potential increase in 

invasive species associated with the use of existing roads and any new roads constructed as 

well as other activities that would continue to occur under this alternative. 

Compared to other alternatives, there would be fewer tree-cutting and removal activities and 

coal operations. Tree-cutting would generally occur in areas where there are existing roads or 

where road construction was previously authorized. Projected linear construction zones are 

similar in all alternatives except for a slight increase in their use under alternative 3. 

This alternative does not include 409,500 acres of unroaded lands that are outside IRAs, which 

would be managed according to forest plan direction. The biggest potential effect of not 

including those acres in IRAs that are in the CRAs would be to the wetlands and fens that may 

be affected by increased human activity on those acres. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

186—Chapter 3. Affected Environment and Environmental Consequences

The road construction and tree-cutting restrictions under this alternative would be expected to 

adequately protect the roadless area characteristics and the T&E species, sensitive species, and 

MIS found in the IRAs. On all of the national forests, there is no adverse effect on the T&E, 

sensitive species and MIS that occur there or on T&E species downstream. There is no adverse 

effect on fens, other wetlands or riparian areas. This assumption presumes that appropriate 

mitigation measures and best management practices would help avoid or minimize impacts 

from the activities allowed to occur in roadless areas under alternative 1.

Alternative 2 – Colorado Roadless Rule (Proposed Action)

This alternative projects a higher level of road construction and tree-cutting than alternatives 1 

and 4, but less than alternative 3. The upper tier acres identified under this alternative would

have minimal new road construction or tree-cutting activities. Projected linear construction 

zones are similar in all alternatives except for a slight increase in their use under alternative 3. 

In the substantially altered IRA acres located outside the CRAs, there would be a greater 

potential for impacts on aquatic habitat and species compared to alternative 1. No roadless rule 

prohibitions would apply to these areas and under this alternative, as well as under alternatives 

3 and 4, they would be managed following forest plan direction. Some of these acres would 

likely have more new roads and associated management activities under the governing forest 

plans. The biggest potential effect of not including those acres in CRAs would be to the 

wetlands and fens that may be affected by increased human activity on those acres. The increase 

in activities on these acres would be expected to increase risks to individual fish populations 

but would not likely result in measurable declines in overall population trends on any national 

forest for any of the aquatic T&E species, sensitive species, or MIS. 

This alternative includes 409,500 acres of unroaded lands in CRAs that are outside IRAs, which 

should afford greater protection from potential impacts from new roads in those additional 

CRA acreages compared to alternatives 1 and 3. 

The effects of roads and increased vehicle traffic in the CRAs would be the same as described in 

the general effects, with the main risk being associated with potential increases in invasive 

species compared to alternatives 1 and 4. This increased risk of impact could occur in locations 

where there could be a higher likelihood for multiple activities and roads in the same CRA 

where native aquatic species exist. There would be impacts in roadless areas where invasive 

species are introduced, or human activity increases, or inadvertent accidental damage to aquatic 

habitat occurs as a result of management activities. 

The risk of impacts on individual fish populations is predicted to be greater in the roadless 

areas where coal development activities are projected to increase compared to alternative 1, on 

the GMUG National Forests. 

The temporary nature and protection measures placed on many of the new roads likely to be 

developed in CRAs would help minimize the risk of long term road-related impacts on aquatic

habitat. Roads constructed under this alternative would be closed to public motorized vehicles,

including off-highway vehicles, unless specifically used for the purpose for which the road was 

constructed or where specifically authorized, and for administrative or emergency use. 

Alternative 2 requires that any road construction or LCZ construction must maintain or 

improve existing native cutthroat trout habitat. This requirement ensures that any roads or LCZ 

constructed within the CRAs would be constructed in a way that maintains or improves 

cutthroat trout habitat over the long-term. For this reason, alternative 2 provides greater 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—187

protections for the cutthroat trout than either alternative 1 or 3.

On all of the national forests, there is no adverse effect on the T&E, sensitive species and MIS

that occur there or on T&E species downstream. There is no adverse affect on fens, other 

wetlands or riparian areas. This assumption presumes that appropriate mitigation measures 

and best management practices would help avoid or minimize impacts from the activities 

allowed to occur in roadless areas under alternative 2. The specialist report in the EIS record 

contains further details for each national forest and specific roadless area. 

Alternative 3 – Forest Plans (No Action)

Under this alternative, the forest plan direction related to road construction and tree-cutting 

activities in roadless areas varies widely for each national forest and roadless area. Information 

is provided in Appendix B: Forest Plan Management Area Direction and Map 5 within the map 

packet, regarding road construction and tree-cutting direction found in the forest plans. This 

alternative could potentially create more impacts on aquatic species and ecosystems compared 

to the other three alternatives, as the forest plans are generally less restrictive on more acres of 

IRAs and there are more projected activities in IRAs under this alternative. There is a slight 

increase in the use of linear construction zones when compared to the other three alternatives.

The effects of road construction and tree-cutting under this alternative are similar to what was

previously described. The IRAs included under this alternative contain aquatic species and 

habitat that occur in the same areas where road construction and road-related activities are 

projected to occur. In these IRAs, there is an increased risk of adverse impacts on individual 

populations. Wetlands and riparian areas in many IRAs could be affected by the extent of 

projected activities. 

On the GMUG National Forests, the additional coal roads and operations result in less 

protection to the abundant riparian areas, wetlands, and fens under this alternative, increasing 

the risk of impact on individual populations. An increase in future oil and gas activity under 

this alternative is projected. This alternative may also result in an increased risk of impacts on 

individual populations from increased road construction and associated oil and gas activities in 

locations where aquatic sensitive species occur.

If the reduction in hazardous fuels was adequate to limit harmful fires and the impacts from 

roads and other activities associated with these activities were fully mitigated, this alternative 

could produce a beneficial effect. 

Overall, this alternative would result in the least population fitness of some aquatic MIS species, 

potentially affecting populations of aquatic T&E and sensitive species, and could further reduce 

wetland and riparian abundance and health.

Though there is a higher risk than other alternatives for impacts on individual threatened 

species habitat, wetlands, and riparian areas, there is no long-term adverse effect on T&E

species, sensitive species, and MIS population trends; downstream T&E species; or wetlands 

and riparian areas. This assumption presumes that appropriate mitigation measures and best 

management practices would help avoid or minimize impacts from the activities allowed to 

occur under alternative 3. The specialist report in the EIS record contains further details for each 

national forest and specific roadless areas. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

188—Chapter 3. Affected Environment and Environmental Consequences

Alternative 4 – Colorado Roadless Rule with Public Proposed Upper Tier

Alternative 4 contains identical prohibitions and exceptions as alternative 2; however, there are 

more acres identified as Colorado Roadless Area upper tier acres. A portion of these upper tier 

acres have been identified as being within watersheds that are currently occupied by T&E, 

sensitive, and MIS fish. For this reason, alternative 4 provides more protection than alternative 

2. In addition, these additional acres contain stream riparian and wetland acres not included in 

the other alternatives. In these areas, alternative 4 would provide additional restrictions on 

management activities. Compared to alternative 1, these additional restrictions would reduce 

the risks associated tree-cutting, sale or removal or road construction and reconstruction. 

On all of the national forests, there is no adverse effect on the T&E, sensitive species and MIS

that occur within the areas or on T&E species downstream. There is no adverse effect on fens, 

other wetlands or riparian areas. This assumption presumes that appropriate mitigation

measures and best management practices would help avoid or minimize impacts from the 

activities allowed to occur in roadless areas under alternative 4.

Aquatic Species and Habitat: Cumulative Effects

The effects on aquatic habitat and species from past, ongoing, and foreseeable future activities 

were considered, including all of those listed in Appendix D: Cumulative Effects Framework. 

Also considered was whether the effects of other activities and land uses would overlap in time 

and space with the effects just described for each roadless management alternative. 

There are a number of cumulative effects on aquatic species and habitat from the additive 

influences from other human activities, such as historic settlements and ongoing land uses. The 

cumulative effects of management activities on native fishery resources have resulted in most of 

Colorado‘s native fish having special regulatory considerations because of their rarity (Behnke 

2002). While non-native trout such as brown, brook, and rainbow appear to be thriving on most 

national forests in Colorado, continual change in human influences suggests that in some areas 

native aquatic populations may be suppressed or non-viable. Historic activities have resulted in 

a considerable loss of wetlands and riparian areas in Colorado; the State has lost approximately 

50 percent of its natural wetlands (Dahl 1990).

Where there are more roadless area acres in close proximity to large population centers in 

Colorado, such as on the Arapaho-Roosevelt or Pike-San Isabel National Forests, there is a 

higher potential for cumulative impacts on aquatic species and habitat. The roadless areas on 

these forests that are close to large population centers experience a wide array of recreational, 

developmental, and municipal uses that affect the associated streams, wetlands, and other 

aquatic habitat within those areas. These various land use activities, when they occur in the 

same vicinity, may cumulatively limit the potential for reestablishment of threatened greenback 

cutthroat trout, a threatened fish species that only occurs on these two national forest units in 

Colorado. 

When oil and gas development or coal mining occur in the same roadless areas as developed ski 

areas, other recreational uses, fuel reduction projects, and other land management activities, 

there can be cumulatively adverse impacts on aquatic habitat. This would be most likely to 

occur in roadless areas on the GMUG National Forests, as well as the San Juan or White River

National Forests. In roadless areas on the GMUG and San Juan National Forests, unique 

features like fens and wetlands are relatively more abundant and therefore are more vulnerable 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—189

to cumulative effects from the many activities expected to occur over the next 15 years. Additive 

impacts on aquatic resources on the White River National Forest may be related to roadless area 

proximity to populated areas that continue to experience rapid growth. Recreation use is 

considered very high in several areas, with Summit County having the highest concentration of 

ski areas in the State. The White River National Forest contains numerous roads, including 

roads that cross streams. Road crossings and multiple use activities on the White River may be 

limiting movement of native and non-native fish throughout a considerable portion of the 

forest, particularly in the southern and eastern portions. 

On the Manti-La Sal National Forest, the Roc Creek roadless area contains an eligible wild and 

scenic river based on its scenic, geologic, and hydrologic values, along with waterfalls and 

riparian vegetation complexes. There are several oil and gas leases in the area that may add to 

recreational uses and other ongoing activities to additively affect the unique riparian resources 

in this roadless area. 

There are roadless areas on the national forests that are not adjacent to large population centers 

and are not expected to have oil, gas, or coal operations in the next 15 years, such as areas on the 

Rio Grande and Routt National Forests. Despite those expectations, there would still be a 

variety of human developments and land use activities that continue to increase over time and 

have additive effects on the streams that historically supported Rio Grande cutthroat trout or 

other sensitive or MIS fish, as well as riparian areas and wetlands.

Considering all past, ongoing, and projected future activities within the same watersheds as the 

roadless areas in Colorado, cumulative effects are clearly evident and would be likely to 

continue to occur. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

190—Chapter 3. Affected Environment and Environmental Consequences

TERRESTRIAL SPECIES AND HABITAT

This section presents the evaluation of effects of the alternatives on terrestrial (land-based) 

wildlife and their habitats. Terrestrial animals evaluated include birds, mammals, amphibians 

(frogs and toads) and terrestrial invertebrates (butterflies and snails). Specific analyses are 

focused on threatened and endangered (T&E) and sensitive species, management indicator 

species (MIS), migratory birds, big game, and their associated habitats. 

Roadless areas have special importance for wildlife because they provide large blocks of habitat

in which natural processes are largely allowed to occur freely and human disturbance is 

relatively low. A high level of security and seclusion is particularly important during periods 

when animals are birthing and rearing their young. Compared to more developed landscapes, a 

higher degree of habitat diversity and complexity and higher levels of snags and coarse woody 

debris are typically found in roadless areas. Roadless areas provide connectivity with other 

blocks of unfragmented habitat and can function as wildlife movement and dispersal corridors. 

Roadless areas will likely play an increasingly important role in sustaining viable populations 

and overall native biodiversity in the face of accelerating human population growth, associated 

land development, and climate change. 

Terrestrial Species and Habitat: Affected Environment

There are approximately 600 species of terrestrial animals that occur within the State of 

Colorado. Roadless areas are considered to have high species richness (variety of species), and 

often harbor more threatened, endangered and sensitive species than adjacent national forest 

lands that have higher levels of resource development and human activities. 

Climate change is affecting terrestrial and aquatic animal species and habitats across Colorado 

and the U.S. Average annual temperature increases due to increased carbon dioxide are 

affecting snowpack, peak runoff, and base flows of streams and rivers. Predictions indicate that 

spring snowpack will probably be less, that more precipitation will probably fall as rain rather 

than as snow, and that spring peak runoff will occur earlier (Backlund et al. 2008). For species 

such as white-tailed ptarmigan and wolverine that require cold, snowy alpine environments to 

survive, warmer temperatures could lead to significant decreases in available suitable habitat.

Climate change is also affecting phenology (the biology of timing of organisms), involving 

aspects such as animal hibernation and migration. For example, bird migration, which formerly 

was synchronized with maximum food availability, may now occur too late and result in 

lowered reproductive success.

Climate change is likely to exaggerate the scale and intensity of natural disturbances such as 

wildfire and beetle epidemics. Larger and more intense fires and insect outbreaks might be 

expected in Colorado in the future. This may affect the ability of individual members of a 

species to survive the direct effects of fire. While many adult vertebrate species are mobile 

enough to flee burning areas or seek refuge, the young born in that year are often most 

vulnerable to injury and mortality from fire (Smith 2000).

Terrestrial Wildlife Habitats 

Roadless areas in Colorado are predominantly coniferous forests in mountainous terrain, 

ranging in elevation from about 7,000 to 14,000 feet above sea level. The predominant 

vegetation cover types are spruce-fir, aspen, lodgepole pine and Douglas-fir, with smaller 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—191

amounts of ponderosa pine and pinyon-juniper woodlands found at the lower elevations. 

Habitat structural stages range from grass/forb and shrub/sapling through late successional 

forest. Mature and old forest conditions are present on about 60% of the acres in roadless areas, 

although the mature lodgepole pine stands are now largely dead due to a mountain pine beetle 

epidemic.

Federally Listed Species and Habitats 

Several sources of information were compiled to identify known and potential occurrence of 

threatened and endangered species in roadless areas. These included Forest Service species 

occurrence matrices (available at the Rocky Mountain and Intermountain Regional Offices), 

information available from the U.S. Fish and Wildlife Service, comments submitted by the 

Colorado Division of Wildlife, Colorado Natural Heritage Program databases, and professional 

knowledge of the Forest Service‘s wildlife staff. 

Three federally-listed threatened or endangered species -- grizzly bear, gray wolf and blackfooted ferret -- have been extirpated from Colorado. If populations of these species should 

become re-established in Colorado in the future, effects of land management activities on them 

will be evaluated at that time. Three terrestrial federally-listed species (whooping crane, piping 

plover, and least tern) occur in Colorado, but are not known or expected to occur in the roadless 

areas. These six species are not analyzed further in this document.

Six federally-listed or proposed terrestrial species are known or are likely to occur within 

roadless areas. Table 3-34 displays key habitat requirements for each listed species and the 

number of roadless areas where the species or suitable habitat is known to occur.

Critical habitat has been designated for the Preble‘s meadow jumping mouse and Mexican 

spotted owl on two national forests in Colorado. Four roadless areas on the Arapaho-Roosevelt 

National Forest contain critical habitat for the Preble‘s meadow jumping mouse; the Pike-San 

Isabel National Forests provides critical habitat for the Preble‘s meadow jumping mouse in two 

roadless areas, and for the Mexican spotted owl in nine roadless areas. 

The yellow-billed cuckoo, Gunnison‘s prairie dog (Montane Significant Portion of the Range), 

New Mexico meadow jumping mouse, greater sage-grouse, and lesser prairie-chicken are 

identified as candidates for listing under the Endangered Species Act (ESA). Candidate status 

means that the best scientific and commercial data available suggest that a proposal for listing 

may be warranted, but the full review has not yet been conducted. Candidate species are 

included on the list of Forest Service sensitive species and are discussed, as such, below. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

192—Chapter 3. Affected Environment and Environmental Consequences

Table 3-34. Occurrence of threatened and endangered species or their habitat within roadless 

areas 

Species and status 

(T) or (E) Key habitat requirements

Roadless areas with 

T&E species occurrence 

or suitable habitat

(# of roadless areas)

BIRD

Southwestern willow flycatcher 

(E)

Empidonax trailii extimus

Dense riparian thickets of willow, cottonwood, and 

other deciduous shrubs and trees about 13–23 ft. or 

more in height. At higher elevations, shrub willows 

are a major component. 

4

Mexican spotted owl (T)

Strix occidentalis lucida

In Colorado, nests in caves or on ledges in steep, 

narrow canyons with uneven-aged stands of mixedconifer forests. May also use ponderosa pine, 

Gambel’s oak and riparian woodlands. Frequent, lowintensity surface-dominated fires maintain opencanopy stands used for foraging.

32

Mountain plover (Proposed)

Charadrius montanus

Short-grass prairie; short vegetation and often in 

prairie dog towns. Nest placed on bare ground.

1

INSECT

Pawnee montane skipper (T)

Hesperia leonardus montana

Restricted to the South Platte River drainage in 

Colorado; dry open ponderosa pine woodlands at 

6,000–7,500 ft., sparse understory with blue grama 

(larval food) and prairie gayfeather (nectar). Frequent 

low-intensity surface fires maintain the preferred 

open-canopy structure.

4

Uncompahgre fritillary (T)

Boloria acrocnema

Above timberline in patches of its larval host plant, 

snow willow. Most often found on cool, moist northand east-facing slopes.

15

MAMMAL

Canada lynx (T)

Lynx canadensis

Spruce-fir forest (potential vegetation type) with cold 

winters, deep snow, and an adequate prey base of 

snowshoe hares. Cover types may include spruce, fir, 

lodgepole pine, Douglas-fir, and aspen. Dense 

horizontal cover is needed for snowshoe hare habitat.

Maintaining habitat connectivity and linkages areas is 

especially important in the Southern Rockies.

307

Preble’s meadow jumping 

mouse (T)

Zapus hudsonius preblei

Riparian vegetation and adjacent upland vegetation 

up to ~7600 ft. elevation. Lush undergrowth of 

grasses or forbs in riparian areas and moist 

meadows, often with tree and shrub cover.

15

Forest Service Sensitive Species

There are 33 sensitive wildlife species that occur or are likely to occur in roadless areas, based 

on their known occurrence or habitat requirements. These consist of 31 vertebrate species (3 

amphibians, 18 birds, and 10 mammals) and 2 invertebrate species (1 insect and 1 mollusk).

Table 3-35 displays those sensitive species that are known or are expected to occur in the 

roadless areas in Colorado and in which national forest(s). 

Inventories of sensitive species on NFS lands are incomplete, especially in roadless areas. Most 

of the available data are from incidental observations rather than systematic inventories, and 

therefore are biased against species that are cryptic, secretive, or nocturnal. Records of sensitive 

species within roadless areas are dominated by a few of the more conspicuous and more widely 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—193

distributed species, such as bighorn sheep, American marten, boreal owl, and northern 

goshawk.

Table 3-35. Sensitive animal species associated with roadless areas in Colorado

Scientific name

Common 

name Habitat National Forest

AMPHIBIAN

Bufo boreas boreas Boreal toad Wetlands near ponds, lakes, reservoirs, 

rivers, and streams between approximately 

7,500 and 12,000 ft. elevation. May be 

observed in other habitats during dispersal. 

AR, GMUG, PSI, 

RG, Routt and WR

Rana pipiens Northern 

leopard frog 

Smaller, semi-permanent ponds with 

emergent vegetation; disperses along creeks 

and small riparian areas.

AR, GMUG, RG, 

Routt, SJ, WR

Rana sylvatica Wood frog Semi-permanent and temporary pools of

natural origin and adjacent wet meadows; 

early fall seek hibernacula in upland forest 

habitat .

AR, Routt

BIRD

Accipiter gentilis Northern 

goshawk 

Large tracts of mature, closed canopy, 

deciduous, coniferous and mixed forests with 

an open understory.

AR, GMUG, MLS, 

PSI, RG, Routt,

SJ, WR

Aegolius funereus Boreal owl Mature, mixed stands of subalpine fir and 

Engelmann spruce with large nest cavities.

GMUG, PSI, RG, 

Routt, SJ, and WR

Buteo regalis Ferruginous 

hawk 

Generally in open grasslands east of the 

Continental Divide and shrub-steppe west of 

the CD; requires adequate supply of small 

rodents.

WR

Centrocercus 

minimus

Gunnison 

sage-grouse

Relies almost entirely on sagebrush 

communities; wet meadow habitats 

interspersed within the sagebrush type are 

also important.

GMUG, PSI, RG

Centrocercus 

urophasianus

Greater 

sage-grouse

Sagebrush grasslands; sagebrush overstory, 

and grass/forb understory without human 

disturbance important as breeding habitat

Routt, WR

Circus cyaneus Northern 

harrier

Open wetland and adjoining upland habitats 

during breeding season especially needs 

large tracts of undisturbed habitat

WR

Contopus cooperi Olive-sided 

flycatcher

Forest openings and edges in mature forests 

and following natural and anthropogenic 

disturbances, such as tree fall gaps, fire, and 

logging; presence of snags essential.

AR, GMUG, WR

Cypseloides niger Black swift Rock ledges associated with waterfalls. AR, GMUG, PSI, 

SJ, RG and WR

Falco peregrinus 

anatum

American 

peregrine 

falcon

Cliff habitat more than 200 ft. high with ledges 

suitable for nesting, usually associated with 

river corridors, reservoirs, or lake basins.

AR, GMUG, MLS, 

PSI, RG, Routt,

SJ, WR

Haliaeetus 

leucocephalus

Bald eagle Large trees for nesting and perching near 

fish-bearing lakes, streams and rivers.

AR, GMUG, MLS, 

PSI, RG, Routt,

SJ, WR
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

194—Chapter 3. Affected Environment and Environmental Consequences

Scientific name

Common 

name Habitat National Forest

Lagopus leucurus White-tailed 

ptarmigan

Alpine ecosystems at or above treeline; 

adjoining riparian and meadow habitats within 

the subalpine zone; primary winter food is 

willow.

AR, GMUG, PSI, 

WR

Lanius ludovicianus Loggerhead 

shrike

Open habitats such as deserts, sagebrush, 

grasslands, and pastures.

WR

Melanerpes lewis Lewis’s

woodpecker

Open forest (< 30 percent canopy cover) and 

abundant snags; preference for pine forests 

and for riparian cottonwoods at low elevation.

AR, GMUG, PSI, 

RG, Routt SJ, WR

Otus flammeolus Flammulated 

owl 

Open ponderosa pine or mixed conifer forests 

with cavities for nesting intermixed with 

grassy openings and dense thickets.

AR, GMUG, SJ

Picoides dorsalis American 

three-toed 

woodpecker

Mature and over-mature coniferous forests 

with dead and dying trees providing insect 

prey.

AR, GMUG, MLS, 

RG, Routt, WR

Progne subis Purple martin Mature aspen forest with nest cavities and 

nearby meadows and open water.

GMUG, WR

Spizella breweri Brewer’s 

sparrow

Sagebrush communities dominated by big 

sagebrush of canopy height <1.5 m; also 

occurs in shrubby openings in pinyon-juniper 

and mountain mahogany woodlands and 

large shrubby parklands within coniferous 

forests.

WR

Tympanuchus 

phasianellus 

columbianus

Columbian 

sharp-tailed 

grouse

Mid-tall prairie grasslands, upland sagebrush, 

and montane scrub during breeding; riparian

scrub and open coniferous forests in winter.

GMUG, Routt WR

MAMMAL

Conepatus 

leuconotus

Common 

hog-nosed 

skunk

Riparian areas, rocky canyonlands, piñyonjuniper woodlands, shrublands, and 

grasslands that contain brushy and rocky 

habitat

PSI

Euderma maculatum Spotted bat Xeric and riparian habitats in deep, narrow 

canyons with cliffs and rocky outcrops

MLS, WR

Gulo gulo North 

American 

wolverine

Late spring snow in cirque basins and 

subalpine forests; dens in snow often 

associated with talus and coarse woody 

debris.

AR, GMUG, PSI, 

RG, Routt, SJ, 

WR

Lontra canadensis North 

American 

river otter

Streams, lakes, and reservoirs AR, Routt SJ, WR

Martes americana American 

marten

Mesic (moist), dense coniferous forests with 

complex physical structure; in winter prefer 

mature and old-growth conifers; summer 

habitat use is somewhat broader; large 

snags, large logs, large live spruce-fir trees, 

and squirrel middens are important 

characteristics of maternal dens.

AR, GMUG, RG, 

Routt, SJ, WR

Myotis thysanodes Fringed 

myotis

Low- and mid-elevation mines in steep river 

valleys, large canyons, or other sites having 

steep and rock terrain.

AR, GMUG, PSI, 

RG
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—195

Scientific name

Common 

name Habitat National Forest

Ovis canadensis 

canadensis

Rocky 

Mountain 

bighorn 

sheep

Open habitats such as alpine meadows, open 

grasslands, shrub-steppe, talus slopes, rock 

outcrops, and cliffs.

AR, GMUG, PSI, 

Routt SJ, WR

Corynorhinus 

townsendii

Townsend’s 

big-eared bat

A wide variety of habitats from arid sagebrush 

and juniper breaks to high-elevation forests 

including caves, mines, and rock crevices.

AR, GMUG, MLS, 

PSI, RG, WR

Sorex hoyi Pygmy 

shrew

Ssp. montanus in Colorado occurs in moist 

coniferous forest, possibly preferring lateseral stands and the edges between wet and 

dry forest types. 

AR, GMUG, Routt

WR

Vulpes macrotis Kit fox Desert and semiarid habitats, inhabiting 

mixed-grass shrublands, shrublands, and 

margins of pinyon-juniper woodlands.

GMUG

Vulpes velox Swift fox Variety of habitats including shortgrass and 

mid-grass prairies, plowed fields and 

fencerows, and sagebrush; select lowgrowing vegetation and relatively flat terrain, 

friable soils and high den potential (prairie 

dog towns/burrows, badger burrows), and 

areas near roads.

Routt

INVERTEBRATE

Acroloxus 

coloradensis

Rocky 

Mountain 

capshell 

snail

Clean boreal lakes with rocky substrate. Routt

Speyeria nokomis 

nokomis

Nokomis 

fritillary (or 

Great Basin 

silverspot)

Wetlands with flowing water (i.e., springs, 

seeps, wet meadows); abundant larval food 

plant (bog violet) and adult nectar sources 

(mostly Composites).

WR

Key to National Forest abbreviations: AR = Arapaho-Roosevelt; GMUG = Grand Mesa, Uncompahgre and Gunnison; 

MLS = Manti La Sal; PSI = Pike-San Isabel; RG = Rio Grande; Routt = Routt; SJ = San Juan; WR = White River.

Source: U.S. Fish and Wildlife Service and Forest Service list of federally listed species, for national forests in Colorado, April 

2008 (in EIS record).

Management Indicator Species (MIS)

There are a total of 36 terrestrial animals identified as MIS by the national forests in Colorado 

(excluding those selected only for national grasslands). This includes 11 mammals and 25 birds. 

Four of the 36 MIS are listed as threatened or endangered species and are discussed in the 

previous section.

All of the 36 terrestrial MIS are likely to occur within one or more roadless areas. Table 3-36

displays the population and habitat trend for each terrestrial MIS, based on the latest MIS 

monitoring report for each national forest in Colorado, as well as the reason the species was 

selected as a MIS, based on each forest plan. MIS generally can be grouped as follows: 

Those that represent certain vegetation types and/or structural stages: American pipit, 

bald eagle, Brewer‘s sparrow, brown creeper, Columbian sharp-tailed grouse, goldencrowned kinglet, green-tailed towhee, hermit thrush, Lincoln‘s sparrow, Merriam‘s wild 

turkey, mountain bluebird, northern goshawk, pygmy nuthatch, red-naped sapsucker, 

vesper sparrow, Virginia‘s warbler, warbling vireo, Wilson‘s warbler, Abert‘s squirrel, 

American marten, bighorn sheep, deer mouse, elk and mule deer.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

196—Chapter 3. Affected Environment and Environmental Consequences

Those that represent unique habitat features such as snags, caves, or wetlands and 

streams: boreal toad, hairy woodpecker, beaver, cave bats, and river otter.

Those that respond to road density and management: elk, mule deer.

Those that are economically important or have high public interest: black bear, elk, 

mallard.

Those that are listed under the ESA: Canada lynx, Mexican spotted owl, southwestern 

willow flycatcher, Uncompahgre fritillary butterfly. 

Table 3-36. Terrestrial management indicator species, their population and habitat trend in 

Colorado, and reason for selection

MIS

species A

R

GMUGMLSPSIRGROUTTSJWR

Reason for selection

MAMMALS

Abert’s 

squirrel D/U U/S I/U S/S Management of ponderosa pine forest (GMUG, PSI)

American 

marten (S) D/U I/S Management of spruce-fir forest (GMUG, RG)

Beaver I/I Riparian habitat

Bighorn sheep

(S) D/U Management of forest openings (AR)

Black bear D/S Economically important, forest generalist

Canada lynx 

(T) S/S T&E species (SJ)

Cave bats (S) S/D Management of cave recreation (WR)

Deer mouse I/I Early successional stages

Elk S/U S/U S/S I/I D/S S/D D/U

Management of roads (GMUG, RG, WR), Public 

interest (PSI); juxtaposition of openings and forest 

cover (AR)

Mule deer D/U I/S I/S S/D Habitat interspersion (AR); road density (RG)

River otter (S) I/I Sensitive species

BIRDS

American pipit U/U Alpine grasslands (WR)

Brewer’s 

sparrow (S) D/U U/U Sagebrush shrubland management (GMUG, WR)

Bald eagle (S) S/S Sensitive species (SJ)

Brown creeper I/I Management of late succession spruce-fir forest 

(RG)

Columbian 

sharp-tailed 

grouse (S)

U/S Sensitive species (SJ)

Goldencrowned 

kinglet

D/U S/D Interior forest (AR), Spruce-fir forest management 

(Routt)

Green-tailed S/S Mountain shrub communities
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—197

MIS

species A

R

GMUGMLSPSIRGROUTTSJWR

Reason for selection

towhee

Hairy 

woodpecker I/U S/S Snag management (AR)

Hermit thrush S/S Forest management (RG)

Lincoln’s 

sparrow

S/S Riparian willow management (RG)

Mallard I/I Economically important, wetlands

Merriam’s wild 

turkey I/U I/S Management of oak, pinion/juniper, and ponderosa pine (GMUG)

Mexican 

spotted owl 

(T)

U/S T&E species (San Juan)

Mountain 

bluebird S/U S/S Openings adjacent to forest (AR)

Northern 

goshawk (S) D/U U/U S/U S/S

Mature and older aspen, mixed conifer, and 

spruce-fir forest (GMUG); lodgepole pine timber

management (Routt)

Pygmy 

nuthatch S/U S/S Late succession ponderosa pine (AR, RG)

Red-naped 

sapsucker S/U Mature aspen in riparian areas (GMUG)

Southwestern 

willow 

flycatcher (E)

U/S T&E species (SJ)

Vesper 

sparrow

S/S S/U Rangeland residual forage and mountain 

grasslands (Routt, RG)

Virginia’s 

warbler U/U Shrub management and shrub related species (WR)

Warbling vireo S/U Aspen community status (AR)

Wilson’s 

warbler S/U S/S D/U

Mountain riparian and wetland communities (AR); 

herbivore in riparian areas (Routt); riparian willow 

(RG)

AMPHIBIANS AND INSECTS

Boreal toad 

(S) D/U Mountain riparian and wetland communities (AR)

Uncompahgre 

fritillary (T) S/S Wetland communities (SJ)

(T)(E)(S) indicate MIS that are listed as threatened (T), endangered (E), or sensitive (S) species. 

Population trend and habitat trend are indicated with “I” for increasing, “D“ for decreasing, “S” for stable, and “U” for 

unknown.

Source: MIS monitoring and evaluation reports completed for each national forest in Colorado (in EIS record).

AR=Arapaho-Roosevelt National Forests; GMUG=Grand Mesa, Uncompahgre, and Gunnison National Forests; MLS=MantiLa Sal National Forest; PSI=Pike- San Isabel National Forests; RG=Rio Grande National Forest; SJ=San Juan National 

Forest; WR=White River National Forest.

Migratory Birds

More than 400 species of birds have been recorded in Colorado, and over 250 species nest in the 

State. Because roadless areas encompass a wide variety of vegetation and range of elevations, 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

198—Chapter 3. Affected Environment and Environmental Consequences

there is a great diversity of migratory birds that inhabit roadless areas in Colorado.

The Colorado Bird Conservation Plan identifies priority species and habitats and establishes 

objectives for bird populations and habitats in the State of Colorado. The roadless areas of 

Colorado are located within the Southern Rocky Mountains and the Colorado Plateau 

Physiographic Areas PA62 and PA87 (Partners in Flight 2007).

Migratory bird monitoring has been conducted annually since 1998 through Monitoring 

Colorado Birds, a partnership between the Forest Service, Colorado Division of Wildlife, the 

Rocky Mountain Bird Observatory, the Bureau of Land Management, and the National Park 

Service. Monitoring is conducted annually during the breeding season across Colorado. 

Monitoring transects were randomly located in order to sample habitats that are representative 

of the State (Leukering et al. 2000). Of approximately 499 (current and retired) monitoring 

transects in Colorado, 10 transects (two percent) exist within portions of the IRAs and five

transects (one percent) exist in portions of CRAs. Originally a road-based monitoring program, 

it has been redesigned. Starting in 2008, of the 184 sampling units in Colorado, 44 (24 percent) 

occur in IRAs and 42 (23 percent) occur in CRAs. 

The National Audubon Society identifies Important Bird Areas (IBA) that are vital to bird 

migration, breeding, and wintering. Of the 53 IBAs designated in Colorado, six are located on 

national forests and grasslands. Two IBAs occur in roadless areas or adjoining wilderness areas 

on the White River National Forest: Hanging Lake IBA in the Grizzly Creek IRA/CRA and the 

Alfred M. Bailey Bird Nesting Area IBA in Eagle‘s Nest Wilderness adjacent to the Maryland 

Creek IRA/CRA. The National Audubon Society has identified habitat disturbance from 

recreational rock and ice climbers as a potential threat to Hanging Lake IBA. The Alfred M. 

Bailey Bird Nesting Area IBA was designated because it is one of the most diverse mountain 

avian breeding sites in Colorado, with approximately 44 species of breeding birds identified. 

The National Audubon Society has identified habitat conversion of the surrounding forest by 

logging as a potential threat to this IBA.

Big Game 

Big game species (ungulates -- elk, deer, moose, bighorn sheep, and mountain goats -- as well as 

black bear and mountain lion) are tremendously important socially and economically to the 

State. Colorado boasts the largest elk and mule deer herds in the United States. Hunting and 

fishing generate about $1 billion annually to the State‘s economy, with wildlife viewing 

contributing an additional $1.3 billion (USDI Fish and Wildlife Service and USDOC, U.S. 

Census Bureau 2008). 

Roadless areas provide important habitats for wild ungulates. Deer fawning and/or elk calving 

habitat has been documented on more than 40 percent of roadless areas in the State, and about 

one-third contain seasonal migration corridors for big game animals. 

Winter range is often the primary limiting factor for most ungulate populations. During the 

winter, most ungulates migrate to lower-elevation areas where the snow is not as deep. The 

animals utilize physiological and behavioral adaptations (e.g., lowered metabolic and activity 

rates) to reduce energy requirements during stressful periods of cold temperatures and deep 

snow. Despite this, most ungulates lose weight throughout the winter. Human disturbances, 

especially unpredictable or erratic occurrences, increase energy costs, for example, by simply 

raising the heart rate or by causing the animal to flee. This additional stress ultimately can 

reduce reproductive success or over-winter survival (Cole et al. 1997). More than half of the 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—199

roadless areas in Colorado provide winter range, and are important to sustaining ungulate 

populations.

Roadless areas also provide important summer habitat for ungulates. The quality of summer 

habitat has been shown to be very important to overall nutritional status. Animals that leave 

their summer ranges in good body condition have higher survival and reproductive rates the 

following spring. Road density is also an important factor in vulnerability of elk to hunters in 

the fall (Hayes et al. 2002).

Terrestrial Species and Habitat: General Environmental 

Consequences 

General Wildlife Responses

This subsection provides the background for understanding the environmental consequences 

described in more detail in the next part of this evaluation, while minimizing the need to 

reiterate effects of activities common to all alternatives. A general discussion of potential 

impacts on animal species and their habitats from road construction and reconstruction, treecutting and removal activities, and oil, gas and coal resource operations is presented. The extent 

to which these activities would be permissible varies by alternative. The general discussion on 

wildlife effects is followed by a more specific evaluation of the effects of each alternative to 

threatened and endangered species, sensitive species, management indicator species, and 

migratory birds. 

None of the alternatives by themselves would authorize or result in any ground-disturbing 

activities. The extent to which these effects could be realized depend on site-specific factors such 

as the type, location, timing, duration, frequency, and magnitude of the management actions. 

Forest plans contain objectives, standards and guidelines designed specifically to maintain or 

improve habitat for terrestrial animals, especially threatened and endangered species, sensitive 

species, and MIS. Thus, some of the potential impacts described programmatically would likely 

be avoided or reduced through site-specific planning and implementation. 

Effects of Road Construction, Reconstruction and Maintenance

Although the amount and conditions vary by alternative, all alternatives include provisions that 

would allow construction, reconstruction or maintenance of roads within roadless areas under 

certain circumstances.

The potential impacts of roads on terrestrial species and their habitats are well-documented in 

the scientific literature. Based on several comprehensive syntheses on this topic (Forman et al. 

2003, Wisdom et al. 2000, Trombulak and Frissell 2000, Joslin 1999), effects of roads on wildlife

habitats were organized into the following categories: habitat availability and effectiveness; 

habitat fragmentation; spread of non-native invasive species; and human-caused disturbance 

and mortality. 

Habitat Availability and Effectiveness

Road construction and road use can affect habitat availability. First, construction and 

reconstruction of roads can contribute to an immediate loss of habitat by removing existing 

vegetation and altering the substrate (Forman et al. 2003). Because forest roads, especially in 

roadless areas, tend to be narrow (approximately 12 to 14 ft. wide), their contribution to habitat 

loss on a landscape scale may appear minimal. However, the total extent of the landscape that is 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

200—Chapter 3. Affected Environment and Environmental Consequences

roaded has consequences for habitat availability (Forman et al. 2003). The higher road densities 

that exist outside roadless and wilderness areas increase their role as refugia for terrestrial

animal species. 

The indirect effects of road construction and use include noise and visual disturbance that can 

displace wildlife by causing them to avoid suitable habitats that would otherwise be available to

them. The effect of this pattern, in which the habitat nearest the road is avoided, decreases as 

distance from the road increases and is referred to as a reduction in habitat effectiveness 

(Thomas et al. 1979). 

The reduction in habitat effectiveness can be substantial. With only two miles of roads open to 

vehicular traffic per square mile, the area affected can easily exceed half of all available elk 

habitat (Lyon 1983). Once the original purpose of a forest road has been satisfied, many roads 

have been gated under the assumption that ―administrative use‖ would not unduly disturb elk 

and other wildlife. However, it has been shown that even a limited amount of administrative 

traffic behind closed gates is sufficient to reinforce the avoidance behavior (Lyon 1979).

Reduced habitat effectiveness due to roads has been documented for numerous ungulate 

species. Rowland et al. (2004) found that female elk in the Starkey Experimental Forest 

consistently used areas away from open roads in spring and summer. When vehicular traffic 

was excluded for several years, Cole et al. (2004) documented increased use of open foraging 

habitats by elk. Summer and autumn avoidance of roads by mule deer has been observed in 

arid climates (Marshal et al. 2006). The presence of poaching or hunting can exacerbate 

avoidance behavior and displacement of wildlife from areas adjacent to roads.

Gaines et al. (2005) found that the presence of roads reduced habitat effectiveness across all 

seasons for female black bears. There is some evidence to suggest that American marten may 

use areas adjacent to forest roads less than interior habitats (Robitaille and Aubry 2000), 

although Mowat (2006) did not detect selection against roads or logging in winter habitat 

associations of marten at a coarse scale.

Various avian species have demonstrated sensitivity to the presence of roads. In selection of 

nest sites, some bird species, including bald eagles (Anthony and Isaacs 1989), golden eagles 

(Fernandez 1993), and sandhill cranes (Norling et al. 1992), avoided areas close to roads. It was 

noted that even light traffic (1-12 vehicles per day) on roads associated with natural gas 

development appeared to alter nesting behavior (nest initiation rates and movement from leks) 

of female sage-grouse (Lyon and Anderson 2003).

Temporary roads present most of the same risks posed by permanent roads, although the 

impacts generally would be of shorter duration. Gated or temporary roads facilitate recreational 

uses such as camping, hiking, mountain biking, and Off-Highway Vehicle (OHV) use that can 

negatively influence elk, deer and bighorn sheep distributions and activities.

Road reconstruction can result in substantial changes in the kinds and amount of human uses in 

an area. For example, improving road surfacing or gradient to provide easy access for low 

clearance vehicles may increase the amount of human disturbance, traffic volume and/or 

speeds, resulting in increased wildlife impacts.

Fragmentation and Connectivity

Roads contribute to fragmentation of habitats in previously intact landscapes (Reed et al. 1996).

As road densities increase, edge habitats increase and interior patches decrease, reducing 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—201

habitat available to species requiring interior habitats. For example, Ortega and Capen (2002) 

noted that densities of forest-interior dwelling birds were significantly lower in forested areas 

adjacent to unpaved roads. Breeding songbirds in sagebrush steppe habitat were less abundant 

(39-60% lower) within 100 m of dirt and gravel roads associated with natural gas extraction than 

in areas beyond this distance (Ingelfinger and Anderson 2004). Although traffic volume could 

have contributed to avoidance of habitats adjacent to roads, the authors suggested that these 

species could also have been responding to edge and fragmentation effects.

In addition to changing configuration and availability of interior habitats, edges created by 

roads can alter environmental conditions within interior habitats bordering roads, such as 

microclimate (e.g., increased temperatures, humidity, exposure to direct sunlight, etc) and 

humidity (Chen et al. 1996, Chen et al. 1993). Such changes may make these areas less 

hospitable to particular species (Marsh and Beckman 2004).

Fragmentation can lead to demographic fluctuations, inbreeding, loss of genetic variability, and 

local population extinctions (USDA Forest Service 2000b, Findlay and Bourdages 2000). Roads 

can function as barriers to movement of species, such as small mammals, reptiles, turtles, snails 

and salamanders (Trombulak and Frissell 2000, Swihart and Slade 1984, Oxley et al. 1974, Marsh 

et al. 2005, Baur and Baur 1990). This can result in substantial amounts of suitable habitat being 

unavailable to these species, as well as fragmenting populations into smaller subpopulations 

through loss of habitat connectivity (Shine et al. 2004). Roads have been shown to act as barriers 

to gene flow in a common frog (Rana temporaria) and can lead to significant genetic 

differentiation among populations (Reh and Seitz 1990). Rico et al. (2007) found that whereas 

individual voles and mice were observed crossing narrow highways, wide highways served as 

a complete barrier to movement, effectively separating populations on either side of the 

highway demographically. Forest fragmentation can increase the risk of local extirpations or 

extinctions (Noss and Cooperrider 1994). 

Refugia (landscapes that are not readily subject to high levels of hunting and frequent human 

disturbance) are necessary for persistence of some wildlife by providing source populations that 

can repopulate adjacent landscapes via dispersal and emigration. Mid- to large-sized carnivores 

characteristically have large home ranges, make long-distance movements, and are particularly 

vulnerable to habitat fragmentation (Ruggiero et al. 1994). Roadless and wilderness areas serve 

a key role in providing refugia.

Spread of Non-Native Invasive Species

The construction of roads creates new edge habitat, and consequently, edge-dwelling species of 

plants and animals can be introduced into forest and grassland environments, adversely 

affecting interior-adapted species. Many non-native plants establish themselves preferentially 

along roadsides and in other disturbed habitats (Trombulak and Frissell 2000, Parendes and 

Jones 2000), as described in the Invasive Plants section. The establishment of these non-natives 

can lead to habitat loss, inter-species competition, loss of quality forage, and lowered 

reproductive success of native wildlife.

Non-native disease organisms also affect native animal species and their habitats. For example, 

local die-offs of boreal toads have occurred in Colorado from infection by the chytrid fungus 

(Batrachochytrium dendrobatidis) (Loeffler 2001). While the environmental factors causing 

susceptibility to this pathogen are not well understood, it is reasonable to assume that increased 

road access could make boreal toad populations more susceptible to exposure to the chytrid 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

202—Chapter 3. Affected Environment and Environmental Consequences

fungus.

Human-Caused Disturbance and Mortality

In general, roads facilitate human access into areas that would otherwise be difficult to reach.

Temporary roads for fuels treatment adjacent to communities would be an exception, as people, 

pets and other disturbances are common. The presence of people can result in both direct and 

indirect impacts, such as increased mortality from traffic collisions and crushing, flight behavior 

and increased physiological stress, increased vulnerability to hunting and recreational shooting, 

and decreased reproductive success.

Winter range is often the primary limiting factor for wild ungulates (such as deer, elk, 

pronghorn antelope, bighorn sheep). Human disturbance during winter months can result in 

displacement and physiological stress that lead to lowered reproduction and survival rates of 

wild ungulates (Freddy 1986, Freddy et al. 1986, Morrison et al. 1995b).

Large numbers of animals are killed annually on roads, including NFS roads. Amphibians and 

reptiles appear to be especially vulnerable to becoming road kill for a variety of reasons 

(Andrews and Gibbons 2005, Mazerolle et al. 2005, Vestjens 1973, USDA Forest Service 2000b).

However, by gating and closing the roads to motor vehicles other than for administrative use, 

the impacts would be minimized.

Effects of Tree-Cutting and Removal Activities

All alternatives have provisions that would allow for tree-cutting for certain purposes. Removal 

of trees to reduce hazardous fuels is the primary reason this would occur within roadless areas 

under all of the alternatives. Tree-cutting may also be allowed to control forest insects and 

pathogens, to maintain or improve habitat for threatened or endangered species, for public 

health and safety, or for removal that is incidental to other purposes.

Activities related to tree-cutting or timber harvesting may include: road construction, 

reconstruction or maintenance; manually felling trees and scattering or piling the slash (small 

trees, tops, and limbs remaining on-site after tree-cutting); and/or use of large machines to do 

the cutting, masticating, chipping and/or piling. In addition, tree-cutting in roadless areas 

would most often be conducted in conjunction with prescribed burning. Typically the smaller 

understory trees (ladder fuels) would be removed and the healthiest dominant trees would be 

retained. All tree-cutting and removal treatments in roadless areas would comply with

applicable forest plan standards and guidelines and other environmental protection 

requirements. 

The effects of tree-cutting and removal activities on wildlife habitats are organized into the 

following categories: habitat availability and effectiveness; habitat fragmentation; spread of 

non-native invasive species; and human-caused disturbance and mortality.

Habitat Quality and Effectiveness

Tree-cutting and removal alters patch sizes, arrangement, tree species composition, and the 

total amount of habitat for terrestrial wildlife species. Vegetation management through treecutting and use of wildfire can have beneficial effects when it is designed to create or maintain 

appropriate forest age-class diversity and habitat mosaics (Wisdom et al. 2000, USDA and USDI 

2001).

In fire-adapted ecosystems where fire suppression has altered plant species composition and 

the spatial arrangement, tree-cutting to reduce fuels is a tool that can be used to improve habitat
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—203

conditions and ecosystem sustainability. Thinning densely stocked conifer stands has been 

found to decrease the abundance of some bird species while favoring others (Hayes et al. 2003).

Reynolds et al. (1992) and Wiens et al. (2006) suggest that forest thinning can be beneficial in 

producing and maintaining the desired conditions to sustain goshawks and their prey species.

Several studies have found that salvage logging reduces diversity and densities of cavitynesting birds, such as the American three-toed (Picoides dorsalis) and black-backed woodpeckers 

(P. arcticus) (Hutto and Gallo 2006, Wesolowski et al. 2005). Decreases in primary cavity nesters 

may be due to either a reduction in food availability (e.g., wood-boring beetle larvae) or 

available nest sites, or both (Hutto and Gallo 2006).

Some species of bats appear to respond favorably to thinning in forested ecosystems if snags or 

caves are available for roosting (Loeb et al. 2002). Patriquin and Barclay (2003) documented 

differential responses of bats depending on species. For example, bat species that glean prey 

from surfaces did not forage in clear-cut plots, whereas aerial foragers frequented areas along 

the forest edges.

Opening the forest canopy can increase the production of food resources – such as acorns and 

berries - for black bears (Mitchell and Powell 2003) and other fructivores. However, thinning in 

spruce-fir forests reduces snowshoe hare populations, in turn negatively affecting Canada lynx 

(Ruediger et al. 2000).

Fragmentation and Connectivity

In terrestrial ecosystems, the edge effect of tree-cutting can extend substantial distances from 

the treated area depending on the type of treatment and extent of change to the forested 

environment. Research over the past two decades has shown that some species thrive at habitat

edges/ecotones, while many interior forest wildlife species are negatively affected by the 

creation of habitat edges by vegetation management practices (or natural disturbances) (Noss 

and Cooperrider 1994). Edge effects include changes in air and soil temperature, wind velocity, 

radiation, and soil and air moisture in the adjacent forest stands (Chen et al. 1995). Furthermore, 

creation of edges due to tree-cutting can favor species such as cowbirds or starlings, which can 

out-compete the indigenous species (Rosenberg et al. 1999, Baker and Lacki 1997, Robinson et 

al. 1995). Whether an effect is realized, and the extent of that effect, are dependent on the 

severity of the forest change (e.g. clearcutting vs. thinning) and species involved. 

As with roads, fragmentation from tree-cutting can create movement barriers to some species, 

which may isolate populations into smaller subpopulations and make them subject to 

inbreeding, loss of genetic variability, and local population extinctions. Amphibian species, 

because of their temporally and spatially dynamic populations, may be especially prone to local 

extinction resulting from human-caused fragmentation (Gibbs 1998). Many amphibian species 

have been found in lower densities in some treatment areas as compared to mature, unmanaged 

forests (DeMaynadier and Hunter, Jr. 1999, DeMaynadier and Hunter, Jr. 1998, Ash 1997, 

Petranka et al. 1993).

Spread of Non-native Invasive Species

Tree-cutting and associated ground-disturbing activities can provide favorable conditions for 

establishment of invasive species. Vegetation removal can also open the canopy and increase 

the sunlight reaching the interior forest floor, accelerating rates of spread of invasive plants.

Introduction and movement of invasive species can also be enhanced by equipment, clothing,
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

204—Chapter 3. Affected Environment and Environmental Consequences

and other human-related transport associated with tree-cutting activities. This may include 

invasive plants, invasive aquatic animals (e.g., zebra mussels) and pathogens (e.g., chytrid 

fungus) that can also have dramatic effects on wildlife.

Human Access and Disturbance

Disturbances associated with tree-cutting activities can displace animals that previously 

occurred on or in proximity to the treatment locations. Felling of trees and snags can destroy the 

nests of birds and squirrels.

Mineral and Oil, Gas or Coal Resource Operations

Although it varies by commodity, surface use associated with the exploration and development 

of leasable minerals requires access, as well as linear construction zones, haul roads, open pits, 

facilities, power lines, pipelines, and communication sites. For example, development of 

geothermal energy would include exploratory drilling (some ground disturbance and access 

roads); if exploratory results are favorable, construction of a well pad and above-ground 

pipelines to a power plant would occur. As with road construction and tree-cutting, mining

operations can remove or degrade habitat, increase fragmentation, facilitate new introductions,

or increase the spread of non-native invasive species, increase disturbance, and increase the 

potential for road-related mortality of wildlife due to collisions and human access.

As alternative 1, 2, and 4 have the same projections for oil and gas development, the magnitude 

of these effects are similar across the alternatives. Alternative 3 projects greater oil and gas 

development; therefore, the magnitude of these effects is greatest under alternative 3. For coal

development, alternatives 2 and 4 have similar projections and the magnitude of these effects is 

expected to be similar. Alternative 3 projects slightly higher projections of future coal 

development; the magnitude of the effects would be greatest among the alternatives. 

Alternative 1 has the least projections for coal development; therefore, the magnitude of these 

effects would be the least among the alternatives.

Linear Construction Zones

The potential effects for the use of linear construction zones are short-term. They are used only 

for the time it takes to install a linear facility and then the disturbed area is reclaimed as 

prescribed in the authorization. The activities differ by alternative and would potentially affect 

wildlife species or habitat. 

Terrestrial Species and Habitat: Environmental Consequences 

All Alternatives

Land management activities in roadless areas often cost more to plan and implement than on 

other NFS lands because these areas can be difficult to access or have not been the focus of past 

management and, therefore, have retained their roadless character. It is unlikely that roadless 

areas would be the primary focus of future land management activities that involve road 

construction, road reconstruction, or tree-cutting because of these logistical constraints. The 

possible exceptions to this generalization are areas that have a high priority for community 

wildfire protection, and areas with mineral, oil, gas or coal resources. Past and projected future 

land management activities in roadless areas have been and are expected to remain relatively 

low, which is reflected in the projected low amounts of road construction and reconstruction 

and tree-cutting for the alternatives.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—205

Alternative 1 – 2001 Roadless Rule 

Under this alternative, about 4.24 million acres of the 14.5 million acres of NFS lands in 

Colorado would be managed to maintain their roadless area characteristics, which would 

benefit a wide range of wildlife species. The prohibitions and permissions on road construction 

and tree-cutting activities in IRAs under this alternative are described in detail in chapter 2. The 

projected amount of new road construction, tree-cutting and linear construction zones expected 

in IRAs over the next 15 years is described in the Analysis Framework section of this chapter. 

Based on the general prohibitions and limitations on road construction, tree-cutting and 

removal, and oil, gas or coal resource operations in IRAs, this alternative would provide the 

highest level of protection to terrestrial wildlife, including T&E species, sensitive species, MIS, 

and migratory bird species, compared to the other three alternatives. This is based on the 

scientific literature previously described, which supports the assumption that areas with low 

road densities, less altered or modified forest vegetation, and lower levels of human activity 

and ground disturbance are generally better for wildlife species and habitat conditions. 

About 11% of the IRA acreage contains existing roads and developments (referred to as 

―substantially altered‖ areas). There are various reasons for this including mapping errors, 

inclusion of areas with oil and gas leases, and the need to provide access to private land 

inholdings. There are currently about 1,260 miles of existing roads within IRAs. Substantially 

altered portions of IRAs would continue to experience higher levels of roads, tree-cutting, and 

human activity than the other portions. Over time, some of the existing roads might be 

decommissioned, but those that allow access to private lands or infrastructure under special use 

permits would likely remain. Not included in the IRAs are 409,500 acres that have been 

identified as roadless and included in the CRAs in alternatives 2 and 4. Under alternative 1, 

these acres are managed according to their respective forest plans and effects are similar to 

those in alternative 3 on these acres. 

New road construction within roadless areas would be very limited, estimated at about 11 

miles/year within the IRAs with another 3 miles/year in the remainder of the analysis area 

under this alternative, primarily related to oil and gas operations under existing leases. Oil and 

gas development under existing leases is equivalent under alternatives 1, 2 and 4. Tree-cutting 

would also occur under very limited circumstances, estimated at about 1,200 acres/year within 

the IRAs and another 1,100 acres/year within the remainder of the analysis area, primarily to 

reduce wildfire hazard. Tree-cutting would primarily focus on protecting human communities, 

but could be used as a tool to enhance habitat for T&E or sensitive species, where ecological

restoration is needed. Forests project three miles/year of linear construction zones within the 

IRAs. Projected linear construction zones are similar in all alternatives except for a slight 

increase in their use under alternative 3. There is no projected development on the acres within 

the IRAs that are currently under ski area permits (6,600 acres) in the next 15 years. 

The road construction and tree-cutting allowed under the exceptions could potentially have 

detrimental effects, as described in the preceding subsection. However, the magnitude of this 

effect likely would be small, since it would be limited to small portions of roadless areas. The 

actual effects on wildlife would depend on the location, timing, duration, and frequency of the 

ground-disturbing activities, which would be designed and conducted in accordance with 

direction in forest plans. 

Limitation of tree-cutting to ―generally small-diameter trees‖ under alternative 1 would help 

maintain larger trees and would provide for more variability in forest structure. The limitations 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

206—Chapter 3. Affected Environment and Environmental Consequences

on the type and extent of tree-cutting under this alternative would make it unlikely that treecutting would measurably increase habitat fragmentation, reduce habitat connectivity, or 

otherwise adversely affect habitat effectiveness for wildlife.

Threatened, Endangered, and Proposed Species 

The Pawnee montane skipper and Mexican spotted owl could benefit from fuels treatments if

they are applied to the appropriate areas and at the proper time of year. It is estimated that tree 

removal may include an average of about 2 acres/year to benefit threatened and endangered

species, for example, by creating fire lines needed to manage prescribed fires. Road construction 

could adversely modify small acreages of critical habitat for these species by removing habitat

from the road prism. Site-specific analysis and design could likely reduce potential impacts to 

these two species.

A review of the IRAs shows that no road construction or tree-cutting activities are expected in 

the IRAs within the planning horizon that contain known populations or habitat for the 

Uncompahgre fritillary butterfly or known populations or habitat for the southwestern willow 

flycatcher. Fuels treatments within a community protection zone are unlikely to impact the 

riparian willow habitat used by the southwestern willow flycatcher.

Lynx habitat occurs within most of the roadless areas, and for a number of those IRAs there is at 

least a low likelihood for some road construction and tree-cutting activities, primarily for the 

purpose of fuels treatments. Those fuels treatments that occur in the spruce-fir habitats used by 

lynx could reduce available snowshoe hare prey, which would adversely affect lynx. Under the 

forest plans as amended by the Southern Rockies Lynx Amendment, those projects would 

consider the recommended management guidance for lynx in their design, and would be 

subject to specific caps on the total acreage of fuels treatments. All forest plans include 

management direction to maintain lynx habitat connectivity, which would remain in effect.

It is anticipated that fuels treatments and associated temporary road construction would occur 

in many of the IRAs that contain the lower-elevation riparian habitats utilized by the Preble‘s 

meadow jumping mouse. It is important to avoid or minimize habitat alteration and 

disturbance during the short period when this species is not hibernating, and to retain down 

logs. These factors would be considered during site-specific project planning. In the long term, 

reducing the risk of uncharacteristically severe wildfires through prescribed fire or mechanical 

treatment would be beneficial for this species. 

Fuels treatments or oil and gas resource development could occur in the lower elevation 

grassland habitat used by the mountain plover. However, habitat for this species likely occurs 

in only one IRA and impacts associated with these activities would be minimal. Prescribed 

burning is generally beneficial for this species.

Overall, based on the very protective guidance that would apply to the 4.24 million acres of 

inventoried roadless areas and the low level and intensity of road construction, tree-cutting, and 

oil and gas development under this alternative, the anticipated effects are mostly beneficial. 

There is potential for minor, local adverse effects to the Southwestern willow flycatcher, 

Mexican spotted owl, Pawnee montane skipper, Canada lynx, Preble‘s meadow jumping 

mouse, and mountain plover, and to designated critical habitat for the Mexican spotted owl and 

Preble‘s meadow jumping mouse. Effects are expected to be wholly beneficial for the 

Uncompahgre fritillary because of the higher degree of certainty of protection of its habitat

under this alternative and the lack of any impacts anticipated in the foreseeable future. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—207

Sensitive Species 

Sensitive species associated with wetland, stream, lake and waterfall habitats are boreal toad, 

northern leopard frog, wood frog, river otter, Great Basin silverspot butterfly, Rocky Mountain 

capshell snail, and black swift. Road construction, in association with existing energy leases,

would have the greatest potential for adverse effects. These effects could include crushing and 

creating movement barriers for the amphibians and the capshell snail, introducing sediment or 

chemicals into aquatic habitats, and providing avenues for the spread of non-native invasives 

and disease organisms. Because of the limited amount of road construction anticipated under 

this alternative, the probability of adverse effects is low.

Sensitive species associated with lower elevation coniferous forests include flammulated owl,

Lewis‘ woodpecker, olive-sided flycatcher, bald eagle, and northern goshawk. Large diameter 

trees and snags are used by these species for nesting, perching, and foraging. These lower 

elevation forests are typically sustained by frequent low-intensity ground fires. Treatment of 

unnaturally heavy fuels could be beneficial to maintaining habitat for these species over time. 

The emphasis on removal of small diameter, rather than large diameter trees would help create 

favorable habitat conditions for these species. The low level of road construction and vegetation 

management under this alternative would have only minor effects on these species.

Sensitive species associated with subalpine conifer forests include boreal owl, three-toed 

woodpecker, American marten, and pygmy shrew. These forests typically have infrequent but 

higher intensity fires, and treatment of fuels is generally not needed to restore natural 

conditions. Large diameter trees, snags, down logs, and moist microclimate are important 

habitat components for these species. Due to the low level of vegetation treatment and road 

construction expected under this alternative, there is a low risk of adverse effects from these 

actions. 

Purple martin is strongly associated with mature aspen stands. Several of the roadless areas 

where this species is known to occur on the Grand Mesa, Uncompahgre and Gunnison National 

Forests and the White River National Forest have existing oil and gas leases and developments 

within them. These leases hold the potential for additional development to occur, which could 

have local adverse effects on this species if its habitat is removed.

The white-tailed ptarmigan inhabits alpine tundra and adjoining subalpine forest where willow 

is present. Most fuels treatments would likely occur at lower elevations, but oil and gas

development could cause impacts, although at a low level under this alternative.

Sensitive species inhabiting cliffs, caves, talus and canyonlands include peregrine falcon, 

bighorn sheep, spotted bat, fringed bat, Townsend‘s big-eared bat, wolverine, and American 

hog-nosed skunk. Overall, only minor disturbances to these species and their habitats would 

occur under this alternative.

Five sensitive species inhabit grassland and meadow habitats: northern harrier, ferruginous 

hawk, loggerhead shrike, and kit fox. These habitats within IRAs would largely be protected, 

but could be impacted by road construction associated with oil, gas or coal development or 

incidental to other management activities. These impacts would likely be minimal and 

localized.

Greater sage-grouse, Gunnison sage-grouse, Columbian sharp-tailed grouse, and Brewer‘s 

sparrow inhabit shrublands dominated by sagebrush. As with the grassland habitats, there 

could be some local impacts on individuals or their habitats, but effects are expected to be 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

208—Chapter 3. Affected Environment and Environmental Consequences

minor under this alternative.

Management Indicator Species

Existing forest plans were developed with an objective to maintain or improve the population 

and habitat trends for MIS. This alternative could result in some positive changes in the 

projected population trends of MIS, and in no case would reduce the probability of maintaining 

viable populations of any species. There is some limited potential for habitat degradation and 

displacement as a result of road construction and other management activities. Due to the lower 

level of development in IRAs, fewer adverse impacts on habitat or species would be expected as 

compared with the other alternatives. Forest plan standards and guidelines would be applied as 

part of project design, in order to meet forest plan objectives for MIS.

Migratory Birds

The Forests would continue to adhere to requirements under the Migratory Bird Treaty Act and 

the Executive Order for protection of migratory birds. Project level design and implementation 

would evaluate potential effects to migratory birds and seek to promote their conservation.

The status and protection of IBAs within roadless areas would remain the same as the existing 

condition. Previous project-level environmental analysis has not identified any major threats to 

those IBAs from roads, road uses, or land use actions that have been authorized in those areas. 

Alternative 2 – Colorado Roadless Rule (Proposed Action)

Under this alternative, about 4.19 million acres would be managed to maintain roadless area 

characteristics, which would benefit a wide range of wildlife species. There are 562,200 acres of 

upper tier under this alternative. There would be little activity on these upper tier acres. The 

prohibitions and exceptions on road construction and tree-cutting activities in CRAs under this 

alternative, including on the upper tier acres, are described in detail in chapter 2. The projected 

amount of new roads and tree-cutting expected in CRAs over the next 15 years is described in 

the Analysis Framework section of this chapter. Under this alternative, the Forest Service would

offer cooperating agency status to the State of Colorado for all proposed projects and planning 

activities to be implemented on lands within Colorado Roadless Areas.

Under this alternative, the roadless inventory would be updated to remove about 458,800 acres 

that have been ―substantially altered‖ (included under alternative 1). This alternative includes

an additional reduction of 8,300 roadless acres that fall within current ski area permit 

boundaries (6,600 acres) or forest plan management areas that have ski area emphasis (1,700 

acres). Forests project no development to occur in these 8,300 acres in the next 15 years under 

any alternative.

About 409,500 acres that meet the roadless criteria would be added to the inventory. The new 

boundaries better meet the intent of roadless area conservation and constitute an improved, 

higher quality portfolio of roadless areas (see letter from CDOW dated October 15, 2009 in the 

administrative record).

The Colorado Roadless Rule proposes exceptions to the prohibition of road construction. Roads 

could only to be constructed if other options were considered but found to be infeasible, and 

any roads constructed would have to be decommissioned and the landscape restored after the 

road is no longer needed. The estimated amount of new road construction under this alternative 

is about 16 miles/year within the CRAs, with an additional 4 miles/year in the remainder of the 

analysis area, of which the majority is needed to access existing oil and gas leases or for coal
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—209

mining operations.

As described previously, road construction and vehicular travel removes and fragments habitat, 

may reduce habitat effectiveness due to avoidance behavior, may increase wildlife mortality, 

and creates opportunities for invasive species introduction, establishment and spread. 

However, fuels treatment roads would only be located within 1⁄2 mile of the community 

boundaries and these areas already experience some degree of human influence.

Under this alternative, the majority of the roads constructed within CRAs would be temporary, 

used only for the permitted activity, and decommissioned immediately after completion of the 

activity. Temporary roads would be available to foot traffic, bicycles, horseback riding, etc. 

which can have negative effects on wildlife. In addition, unauthorized use of closed or restricted 

roads has historically been difficult to control and enforce. Consequently, an assumption of 

minimal impacts from temporary roads may not always hold true. 

Alternative 2 would allow tree-cutting to reduce hazardous fuels and improve forest health, 

and for other incidental removals. The estimated acreage to be treated is about 5,300 acres per 

year within the CRAs to reduce hazardous fuels and about 500 acres per year for other 

purposes, for a total of about 5,800 acres/year within the CRAs. This level of treatment 

constitutes less than 2% of the total acres within CRAs. An additional 1,200 acres per year is 

projected for tree-cutting within the remainder of the analysis area, half of which would be to 

treat hazardous fuels. Less than 100 acres per year is projected within the CRAs to improve 

habitat for threatened or endangered species.

The increased ability to treat acres for forest health and fuels management under alternative 2 

could improve habitats for species that inhabit early seral stages and lower elevation forests 

with frequent low-intensity fire regimes. Removal of diseased, dead, and down materials could 

have negative impacts on primary cavity nesters, although forest plan requirements for 

retention of snags and down logs would help limit negative effects. 

There are three areas are of particular concern for wildlife habitat within the 8,300 acres that 

would be removed from the CRA due to being within current ski area permit boundaries or 

forest plan management areas that have ski area emphasis. These are: Williams Fork IRA/CRA 

(Loveland ski area on Arapaho-Roosevelt NFs), Game Creek IRA/CRA (Vail ski area on White 

River NF), and Porcupine Creek IRA/CRA (Arapaho Basin ski area on White River NF). 

Williams Fork is a critical connecting land bridge for large carnivores and other wide-ranging 

species across I-70 between the north and south parts of the State. Game Creek on the west side 

of Vail is a lynx linkage area (Dowd Junction), deer migration corridor, and elk winter range 

that is experiencing growing recreational use. The Porcupine Creek roadless area provides a 

critical movement area for wildlife between the Arapaho Basin and Keystone ski areas and is 

identified as a lynx linkage area (Loveland Pass linkage). Currently, there is no plan for 

development on any of the 8,300 acres. Any future development within these areas would be 

subject to project-level analysis that would carefully consider impacts on habitat connectivity.

Threatened, Endangered and Proposed Species

As described for alternative 1, the Pawnee montane skipper and Mexican spotted owl could 

benefit from fuels treatments that restore more natural conditions. There is a much higher level 

of tree-cutting allowed and expected to occur under this alternative, although most of the 

treatments would be aimed at reducing fuels surrounding cities and towns. Temporary road 

construction and oil, gas or coal development could remove some habitat and cause 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

210—Chapter 3. Affected Environment and Environmental Consequences

displacement, although site-specific analysis and design would likely reduce those potential 

impacts. 

No road construction or tree-cutting are expected in those CRAs that contain known 

populations or habitat for the Uncompahgre fritillary butterfly. Similarly, for all but one of the 

roadless areas containing habitat for the southwestern willow flycatcher, no road construction 

or tree-cutting are projected to occur. The one exception may be fuels treatments within a 

Community Protection Zone, although such treatments would be unlikely to impact the 

riparian willow habitat used by this species.

Most of the CRAs provide lynx habitat, and there is at least a low likelihood that some road 

construction and tree-cutting activities could occur in a number of those CRAs, primarily for the 

purpose of fuels treatments. Fuels treatments that occur in the spruce-fir habitats used by lynx 

could reduce available snowshoe hare prey, which would adversely affect lynx. However, those 

projects would be subject to the management direction provided in forest plans, as amended by 

the Southern Rockies Lynx Amendment, which includes acreage caps and would limit the 

amount of impact. All forest plans also include management direction to maintain lynx habitat 

connectivity, which would remain in effect.

Under this alternative, some of the lands adjacent to ski areas that are within landscape linkages 

for the Canada lynx, where the forest plan would allow further ski area development, are 

exempted from the roadless prohibitions that would otherwise apply. As discussed under 

alternative 1, only the 1,700 acres that are not currently permitted differ in development 

opportunities under this alternative than alternative 1. The 1,700 acres would require a NEPA

analysis to include the acres in the ski area permit. This elevates the risk to lynx but future 

development would be subject to project-level analysis that would carefully consider impacts 

on habitat connectivity. Additionally, per the Southern Rockies Lynx Amendment, any projects 

would have to be designed in a way that maintains habitat connectivity.

It is anticipated that fuels treatments and associated temporary road construction would occur 

in many of the CRAs that contain Preble‘s meadow jumping mouse habitat. This species is 

vulnerable to habitat alteration and disturbance during the short period when it is not 

hibernating. It is expected that project design would attempt to avoid the low-elevation riparian

habitat of this species, but that may not always be possible. Over the long term, reducing the 

risk of uncharacteristically severe wildfires through prescribed fire or mechanical treatment 

would benefit this species. 

Similarly, temporary road construction could occur in the low-elevation grassland habitat used 

by mountain plover, but there is a low likelihood that this would occur and any impacts would 

be minimal. Prescribed burning is beneficial for this species.

Overall, the level of protection for the 4.19 million acres of roadless areas under the Colorado 

roadless rule is higher than under current forest plan direction, with a generally low level and 

intensity of road construction, tree-cutting, oil and gas development, and ski area development.

The anticipated effects are mostly beneficial, with the potential for some minor impacts to the 

Southwestern willow flycatcher, Mexican spotted owl, Pawnee montane skipper, Canada lynx, 

Preble‘s meadow jumping mouse, and mountain plover, and to designated critical habitat for 

the Mexican spotted owl and Preble‘s meadow jumping mouse. Effects are expected to be 

wholly beneficial for the Uncompahgre fritillary because of the higher degree of certainty of 

protection of its habitat under this alternative and the lack of any impacts anticipated in the 

foreseeable future.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—211

Sensitive Species

The effects from alternative 2 are similar to those described previously for alternative 1, 

although the exceptions allow higher levels of road construction and tree-cutting in areas 

surrounding cities and towns, for coal development, and in the 1,700 acres adjoining certain ski 

areas.

Sensitive species associated with wetland, stream, lake and waterfall habitats are boreal toad, 

northern leopard frog, wood frog, river otter, Great Basin silverspot butterfly, Rocky Mountain 

capshell snail, and black swift. Road construction would have the greatest potential to have 

negative effects on these species and their habitats. Due to the limited circumstances under 

which roads could be constructed, the potential for adverse impacts is low.

As described for alternative 1, fuels treatments within lower elevation conifer forests could have 

long-term benefits to flammulated owl, Lewis‘ woodpecker, olive-sided flycatcher, bald eagle, 

and northern goshawk.

Vegetation treatment and road construction in subalpine forests is expected to occur at a low 

level, and therefore there is a low risk of adverse impacts on boreal owl, three-toed woodpecker, 

American marten, and pygmy shrew. However, there could be local impacts on these species 

from increasing edge effects, fragmentation and invasive species.

Several of the CRAs where the purple martin is known to occur on the Grand Mesa, 

Uncompahgre and Gunnison National Forests and the White River National Forest have

existing oil and gas leases with development. Additional development on existing leases may

have local adverse effects on this species if the activities occur in its aspen habitat, similar to 

alternatives 1, 3 and 4.

The white-tailed ptarmigan inhabits alpine tundra and adjoining subalpine forest where willow 

is present. Most fuels treatments would occur at lower elevations. Future ski area expansion in 

the 8,300 acres, including the 1,700 acres that could allow more development than alternative 1,

could cause some additional impacts; however, there is no projected development on any of the 

8,300 acres within the next 15 years. 

Sensitive species inhabiting cliffs, caves, talus, and canyonlands include peregrine falcon, 

bighorn sheep, spotted bat, fringed bat, Townsend‘s big-eared bat, wolverine, and American 

hog-nosed skunk. Overall, only minor disturbances to these species and their habitats would be 

expected.

Four sensitive species inhabit grassland and meadow habitats: northern harrier, ferruginous 

hawk, loggerhead shrike, and kit fox. These habitats would largely be protected but could be 

impacted by road construction incidental to other management activities. These impacts would 

be minimal and localized.

Sensitive species that inhabit shrublands include greater sage-grouse, Gunnison sage-grouse, 

Columbian sharp-tailed grouse, and Brewer‘s sparrow. Although there could be some local 

impacts on individuals or their habitats, effects are expected to be minor.

Management Indicator Species

Existing forest plans were developed to maintain or improve the population and habitat trends 

for MIS populations. Given the large acreage afforded by roadless protection under this 

alternative, any changes in population trends for MIS would likely be an increase above current 

forest plan projections.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

212—Chapter 3. Affected Environment and Environmental Consequences

Some adverse habitat modifications or species impacts could occur from the exceptions 

allowing temporary roads, tree-cutting activities, and coal resource exploration and 

development, as described previously. For oil and gas development, this risk would be similar 

to alternative 1. The risks are associated with direct habitat loss, reduction in habitat 

effectiveness, fragmentation, increased risk of establishment and spread of invasive species and 

pathogens, and human-caused disturbance and mortality.

Migratory Birds

The Forests would continue to adhere to requirements under the Migratory Bird Treaty Act and 

the Executive Order for protection of migratory birds. Similar to alternative 1, the status and 

protection of important bird areas within roadless areas would not change. There would be no 

increased risk to IBAs existing in roadless areas.

Alternative 3 – Forest Plans (No Action)

The prohibitions and permissions on road construction and tree-cutting activities under this 

alternative are described in detail in chapter 2. The projected amount of new roads and treecutting expected in roadless areas over the next 15 years is described in the Analysis Framework 

section of this chapter. 

Management direction and reasonably foreseeable actions projected under the current forest 

plans are compared with the direction and projections that could occur within the analysis area

under this alternative. This alternative projects the highest level of activity than any of the four 

alternatives. There are 28 miles/year of road construction projected; 16,900 acres/year of treecutting projected; and 4 miles/year of linear construction zones projected. 

The higher levels of road construction and vegetation management under alternative 3 would 

allow direct habitat reduction, disturbance and fragmentation. These would negatively affect 

terrestrial species in the manner described in the general effects discussion. The specific location 

and design of these activities would influence the actual effects and would be addressed at the 

project level.

In contrast to the other alternatives, the roads allowed under the forest plans (alternative 3) may 

be permanent roads. However, based on recent trends on NFS lands in Colorado, it is likely that 

many of the roads would be temporary and closed to public motorized use, and would be 

decommissioned after completion of the activity even under alternative 3. The increased 

mileage of road construction would facilitate recreation uses such as hiking, biking, and 

horseback riding in the backcountry. This increased human disturbance could increase impacts 

to terrestrial species and habitat, as described in the general effects discussion.

The increased flexibility to treat fuels under this alternative would improve habitats for early 

seral species in some areas and in the short term. The projected treatments would be expected to 

reduce the potential for an uncharacteristically severe wildfire. In beetle-killed stands located in 

areas of high importance to T&E and sensitive species, reductions in fuel loading and wildland 

fire hazards could be beneficial due to the expected reduction in fire severity.

The amount of road construction associated with oil, gas, or coal resource exploration and 

development is predicted to be higher under alternative 3 than the other alternatives. In the 

long term, alternative 3 would allow the most impact on IRAs or CRAs as a result of oil, gas, or 

coal development.

Roadless areas within ski area permit boundaries would be managed in accordance with the 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—213

forest plan direction rather than any roadless rule prohibitions or exceptions. Because ski areas 

would be managed under forest plans, alternative 3 would likely have effects similar to 

alternative 2 on lynx habitat connectivity, deer migration corridors, elk winter range, and other 

habitats of concern in those areas. Project planning and design would consider maintaining the 

integrity of wildlife habitats and movement corridors. 

The higher level of anticipated road construction, vegetation management, and other activities 

under alternative 3 could lead to greater impacts on key wildlife habitats. However, the current 

forest plans were designed to ensure that viable populations of wildlife would be maintained 

through time. Project analysis and design would address the location, timing, duration, and 

magnitude of activities to minimize any possible adverse effects. 

Threatened, Endangered, and Proposed Species

Under the existing Pike-San Isabel Forest Plan, current management direction is less restrictive 

than the other three alternatives for all roadless areas where the Pawnee montane skipper, 

mountain plover, and their habitat are known to occur. For the Mexican spotted owl, all of the 

roadless areas on the Pike-San Isabel, GMUG, and San Juan National Forests with known 

occurrences or suitable habitat have less restrictive management direction under those forest 

plans. The management direction on the Arapaho-Roosevelt, Rio Grande, and White River

Forest Plans is generally comparable to or more restrictive than alternatives 1 or 2. These three 

species could benefit from fuels treatments that restore more natural conditions and from the 

use of prescribed fire, if applied to the appropriate areas at the proper time of year. This would 

be allowed in many areas. Road construction could adversely modify small acreages of habitat 

for these species by removing habitat from the road prism. Site-specific analysis and design 

could likely reduce potential impacts to these two species.

A review of the roadless areas that contain known populations or habitat for the Uncompahgre 

fritillary shows a much less restrictive management direction under the current forest plans for 

the GMUG and Pike-San Isabel NFs. Generally comparable management direction is in the 

forest plans for the Rio Grande and White River Forest Plan, compared with the other three

alternatives. Current management direction for the roadless areas containing habitat for the 

southwestern willow flycatcher is generally comparable to the other two alternatives, with less 

restrictive direction in some portions of the roadless areas. Thus, there is a somewhat higher 

potential for adverse impacts on these species under existing forest plans. Again, site-specific 

analysis and design could likely reduce potential impacts to the specific habitats utilized by 

these two species.

Lynx habitat occurs within most of the roadless areas, and for a number of those roadless areas 

there is the potential for some road construction, tree-cutting and other activities under the 

current forest plans. Fuels treatments that occur in the spruce-fir habitats used by lynx could 

reduce available snowshoe hare prey, which would adversely affect lynx. Under the forest 

plans, as amended by the Southern Rockies Lynx Amendment, those projects would consider 

the recommended management guidance for lynx in their design, and would be subject to 

specific caps on the total acreage of fuels treatments. All forest plans also include management 

direction to maintain lynx habitat connectivity, which would remain in effect.

Under the current forest plans, vegetation management and associated road construction could 

occur in many of the roadless areas that contain the lower-elevation riparian habitats utilized by 

the Preble‘s meadow jumping mouse. It is important to avoid or minimize habitat alteration and 

disturbance during the short period when this species is not hibernating. These considerations 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

214—Chapter 3. Affected Environment and Environmental Consequences

would be examined during site-specific project planning. At the same time, reducing the risk of 

uncharacteristically severe wildfires would be beneficial for this species in the long term. 

Overall, based on the activities allowed and projected to occur in roadless areas, alternative 3 is 

not likely to adversely affect any T&E or proposed species. Additionally, alternative 3 would 

not likely result in adverse modification of designated critical habitat for the Mexican spotted 

owl or Preble‘s meadow jumping mouse. However, there is a substantially increased risk of 

negative effects or adverse habitat modification on those forests with older forest plans: the 

GMUG; Pike-San Isabel; Manti-La Sal; and San Juan National Forests.

Sensitive Species

Potential effects on sensitive species would be higher than under the other alternatives, based 

on the increased level of development in roadless areas. As with any of the alternatives, project 

level analysis and design would likely minimize the potential impacts to sensitive species. 

Sensitive species associated with wetland, stream, lake and waterfall habitats are boreal toad, 

northern leopard frog, wood frog, river otter, Great Basin silverspot butterfly, Rocky Mountain 

capshell snail, and black swift. Road construction would have the greatest potential to 

negatively affect these species and their habitats. 

As described for the other alternatives, fuels treatments within lower elevation conifer forests 

could have long-term benefits to flammulated owl, Lewis‘ woodpecker, olive-sided flycatcher, 

bald eagle, and northern goshawk.

Vegetation treatment and road construction in subalpine forests could have local adverse 

impacts on boreal owl, three-toed woodpecker, American marten, and pygmy shrew. These 

impacts would be attributed to the potential for increased edge effects, fragmentation, and 

invasive species associated with the much higher level of development allowed within roadless 

areas.

Several of the CRAs where the purple martin is known to occur on the GMUG National Forests 

and the White River National Forest have existing oil and gas leases with development within 

them. There is potential for additional development to occur, which could have local adverse 

effects on this species if the activities occur in its aspen habitat.

The white-tailed ptarmigan inhabits alpine tundra and adjoining subalpine forest where willow 

is present. There is a higher potential under this alternative for adverse impacts to this species.

Sensitive species inhabiting cliffs, caves, talus, and canyonlands include peregrine falcon, 

bighorn sheep, spotted bat, fringed bat, Townsend‘s big-eared bat, wolverine, and American 

hog-nosed skunk. Overall, only minor disturbances to these species and their habitats would be 

expected.

Four sensitive species inhabit grassland and meadow habitats: northern harrier, ferruginous 

hawk, loggerhead shrike, and kit fox. These habitats could be impacted by road construction 

incidental to other management activities within roadless areas. These impacts would likely be 

minimal and localized.

Sensitive species that inhabit shrublands include greater sage-grouse, Gunnison sage-grouse, 

Columbian sharp-tailed grouse, and Brewer‘s sparrow. The management direction in forest 

plans could result in some local impacts on individuals or their habitats, but project planning 

and design, in accordance with the forest plan, would likely minimize the effects.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—215

Based on the effects this alternative could have on sensitive species and habitats, alternative 3 

may adversely affect individual species but would not likely result in a loss of viability or cause 

a trend toward federal listing of any sensitive species on the national forests in Colorado.

Management Indicator Species

Existing forest plans are designed to maintain or improve the population and habitat trends for 

MIS populations. This alternative would not change current direction, and therefore there 

would not be any changes expected in the habitat or population trends of these species.

Some local adverse habitat modifications or species impacts could occur from road construction 

and reconstruction, tree-cutting activities, and oil, gas or coal resource exploration and 

development, as described previously. The risks are associated with direct habitat loss, 

reduction in habitat effectiveness, fragmentation, increased risk of establishment and spread of 

invasive species and pathogens, and human-caused disturbance and mortality.

Migratory Birds

The status and protection of important bird areas within roadless areas differ under alternative 

3 with respect to one designated IBA. The Alfred M. Bailey Bird Nesting Area IBA occurs within 

the Eagles Nest Wilderness Area but is adjacent to the Maryland Creek Roadless Area on the 

White River National Forest. As described in the Affected Environment section, this IBA 

provides one of the most diverse bird breeding sites in Colorado. Because the actual IBA is 

within the wilderness area outside of the roadless area, this potential impact would not occur 

directly at the IBA location. However, under alternative 3, the Maryland Creek Roadless Area 

may experience some timber management activities because the area would be managed for 

general forest products.

The Forest Service would continue to conserve migratory birds through application of forest 

plan management direction and project planning and design. 

Alternative 4 – Colorado Roadless Rule with Public Proposed Upper Tier

The CRA boundaries are the same as alternative 2, where about 4.19 million acres would be 

managed to maintain roadless area characteristics, which would benefit a wide range of wildlife

species. There are 2,614,200 acres of upper tier within the CRAs; over 2 million more acres than 

alternative 2. The projected amount of new roads and tree-cutting expected in CRAs over the 

next 15 years is described in the Analysis Framework section of this chapter. Under this 

alternative, the Forest Service would offer cooperating agency status to the State of Colorado for 

all proposed projects and planning activities to be implemented on lands within Colorado 

Roadless Areas.

Alternative 4 contains identical prohibitions and exceptions to alternative 2. The difference in 

the projected activities is due to the amount of acres within upper tier. Under this alternative, 

there are 14 miles per year of road construction projected within the CRAs and an additional 4 

miles per year of road construction projected within the remainder of the analysis area. There 

are 1,800 acres per year of tree-cutting projected within the CRAs (1,600 are for hazardous fuels 

treatment). An additional 1,200 acres per year of tree-cutting is projected within the remainder 

of the analysis area (half of which is for hazardous fuels treatment), identical to alternative 2. As 

with alternative 1, less than five acres per year are projected within the CRAs to improve habitat

for threatened or endangered species. The same 3 miles/year of linear construction zones are 

projected within the CRAs as alternative 2. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

216—Chapter 3. Affected Environment and Environmental Consequences

There is an increased ability to treat acres for forest health and fuels management under 

alternative 4 than alternative 1, but much less than alternative 2. These treatments could 

improve habitats for species that inhabit early seral stages and lower elevation forests with 

frequent low-intensity fire regimes. Removal of diseased, dead, and down materials could have 

negative impacts on primary cavity nesters, although forest plan requirements for retention of 

snags and down logs would help limit negative effects. 

Threatened, Endangered, and Proposed Species

As this alternative contains more upper tier acres within Colorado Roadless areas, there is a 

lower risk of adverse effects to threatened, endangered, and proposed species as a result of 

temporary road construction and other resource management activities in these areas. 

However, the removal of the provision allowing tree-cutting, sales, or removal for habitat

improvement of threatened, endangered, or sensitive species in the upper tier may result in a 

higher risk of adverse impacts for the Mexican spotted owl over the long term due to 

uncharacteristically severe wildfires in its lower elevation montane forest habitat. None of the 

CRAs that provide habitat for Pawnee montane skipper are included in the upper tier, so the 

effects are identical to alternative 2 for this species.

Sensitive Species

Alternative 4 would have similar effects to alternative 2. As this alternative contains more upper 

tier acres within the Colorado Roadless areas, there is a lower risk of adverse effects to sensitive 

species in these areas as a result of temporary road construction and other resource 

management activities. However, the removal of the provision allowing tree-cutting, sales, or 

removal for habitat improvement of threatened, endangered, or sensitive species may result in a

higher risk of adverse impacts over the long term. These impacts would be due to 

uncharacteristically severe wildfires in lower elevation montane forests, shrublands and 

grasslands

Management Indicator Species

Given the large acreage afforded roadless protection under this alternative and the upper tier

acres where little if any activity would occur, any changes in population trends for MIS would 

likely be an increase above current forest plan projections.

As this alternative contains more upper tier acres within the CRAs, there is a lower risk of 

adverse effects to management indicator species in these areas due to temporary road

construction and other resource management activities.

Migratory Birds

The Forests would continue to adhere to requirements under the Migratory Bird Treaty Act and 

the Executive Order for protection of migratory birds. Similar to the other alternatives, the 

status and protection of important bird areas within roadless areas would not change.

Terrestrial Species and Habitat: Cumulative Effects 

This cumulative effects analysis considers how other factors might combine with the direct and 

indirect effects of the alternatives just described to have an additive impact. Past, present, and 

reasonably foreseeable future actions were evaluated, including those described in Appendix E, 

Cumulative Effects. 

The effects of projected activities in roadless areas that result in habitat loss or degradation, 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—217

fragmentation, disturbance, and/or increases in invasive species and pathogens were 

previously discussed as potential direct and indirect effects. Those are the effects that may 

combine with effects from other activities or land uses in or adjacent to roadless areas to result 

in a cumulative effect. The following discussion addresses the activities ongoing or expected in 

the next 15 years in the Colorado National Forests especially those adjacent to or potentially 

affecting roadless areas.

Increasing Human Population Growth and Development

Colorado‘s residential population in 2006 was 4.8 million and is expected to be 7.3 million by 

2030 (Colorado DOLA State Demography Office 2007). The increased demands these residents 

will place on the lands surrounding roadless areas will increase the importance of the roadless 

areas to terrestrial and aquatic species. The higher resource demands placed on the land by a 

larger population could also limit options for any future protection of new roadless acres that 

might otherwise be identified. In light of projected future population trends, roadless areas 

would continue to provide some of the best terrestrial and aquatic species habitat in Colorado 

into the future.

The effects of population growth on wildlife are evident in the amount of habitat that has been 

converted to human development or fragmented by it across the State. Residential, commercial 

and industrial developments are built on what used to be open space. Five-acre ranchettes have 

replaced large tracts of private land that used to belong to ranching families. Much of that 

development has occurred in lower elevation areas that have historically provided habitat that 

allowed species, such as bears and ungulates, to prepare for and survive winter. Providing for 

the intact structure and function of the limited low and middle elevation roadless areas with 

these types of high-value, yet limited habitats, is even more important now and into the future. 

This human-associated encroachment has resulted in, and is expected to continue to decrease

habitat availability, decrease habitat effectiveness, increase disturbance, and increase 

fragmentation. 

Colorado‘s Comprehensive Wildlife Conservation Strategy provides a foundation for sustaining 

Colorado‘s wildlife and their habitats (Colorado Department of Natural Resources, Division of 

Wildlife 2006). The strategy provides general directions for wildlife conservation and a stimulus

plan to engage partners in conservation of Colorado‘s wildlife resources. These efforts will 

increase the probability of terrestrial species habitats on non-federal land remaining stable over 

the long term. However, considering the growth rate of the State and the high demand for 

resources available in Colorado, some non-federal lands will continue to experience impacts on 

natural resources from urbanization and development, resource demands (for example, 

minerals), and recreation. Some effects that result in lower habitat quality on non-federal land 

may limit the potential effectiveness of habitat conservation and restoration on federal lands.

Increasing Recreation Demand

The growing population will continue to be drawn to the natural beauty, seclusion, and 

undeveloped nature of roadless areas in Colorado for enjoyment of outdoor recreation pursuits. 

Demand for additional snowmobile, hiking, mountain bike, and cross-country ski trails will 

continue to increase, thereby increasing the use of roadless areas. The trend in mountain bike 

use in particular has greatly increased in the past decade. Habitats and associated animals 

previously secluded and undisturbed now experience an unpredictable human presence. The 

physiological effects of these types of occurrences and impacts on survival have been discussed 

in previous sections. Recreational activities can affect the quality and quantity of habitat, 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

218—Chapter 3. Affected Environment and Environmental Consequences

displace wildlife from core habitats, fragment habitat, and increase the establishment and 

spread of invasive species and pathogens. Thus, increases in recreational use could compound 

the effects of increased road construction and vegetation treatment for many wildlife species.

Increasing Energy Demand

Oil, gas, and coal reserves are among the valuable natural resources found within the roadless 

areas and surrounding lands in Colorado. The national focus on energy independence,

combined with the high demand for energy, has resulted in a surge of exploration and 

development of those resources across the State. Many of the areas where exploration and 

development are occurring also provide valuable wildlife habitat and in some cases this habitat 

is critical to the survival of individuals and populations of species. Although most development 

occurs on non-federal lands, many areas are adjacent or in close proximity to NFS roadless 

areas. Development of non-federal lands displaces animals onto adjacent NFS lands, 

accentuating the need to provide effective habitat that is free from disturbance. The Mamm 

Peak CRA is an example of that situation; the CRA has concentrated gas field development on 

adjacent private and BLM lands in areas important for elk calving and winter range. 

Consequently, the Mamm Peak CRA, which provides very important habitat, is critical to the 

survival of that elk population.

The current interest in wood fiber and biofuels as economical energy sources is anticipated to 

increase, placing additional attention on NFS resources. It can be anticipated that harvesting 

wood fiber to meet increasing demand will increase as technology improves. Tree harvesting, as 

discussed throughout this document, may require road infrastructure, which could result in the 

associated impacts on wildlife discussed previously in this document.

Development of wind energy is another anticipated focus in the effort to become energy 

independent, and national forests are beginning to receive inquiries about tower placement. 

Mortality of migrating bats and a variety of birds by striking wind towers has been documented 

in numerous locations. Like other intrusions into previously undisturbed habitats, these 

structures directly remove habitat and have the potential to modify habitat effectiveness, create 

disturbance, and fragment landscapes, thus adding to the cumulative effect of activities in the 

proposed alternatives. 

Some energy-related activities require pipelines to move the product off and through the 

national forests. Direct loss of habitat and disturbance created during construction may become 

permanent for above-ground structures. Most electrical transmission lines have been 

concentrated along corridors adjacent to roadless areas, rather than going through roadless 

areas.

Cumulative Effects

Based on scientific literature (Stein et al. 2000, Flather et al. 1999, Noss and Cooperrider 1994), it 

is possible to conclude that with or without conservation of roadless areas, biodiversity is at an 

increased risk of adverse cumulative effects from increased population growth and associated 

land uses, land conversions, and non-native species invasions. Maintenance of roadless areas 

characteristics may lessen this risk, at least in the near term (15 years). 

By reducing the level of potential adverse impacts on roadless areas, some of the last relatively 

undisturbed large blocks of land, outside of designated wilderness areas, that contribute to 

species biodiversity would be conserved. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—219

Alternative 1, when combined with other cumulative effects, would be beneficial to 

maintenance of biological diversity, including benefits for species habitats, populations, and 

landscape diversity. Alternative 1 would provide for considerably more secure habitat and 

protection for T&E species, sensitive species, and other terrestrial wildlife than under current 

direction. Conservation of roadless areas will be increasingly important with the growing 

population and pressures on the land in Colorado.

Alternatives 2 and 4, with their exceptions for road construction, tree-cutting, sale or removal, 

and coal development would be less beneficial to biological diversity than alternative 1 when 

combined with other cumulative effects. The upper tier acres under each of these alternatives 

would have almost no road construction or tree-cutting activities. Designating approximately 

4.19 million acres of roadless area would result in a net benefit to T&E species, sensitive species, 

and other terrestrial wildlife. Although substantially altered acres are removed from the 

roadless inventory, an equivalent acreage of areas that are currently roadless would be added. 

Project-level analysis and design would minimize local effects on species. 

Alternative 3, because of less restriction of land use activities in roadless areas, would pose a 

higher risk of affecting biological diversity, species habitats, and populations than the other 

alternatives. However, these effects would not be uniform across forests or roadless areas. As 

previously described, some forest plans place more restrictions than others on road construction 

or tree-cutting activities in some of their roadless areas. For those with forest plans that are less 

restrictive on activities within roadless areas, effects from activities outside the roadless area 

boundary would add to the potential adverse effects described for this alternative. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

220—Chapter 3. Affected Environment and Environmental Consequences

SCENIC QUALITY

Introduction

Scenery with natural-appearing landscapes enhances people‘s lives and benefits society (Driver 

et al. 1991). It is a primary reason that people choose to recreate on NFS lands, and it contributes 

directly to real estate values in neighboring communities and residential areas. Scenic quality is 

based on two definable elements, landscape character and scenic integrity. Landscape character 

defines particular attributes, qualities, and traits of a landscape that give it an image that makes 

it identifiable or unique. Scenic integrity measures the state of naturalness or disturbance 

created by human activities or alteration. Roadless areas inherently have high scenic quality 

because of the lack of human-induced disturbance.

The scenic quality of a forest is not static; it changes over time. To varying degrees, roads, treecutting, insect infestations, and wildland fires all affect the scenic integrity of a landscape. 

Managers may influence the effects of natural events to some extent by managing vegetation 

with silvicultural and fuels treatments. The positive effects on scenic quality resulting from 

reducing the effects of these events may be offset by the negative effects of road construction 

and vegetative treatments. Wildfire events, insect or disease infestations, avalanches, and other 

natural events are considered a part of a landscape‘s natural processes. Such events and 

resultant landscape changes (even if visually unappealing) are consistent with High or Very 

High levels of scenic integrity.

Scenery: Affected Environment

Resource management activities in roadless areas strive to achieve long-term sustainable 

landscape character goals within the scenic integrity objectives identified in the land 

management planning process using the Scenery Management System (SMS) (USDA Forest 

Service 1995b) or with establishment of visual quality objectives using the Visual Management 

System (VMS) (USDA Forest Service 1974). These visual or scenic management objectives define 

allowable levels of change on specific land areas.

The VMS process applies to all management activities on National Forest System lands to set 

visual goals and assist in final management decisions. It provides the groundwork for visual 

assessments that evaluate the visual resources, character types/variety classes, and sensitivity 

levels based on public concerns, and ultimately assigns Visual Quality Objectives (VQO). These 

VQO‘s establish degrees of acceptable alterations to the natural landscape found in various 

management units.

The current basis for describing scenic quality is the SMS, as described in Landscape Aesthetics 

(USDA Forest Service 1995b). This handbook defines a system for inventory and analysis of the 

aesthetic values of NFS lands and replaces the Visual Management System. The analysis 

evaluates how the prohibitions and exceptions for tree-cutting, sale or removal, road 

construction/reconstruction, and discretionary mineral activities would affect the ability to 

maintain or enhance the supply of high scenic quality. 

The SMS identifies landscape character and scenic integrity as the basis for scenic quality. 

Landscape character is the overall visual impression of landscape attributes that provide a 

landscape with an identity and sense of place; it consists of the combination of physical, 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—221

biological, and cultural attributes that make each landscape identifiable and distinct. Similar to 

VQO‘s, Scenic Integrity Objectives (SIO) are the measure of the wholeness or completeness of 

the landscape, including the degree of visual deviation from the landscape character valued by 

constituents. Scenic integrity is a continuum ranging over five levels of integrity from Very 

High to Very Low. Unacceptably Low scenic integrity is not considered an objective. The 

following table shows a cross-walk of the SMS/SIO‘s and the VMS/VQO‘s. 

Table 3-37. Scenic Integrity Objectives and Visual Quality Objectives

Scenic Quality Visual Quality

Very High (Unaltered): refers to landscapes where the 

valued landscape character is intact with only minute, if 

any, deviations. The existing landscape character and 

sense of place is expressed at the highest level.

Preservation: this visual quality objective allows 

ecological changes only. Management activities, except 

for very low visual-impact recreation facilities, are 

prohibited.

High (Appears Unaltered):refers to landscapes where the 

valued landscape character appears intact.

Retention: this visual quality objective provides for 

management activities which are not visually evident.

Moderate (Slightly Altered): refers to landscapes where 

the valued landscape character appears slightly altered. 

Noticeable deviations must remain visually subordinate 

to the landscape character being viewed.

Partial Retention: management activities remain visually 

subordinate to the characteristic landscape when 

managed.

Low (Moderately Altered): refers to landscapes where 

the valued landscape character appears moderately 

altered. Deviations begin to dominate the valued 

landscape but they borrow valued attributes from the 

surrounding landscape.

Modification: management activities may visually 

dominate the original characteristic landscape.

However,, activities of vegetative and land form 

alteration must borrow from the naturally established 

form, line, color or texture and must remain visually 

subordinate to the proposed composition.

Very Low (Heavily Altered): refers to landscapes where 

the valued landscape character appears heavily altered. 

Deviations may strongly dominate the valued landscape.

Maximum Modification: management activities of 

vegetative and landform alterations may dominate the 

characteristics landscape.

Unacceptably Low: where human activities of vegetative 

and landform alterations are excessive and totally 

dominate the natural or natural-appearing landscape 

character.

Unacceptable Modification: overall extent of 

management activities is excessive or poorly related to 

scale of landform and vegetative patterns in the 

characteristic landscape.

The original VMS process was considered a visual ―snap shot in time‖ and established 

acceptable levels of management activities. In comparison, the current SMS process creates a 

visual inventory of acceptable levels of management activities and focuses on future desired 

visual conditions. With the advent of GIS technology, SMS coverage mapping is recorded 

forest-wide. Typically, the transition from the VMS process to the SMS process occurs whenever 

a forest goes through their forest plan revision. Some national forests in Colorado have revised 

forest plans and have converted to the Scenery Management System. Other national forests are 

under the Visual Management System:

Scenery Management System – Arapaho-Roosevelt NFs and Pawnee NGs, GMUG NFs, 

Rio Grande NF, San Juan NF, White River NF

Visual Management System – Pike-San Isabel NFs, Routt NF, Manti-La Sal NF

Roadless areas generally do not carry evidence of management activities and currently have a 

high degree of scenic integrity. The scenic integrity of landscapes in these roadless areas is 

generally High to Very High or Retention to Preservation, which indicates a low level of 

landscape modification due to a lack of high intensity management activities in the past. 

However, some roadless areas have had extensive use, including from ski areas, cattle grazing, 

off-highway vehicles, timber sales, and mining. Therefore, the scenic integrity/objectives have 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

222—Chapter 3. Affected Environment and Environmental Consequences

been modified and the resulting scenic integrity is considered Moderate/Partial Retention to 

Low/Modification. These substantially altered areas in inventoried roadless areas do not meet 

the desired scenic quality conditions for maintaining roadless area characteristics and values in 

inventoried roadless areas.

Scenery: Environmental Consequences

Alternative 1- 2001 Roadless Rule 

The 2001 Roadless Rule is anticipated to maintain high levels of scenic integrity in the roadless 

areas. By maintaining the restrictions or limitations on future road construction or 

reconstruction and tree-cutting activities within IRAs, the scenic quality would remain 

substantially unaltered by future management activities, consistent with High to Very High 

SIOs or Retention to Preservation VQOs.

The 2001 Roadless Rule would allow road construction in limited situations. About 11 miles of 

road construction and reconstruction are projected to occur within the IRAs, along with an 

additional three within the remainder of the analysis area, over the next 15 years under this 

alternative. The majority of these would be temporary roads associated with existing oil and gas

or coal leases. It is anticipated that the amount of change from such new road construction 

would have a negligible change on the current High and Very High scenic integrity in most 

roadless areas. In those few areas where roads are constructed, the scenic integrity could change 

from High to Low or Moderate.

There are existing oil and gas leases within the IRAs, as well as existing coal leases. The 

disturbance in these areas, which includes both road construction and tree-cutting while 

operations are ongoing, can be expected to have an impact on the scenic value. However, as 

areas are reclaimed and roads are removed, the scenic values would increase over time, 

commensurate with the revegetation. 

The 2001 Roadless Rule would allow limited tree-cutting of generally small-diameter material 

for specific purposes within IRAs. About 1,200 acres within the IRAs and an additional 1,100 

acres within the remainder of the analysis area are anticipated to be treated annually over the 

next 15 years. The intensity of change associated with such activities is not expected to create a 

measurable change in scenic integrity, though there could be minor localized effects. The 

magnitude or amount of area per project that would potentially be affected is also considered to 

be relatively minor, typically several hundred acres or less. Vegetation management would 

result in short-term changes in scenic quality. These projected activities would be spread out 

over very large acreages.

Based on the anticipated intensity and magnitude of change from potential vegetation 

management, it is anticipated that most of the current High and Very High scenic integrity 

within all IRAs would be retained.

Retaining the substantially altered areas and developed ski areas inside the roadless areas 

would allow portions of the roadless areas to continue to depart from desired roadless area 

characteristics and values regarding scenic quality.

The acres within the analysis area that are not within the IRAs have been identified by the 

forests as having roadless area characteristics and are most likely have High/Retention and 

Very High/Preservation scenic integrity. Where tree-cutting, sale or removal and road 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—223

construction is projected to occur, the SIO/VQOs could change on those acres from 

High/Retention to Moderate/Partial Retention.

Alternative 2 – Colorado Roadless Rule (Proposed Action)

Under this alternative, limiting human activities in CRAs helps minimize adverse modifications 

to existing scenic quality. Removing the substantially altered areas and developed ski areas 

from the CRAs and redefining the CRA boundaries to include areas with roadless area 

characteristics would increase values regarding scenic quality.

Annually, 16 miles of road construction are projected within the CRAs and an additional four

miles are projected within the remainder of the analysis area. Most of these roads are temporary 

roads, including those temporary roads associated with existing oil and gas development and 

existing and future coal leases within the North Fork coal mining area. All roads would be 

decommissioned following the specific permitted use. It is anticipated that the amount of 

change from such new road construction would have a negligible change on the current High 

and Very High scenic integrity in most roadless areas. In those few areas where roads are 

constructed, the scenic integrity could change from High to Low or Moderate.

There are existing oil and gas leases within the CRAs, as well as existing coal leases. In the 

future, an additional 16,000 acres within the North Fork coal mining area would be available for 

coal leases including road construction. The disturbance in these areas, which includes both 

road construction and tree-cutting while operations are ongoing, can be expected to have an 

impact on the scenic value. However, as areas are reclaimed and roads are removed, the scenic 

values would increase over time, commensurate with the revegetation. 

Limited tree-cutting, sale, or removal is permissible in CRAs, primarily to reduce the wildfire

hazard to at-risk communities or municipal water supply systems. Annually, tree-cutting, sale,

or removal is projected to occur on about 5,800 acres within the CRAs, the majority within the 

CPZ. Forests project an additional 1,200 acres of tree-cutting annually within the remainder of 

the analysis area. Tree-cutting within the CRAs, other than for the purpose of incidental, 

personal, or administrative uses, must maintain or improve one or more of the roadless area 

characteristics over the long-term. 

Tree-cutting could modify scenic integrity at least in the short term, but is assumed to maintain 

at least a Moderate/Partial Retention level of scenic quality. In the long term, SIOs/VQOs 

associated with these tree-cutting treatments would result in High/Retention to Very 

High/Preservation scenic levels. It is likely that tree-cutting would be spread across multiple 

roadless areas across the State, thus reducing the potential change in any one CRA. Also, 

potential effects across CRAs would be moderated because priority treatment of hazardous 

fuels would be concentrated around communities. These treatments would minimize impacts to 

communities by applying SIO and VQO guidelines from forest plans.

Based on the anticipated intensity and magnitude of change from potential vegetation 

management, it is anticipated that most of the current High and Very High scenic integrity 

within all upper tier acres would be retained due to the limited activities allowed.

Removing the substantially altered areas and developed ski areas from the roadless areas 

would allow these areas to be managed according to forest plan direction regarding scenic

quality, which may no longer reflect roadless area characteristics. However, the substantially 

altered acres were specifically removed because they currently do not reflect roadless area 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

224—Chapter 3. Affected Environment and Environmental Consequences

characteristics. The additional CRA acres added to the inventory are mostly High/Retention 

and Very High/Preservation scenic integrity and would be retained as such due to the limited 

activities allowed under alternative 2 over the long term.

Alternative 3 – Forest Plans (No Action)

This alternative would incur the highest risk of increased adverse impacts to existing scenic

quality. This is because this alternative allows for the most additional road construction or 

reconstruction and tree-cutting, sale, or removal activities in IRAs, as defined by individual 

forest plans. Based on the forest plan restrictions on activities within the areas analysis area,

including within the IRAs, combined with topographic or economic constraints, new roads or 

tree-cutting activities would be projected to occur on only a small percentage of the existing 

roadless area acreage. 

Management prescriptions similar to Wilderness/Primitive settings are likely to retain their 

High/Retention to Very High/Preservation SIOs/VQOs because limited activity is permitted to 

occur in these areas. Generally, natural processes dominate. 

Annually within the analysis area, approximately 28 miles of road are projected to be 

constructed or reconstructed. Tree-cutting, sale, or removal is projected to occur on 

approximately 16,900 acres. 

There are existing oil and gas leases within the analysis area, as well as existing coal leases. 

Under this alternative, future leasing can occur. The disturbance in these areas, which includes 

both road construction and tree-cutting, while operations are ongoing, can be expected to have 

an impact on the scenic value. However, as areas are reclaimed and roads are removed, the 

scenic values would increase over time, commensurate with the revegetation. 

Scenic quality could be reduced in areas where road construction/reconstruction occurs. In 

areas with prescriptions similar to the backcountry theme, it is likely that scenic quality would 

not be reduced as much because these prescriptions generally encourage the use of temporary 

roads (short-term impact) and retention of more trees because of wildlife considerations. There 

may be some beneficial effects on scenic quality from silvicultural and fuels treatments that 

reduce the potential magnitude of natural events such as insect infestations and wildland fires. 

Also, potential effects would be moderated because of priority treatment of hazardous fuels 

around communities and by applying SIOs and VQOs guidelines from forest plans.

Alternative 4 – Colorado Roadless Rule with Public Proposed Upper Tier

Under this alternative, limiting human activities in CRAs would help minimize adverse 

modifications to existing scenic quality. Removing the substantially altered areas and 

developed ski areas from the CRAs, and redefining the CRA boundaries to include areas with 

roadless area characteristics would increase values regarding scenic quality.

Annually, 14 miles of road construction are projected within the CRAs and an additional 4 miles 

projected within the remainder of the analysis area. Most of these roads are temporary roads, 

including those temporary roads associated with hazardous fuels treatments, existing oil and

gas leases, and existing and future coal leases within the North Fork coal mining area. All 

would be decommissioned following the specific use. It is anticipated that the amount of change 

from such new road construction would have a negligible change on the current High and Very 

High scenic integrity in most roadless areas. In those few areas where roads are constructed, the 

scenic integrity could change from High to Low or Moderate.

There are existing oil and gas leases within the CRAs, as well as existing coal leases. In the 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—225

future, an additional 16,000 acres within the North Fork coal mining area is available for future 

coal leases including road construction. The disturbance in these areas, which includes both 

road construction and tree-cutting, while operations are ongoing, can be expected to have an 

impact on the scenic value. However, as areas are reclaimed and roads are removed, the scenic 

values would increase over time, commensurate with the revegetation. Those acres within the 

upper tier acres that have existing oil and gas leases would continue to allow development 

according to lease stipulations and may not provide additional scenic quality until after 

operations have been completed and reclaimed.

Limited tree-cutting, sale, or removal is permissible in CRAs, primarily to reduce the wildfire

hazard to at-risk communities or municipal water supply systems. Annually tree-cutting, sale,

or removal is projected to occur on about 1,800 acres within the CRAs, the majority within the 

CPZ. Forests project an additional 1,200 acres of tree-cutting annually within the remainder of 

the analysis area. Tree-cutting within the CRAs, other than for incidental, personal, or 

administrative purposes, must maintain or improve one or more of the roadless area 

characteristics over the long-term and would be limited to those acres outside of the upper tier. 

Tree-cutting outside the upper tier acres could modify scenic integrity at least in the short term, 

but is assumed to maintain at least a Moderate/Partial Retention level of scenic quality. In the 

long term, SIOs/VQOs associated with these tree-cutting treatments would result in 

High/Retention to Very High/Preservation scenic levels. It is likely that tree-cutting would be 

spread across multiple roadless areas across the State, thus reducing the potential change in any 

one CRA. Also, potential effects across CRAs would be moderated because of priority treatment 

of hazardous fuels would be concentrated around communities that are not within the upper 

tier. These treatments would minimize impacts to communities by applying SIO and VQO 

guidelines from forest plans.

Based on the anticipated intensity and magnitude of change from potential vegetation 

management, it is anticipated that the most of the current High and Very High scenic integrity 

within all upper tier acres would be retained due to the limited activities allowed.

Removing the substantially altered areas and developed ski areas from the roadless areas 

allows these areas to be managed according to forest plan direction regarding scenic quality,

which may no longer reflect roadless area characteristics. However, the substantially altered 

acres were specifically removed because they currently do not reflect roadless area 

characteristics. The additional CRA acres added to the inventory are mostly High/Retention 

and Very High/Preservation scenic integrity and would be retained as such due to the limited 

activities allowed under alternative 4 over the long-term.

Scenery: Cumulative Effects

Past actions and events have shaped the current landscape. The current High/Retention to Very 

High/Preservation scenic qualities are a reflection of the low level of active management in 

these areas. It is anticipated that current or planned actions and foreseeable future actions 

would generally retain the current High/Retention to Very High/Preservation scenic quality 

designations with the majority of the CRAs under any alternative.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

226—Chapter 3. Affected Environment and Environmental Consequences

RECREATION

Many definitions of recreation exist, each emphasizing a slightly different aspect of an enjoyable 

pursuit. The basic premise behind recreation is the pleasurable and constructive use of one‘s 

spare time. This sense of refreshment, relaxation, and the active pursuit of pleasure are realized 

through participation in recreational activities suited to individual preference. 

This analysis reviews the possible changes to roadless areas available for dispersed recreation, 

developed recreation, and recreation special uses. The disclosed environmental consequences 

are based on factors such as trends in recreation use; the prohibitions and permissions for treecutting and road construction and reconstruction; and the availability of future roadless areas in 

Colorado to meet growing future demands.

Generally, the recreation characteristics of most roadless areas are either in a Primitive setting, a 

Semi-Primitive Non-Motorized (SPNM) setting, or a Semi-Primitive Motorized (SPM) setting. A 

Primitive setting describes an area with little developed infrastructure that allows nonmotorized uses but may also allow mechanized uses. A SPNM setting describes an area with 

minimal developed infrastructure that allows non-motorized and mechanized use. A SPM 

setting describes an area with minimal developed infrastructure that allows for non-motorized, 

motorized, and mechanized uses. More developed recreational settings, including roads, trail

heads, campgrounds, boat launches, and picnic areas, would be found outside of roadless areas, 

but would allow access to trails into roadless areas.

Dispersed Recreation: Affected Environment

Dispersed recreation is generally associated with activities that do not require constructed 

facilities, except for trails. Non-motorized activities (such as hiking, biking, and backcountry 

skiing) and motorized activities (such as snowmobiling and OHV trails use) best represent 

dispersed recreation. Thus, dispersed recreation is generally associated with the Primitive, 

SPNM, and SPM recreation settings. Roadless areas in Colorado provide opportunities for nonmotorized, motorized, and mechanized dispersed recreation activities, as well as fishing and 

big-game hunting opportunities.

These roadless areas provide settings for dispersed recreational activities that are prohibited in 

designated wilderness areas and not readily available in developed or modified settings with 

system roads. For example, wilderness areas prohibit, with few exceptions, mechanized and 

motorized uses such as OHVs, mountain bikes, and snowmobiles. Within roadless boundaries,

these activities are permitted on designated trails, including current and new trail construction. 

Wheelchair or handicapped access is allowed within wilderness areas, but is expected to be 

very challenging. Depending on the travel management direction for an individual roadless 

area, many trails within roadless areas are open to OHV use for those who are not able to access 

remote areas without motorized assistance.

Four of the top five activities pursued on NFS lands (viewing natural features, general 

relaxation, hiking, and viewing wildlife) are generally associated with dispersed recreation

(USDA Forest Service 2004b). The demand for Primitive, SPNM, and SPM classes and dispersed 

recreation opportunities is increasing (Cordell et al. 1999a and 1999b).
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—227

Dispersed Recreation: Environmental Consequences

All Alternatives

Restrictions or limitations on future road construction or reconstruction and tree-cutting 

activities within roadless areas would maintain existing opportunities for dispersed recreation

in a semi-primitive setting that would be substantially unaltered by future management 

activities.

Travel management decisions made outside this rulemaking process will have an impact on the 

types of motorized and non-motorized use and level of use available within roadless areas 

under any alternative.

Alternative 1- 2001 Roadless Rule 

Alternative 1 prohibits road construction and reconstruction in IRAs except under very limited 

exceptions. The limited road construction and reconstruction exceptions could change the 

dispersed recreation opportunities within a given area. Annually, about 11 miles of road are 

projected to be constructed or reconstructed within the IRA boundaries. In addition, about three

miles are projected to be constructed outside of the IRA boundaries but within the analysis area, 

over the next 15 years. This level of disturbance would not measurably change the dispersed 

recreation opportunities in any given area.

There are currently about 1,260 miles of road within the boundary of the IRAs. Existing road 

density in roadless areas may gradually be reduced over time, as more miles of road would 

likely be decommissioned or obliterated than constructed. Many unauthorized roads would be 

eliminated or naturally disappear. The associated effects would increase the semi-primitive

setting and recreation opportunities from fewer roads in the long-run.

Alternative 1 prohibits tree-cutting, sale or removal, with a few exceptions. Annually, it is 

projected there would be about 1,200 acres of tree-cutting annually within the IRAs. In addition, 

it is projected that there would be about 1,100 acres of tree-cutting outside of the IRA 

boundaries but within the analysis area over the next 15 years. This level of activity would not 

measurably alter roadless area characteristics currently identified, especially over the long-term. 

IRAs would continue to provide habitat for wildlife and fish; therefore, hunting and fishing

opportunities would continue. Retaining the substantially altered areas and developed ski areas 

inside the roadless areas would allow portions of the roadless areas to continue to depart from 

desired roadless area characteristics and values regarding semi-primitive settings. Visitors 

would expect IRAs to be substantially unroaded and undeveloped. Thus, those portions of the 

IRAs would continue to conflict with visitor expectations. 

Alternative 2 –Colorado Roadless Rule (Proposed Action)

Under alternative 2, tree-cutting, sale, or removal and road construction and reconstruction are 

prohibited with specific exceptions. Approximately 16 miles of roads are projected (average 

annual) to be constructed or reconstructed within the CRAs. The majority of roads are 

temporary and associated with fuel treatments within the CPZ, for existing oil and gas leases, 

and within the North Fork Coal mining area for coal removal. An additional 4 miles annually of 

road construction on the substantially altered acres is projected over the next 15 years with most 

of the activity occurring in SPM areas, with lesser amounts in SPNM and Primitive settings in 

roadless areas. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

228—Chapter 3. Affected Environment and Environmental Consequences

This level of road construction and reconstruction could change dispersed recreation

opportunity settings in some areas from a SPM to a more roaded type opportunity; however, 

because the roads are decommissioned and obliterated after use, the change in the type of 

recreation opportunity would be temporary. There are currently 8.5 miles of road within the 

CRAs, with 8.0 miles identified as no longer needed, and the majority of roads projected (16 

miles) would also be decommissioned after use. Those roads remaining on the system are 

generally associated with access to private inholdings and would not be open for public use.

Tree-cutting is projected to occur annually on about 5,800 acres within the CRAs and about 

1,200 acres on the substantially altered acres that are not within the CRAs. Depending on 

whether the tree-cutting occurs as thinning or as removal of dead material, the projected treecutting on 87,000 acres within the CRAs over 15 years may change the natural appearance of 

some areas for a period of time until the area regenerates. A majority of this tree-cutting would 

be done for hazardous fuels management, and would be done within one-half mile to one and 

half miles from at-risk communities in more developed recreation settings. Based on this level 

of tree-cutting, a small percentage of the CRAs would be affected over 15 years. Dispersed 

recreation opportunities would not change as a result of such tree-cutting, but the feeling of 

remoteness may change in some locations for a period of time.

None of these activities would take place in the upper tier acres where roads and tree-cutting 

for fuel treatments is prohibited. So, dispersed recreation in those upper tier acres would not 

likely see any changes due to exceptions.

Hunting and fishing opportunities likely would not change in areas where tree-cutting and 

associated road construction occurs because of the dispersed nature of these activities. Some 

species are likely to thrive in the openings created by the tree-cuttings prior to the recovery of 

vegetative conditions. The use of temporary roads would limit the impact to wildlife and fish

habitat because the roads would be decommissioned as soon as the use is completed. In 

addition, any areas which are in the upper tier would see additional restrictions in activities 

under alternative 2.

Alternative 3 – Forest Plans (No Action)

This alternative would incur the highest risk of change or adverse impacts to the existing semiprimitive recreation setting and opportunities. This is because this alternative allows for the 

most additional road construction or reconstruction, tree-cutting, and discretionary fluid and 

solid mineral activities in roadless areas. However, based on forest plan restrictions on activities 

within the IRAs, together with topographic or economic constraints, new roads or tree-cutting 

activities would be projected to occur on only a small percentage of the existing roadless area 

acreage.

Under existing forest plans, road construction and reconstruction, tree-cutting, and oil, gas, and 

coal activities are generally not permitted on areas with management prescriptions of Primitive, 

SPNM and SPM. Some tree-cutting could occur in the more developed and roaded recreation 

settings but would likely not be done to a degree that would change the roadless character. 

Within the analysis area, approximately 28 miles of road construction is projected to occur 

annually. Tree-cutting is projected to occur on 16,900 acres annually. This level of road 

construction and reconstruction could change dispersed recreation opportunity settings in some 

areas from a SPM to a more roaded setting; however, if roads are decommissioned after use 

then the change would be more temporary in nature. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—229

Depending on the nature of the forest plan prescription, tree-cutting on 253,500 acres over 15 

years may change the natural appearance of some areas for a period of time until the area 

regenerates. The type of cutting would depend whether the fuels treatment need is to thin 

overstocked stands or to remove dead material (see Scenery section). Based on this level of 

cutting, a small percentage of the roadless areas would be affected over 15 years. Dispersed 

recreation opportunities would not change as a result of tree-cutting, but the sense of 

remoteness may change for a period of time. 

Alternative 4 – Colorado Roadless Rule with Public Proposed Upper Tier

Under alternative 4, tree-cutting, sale, or removal and road construction and reconstruction are 

prohibited with specific exceptions. Approximately 14 miles of roads are projected to be 

constructed or reconstructed within the CRAs; the majority of roads are temporary and are 

associated with fuel treatments within the CPZ for existing oil and gas leases, and within the 

North Fork coal mining area for coal development. No new road construction is projected 

within the upper tier acres. An additional four miles of road construction on the substantially 

altered acres is projected over the next 15 years, with most of the activity occurring in SPM 

areas and lesser amounts in SPNM and Primitive settings in roadless areas. 

This level of road construction and reconstruction could change dispersed recreation

opportunity settings in some areas from a SPM to a more roaded type opportunity; however, 

because the roads are decommissioned and obliterated after use, the change in the type of 

recreation opportunity would be temporary. There are currently 8.5 miles of road within the 

CRAs, with 8.0 miles identified as no longer needed and the majority of roads projected (14 

miles annually) would be decommissioned after use. Those roads remaining on the system are 

generally associated with access to private inholdings and would not be open for public use.

Tree-cutting is projected to occur annually on about 1,800 acres within the CRAs and about 

1,200 acres on the substantially altered acres that are not within the CRAs. Depending on 

whether the tree-cutting occurs as thinning or as removal of dead material, the projected treecutting on 27,000 acres within the CRAs over 15 years may change the natural appearance of 

some areas for a period of time until the area regenerates. Based on this level of tree-cutting, a 

small percentage of the CRAs would be affected over 15 years.

A majority of this tree-cutting would be done for hazardous fuels management, and would be 

done within one-half mile to one and half miles from at-risk communities in more developed 

recreation settings outside of the upper tier acres. The acres in the upper tier would remain in 

their current recreation setting, but may create concern for local communities if not being able 

to treat those acres would cause hazards for fire fighters or local people if a fire should occur.

Dispersed recreation opportunities would not change as a result of such tree-cutting, but the 

sense of remoteness may change in a few locations for a period of time. Dispersed recreation in 

those upper tier acres would not likely see any changes due to exceptions.

Hunting and fishing opportunities likely would not change in areas where tree-cutting and 

associated road construction occurs because of the dispersed nature of these activities. Some 

species are likely to thrive in the openings created by the tree-cuttings prior to the recovery of 

vegetative conditions. The use of temporary roads would limit the impact to wildlife and fish

habitat because the roads would be decommissioned as soon as the use is completed.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

230—Chapter 3. Affected Environment and Environmental Consequences

Developed Recreation: Affected Environment

Developed recreation sites are those with constructed facilities, such as campgrounds; picnic or 

day-use sites; trailheads and scenic overlooks with parking areas; interpretive sites; ski areas; 

and visitor centers. Developed recreation sites typically provide semi-primitive motorized, 

roaded natural, rural, and urban Recreation Opportunity Spectrum class opportunities and 

settings. 

While some visitors prefer dispersed recreation opportunities and settings that are farther away 

from the sights and sounds of people and development, others prefer settings that offer more 

developed amenities, such as picnic tables, trash receptacles, roads, parking lots, boat ramps, 

and other built features. 

There are about 1,820 developed recreation sites on NFS lands in Colorado (Region-2 INFRARecreation Facilities database, April 2008). Most of these sites are along roads that provide 

motorized access to the public. None of the roadless areas in Colorado contain developed 

recreation sites, except for portions of developed ski areas. However, access roads, 

campgrounds, and trailheads along the outer boundaries of many of the roadless areas provide 

public services and entry points into the roadless areas. 

Developed Recreation: Environmental Consequences

All Alternatives

The effects on developed recreation opportunities in roadless areas do not substantially differ 

among the alternatives being evaluated in this document. Thus, the effects are described for all 

four alternatives at once. 

Developed sites may be built adjacent to roadless areas in order to facilitate specific demands 

for recreation activities within the area. However, aside from trail construction (motorized and 

non-motorized), developed recreation sites would generally not be constructed within roadless 

areas under alternatives 1, 2 or 4. Under these alternatives, developed recreation sites could be 

developed in the analysis area acreage that is not within the roadless area boundaries for those 

alternatives, depending on forest plan direction or the upper tier restrictions. 

Roads projected to be constructed in a roadless area for the foreseeable uses identified for each 

alternative would not be expected to remain open for public vehicle travel (see Analysis 

Framework). Therefore, there would be no measurable increase in motorized road access for 

recreation opportunities within roadless areas under any alternative. However, under 

alternative 3 there would potentially be additional opportunities for development of 

recreational sites or facilities within IRAs in accordance with forest plan direction. In addition, 

there would potentially be additional opportunities for development of recreational sites or 

facilities within the analysis area for all four alternatives on acreage not within the particular 

alternative‘s roadless area boundaries. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—231

Recreation Special Uses (not including Ski Areas): Affected 

Environment 

Recreation special use authorizations consist of permits, leases, or other written instruments 

that administratively authorize a broad range of commercial recreational activities, both 

motorized and non-motorized, in dispersed and developed recreation settings. Special use 

authorizations, usually permits, are issued for almost every type of outdoor recreational activity 

and facility, and can occur in every ROS class setting, from primitive to urban.

Visitors to national forests frequently turn to tourism providers to facilitate their recreation 

experience, which may come in the form of lodging, rental equipment, or outfitters and guides. 

Recreation special use permits are used by Forest Service managers to authorize commercial 

operators to provide desired services on NFS lands. Generally, aside from existing developed 

sites, little infrastructure is needed for the permitted activity, with the exception of hut systems. 

Those operating under a special use permit help visitors enjoy high quality recreation 

experiences as an extension of the Forest Service‘s mission. These services allow people with 

limited time and skills or experience to safely participate in various activities. 

There are about 1,390 recreation special use permits currently authorized within NFS lands in 

Colorado (Region-2 INFRA-SUA database, April 2008). These permits include outfitters and 

guides for hunting, fishing, rafting, backpacking, sightseeing, jeep tours, day hiking, ATV tours, 

and educational tours, as well as hut systems, educational camps, resorts and lodges, recreation 

events, and other activities. Outfitter and guide permits account for about 75 percent of all the 

recreation special uses on NFS lands in Colorado and a portion occur within roadless areas. 

Recreation Special Uses (not including Ski Areas): Environmental 

Consequences 

All Alternatives

There is little difference among alternatives with respect to recreation special use authorizations 

in roadless areas, because limitations on road construction and tree-cutting under any 

alternative would not be likely to affect the ability to obtain or use a recreation use 

authorization. 

In general, recreation special use permits allow for commercial operations of activities that 

require the use of facilities (such as huts, resorts, shelters) and activities not requiring facilities 

(such as outfitters and guides). Because alternatives 1, 2, and 4 do not allow for road 

construction or reconstruction to facilitate recreation activities within the boundaries of the 

roadless areas, the special use authorizations in IRAs or CRAs would be limited to uses that do 

not need new roads. Under alternative 3 in IRAs and all alternatives in the analysis area acreage 

that would be managed in that alternative under the forest plan direction only, recreation use 

authorizations could include activities facilitated by new roads. Currently, there are no such 

road developments for recreation special uses projected to occur under any alternative. 

Developed Ski Areas: Affected Environment

Developed ski areas are all of the areas authorized under the Ski Area Permit Act of 1986 and 

that have constructed facilities on NFS lands. This analysis evaluates effects of the alternatives 

on developed ski area recreation opportunities and experiences.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

232—Chapter 3. Affected Environment and Environmental Consequences

Ski resorts are one of the major land use authorizations permitted on NFS lands in Colorado. 

Nationally, there are 134 resorts operating on national forests that receive an estimated 30 

million or more skier visits per year (National Ski Areas Association 2009). Colorado has the 

highest number of ski areas under permit on national forests (22 areas listed in Table 3-38) and 

the highest number of annual skier visits on national forests of any state, with 12.56 million 

skier visits for the 2006–07 season. Skiers spend approximately 2.6 billion dollars annually in the 

State, which is one third of annual tourist dollars spent. All ski areas operating under permit on 

National Forest System lands in Colorado have been withdrawn from mineral entry.

Table 3-38 Colorado ski areas on National Forest System lands

Ski area National forest

1 Arapahoe Basin White River

2 Aspen Highlands White River

3 Aspen Mountain White River

4 Beaver Creek White River

5 Breckenridge White River

6 Buttermilk White River

7 Copper Mountain White River

8 Crested Butte Grand Mesa, Uncompahgre, and Gunnison

9 Durango Mountain Resort San Juan

10 Eldora Arapaho-Roosevelt

11 Keystone White River

12 Loveland Arapaho-Roosevelt

13 Monarch Pike- San Isabel

14 Powderhorn Grand Mesa, Uncompahgre, and Gunnison

15 Ski Cooper White River; and Pike-San Isabel

16 Ski Sunlight White River

17 Snowmass White River

18 Steamboat Routt

19 Telluride Grand Mesa, Uncompahgre, and Gunnison

20 Vail White River

21 Winter Park Arapaho-Roosevelt

22 Wolf Creek Rio Grande

Ski areas not listed are not within National Forest System lands, or not operational.

During the 2005–2006 season, the number of skier visits in the United States hit an all-time 

record of 58.8 million visits, up 3.3 percent from the previous season and up two percent from 

the previous record set in 2002–2003 (RRC Associates 2006). With the population growth in 

many of the key western ski states, the rising ski area visitor trend is projected to continue into 

the foreseeable future. 

The settings, experience, and activities usually associated with ski areas are more representative 

of developed settings for recreation opportunities. Some NFS lands adjacent to developed ski 

areas in Colorado are roadless and fall into the semi-primitive non-motorized, or semi-primitive

motorized settings. This means that if ski areas expand into roadless areas, it may affect 

adjacent national forest roadless area characteristics and move these areas into the more 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—233

developed end of the settings in the winter. Summer use in and around ski resorts is also 

growing, which may also push the recreation setting in the summer into the more developed 

end of the spectrum. 

The IRAs and CRAs differ in whether they include ski areas, and those differences are described 

under alternatives 1, 2 and 4 in the Environmental Consequences section. Appendix F contains 

maps showing the ski areas that occur in roadless areas. 

Developed Ski Areas: Environmental Consequences 

All Alternatives

For any project to be authorized within a ski area under any alternative, the project must be 

consistent with the allocation in the existing forest plan direction, have Forest Service 

acceptance of a Master Development Plan, and have completed a site-specific NEPA analysis of 

that specific project. 

Alternative 1 – 2001 Roadless Rule

By maintaining the restrictions on future road construction or reconstruction and tree-cutting, 

sale, or removal activities within IRAs, opportunities for ski area development and expansion of

some ski areas would be limited. In other ski areas this alternative would have no effect on 

developed ski area recreation in the 15-year planning time frame. 

Currently, 6,550 NFS acres are within IRAs and were under a ski area permit prior to the final 

date of this rule. In these areas, road construction and tree-cutting activities are allowed to 

continue according to master ski area plans (see Table 3-39).

Ski areas on NFS lands in Colorado that are not listed here do not contain roadless acres within 

their permit boundary, or are not currently operating. 

In the case of Loveland Ski Area and Durango Mountain Resort, the forest plan allocation for 

the ski area is larger than the existing permit area. Under alternative 1, no road construction or 

reconstruction would occur outside the existing permit boundary established prior to the date 

of this rule; including those areas that have been allocated under forest plans. 

Some people may perceive a conflict in having permitted ski areas available for development 

within IRAs. However, ski area development can occur without road construction. Over-thesnow construction of lift towers can be accomplished in some locations; similarly, tree-cutting, 

sale, or removal can be completed over snow to clear ski trails and runs without the 

construction of roads. Therefore, it is possible that ski area expansion into IRAs under 

alternative 1 may occur without road construction in areas that are not currently under permit.

Under alternative 1, although there would be limitations on future ski area expansion, 

backcountry skiing would continue to be enjoyed by those users who prefer roadless 

opportunities. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

234—Chapter 3. Affected Environment and Environmental Consequences

Table 3-39. Permitted ski area acreage in the IRAs prior to date of Rule

Acres rounded to nearest 10 acres. Totals may not add due to rounding.

Alternative 2 – Colorado Roadless Rule (Proposed Action)

Under this alternative, ski areas that are permitted or allocated by forest plans are not included 

within CRAs boundaries. Therefore, road construction or reconstruction and tree-cutting, sale,

or removal in those ski areas (outside CRAs) would be allowed as prescribed in the forest plans, 

ski area master plans, and project-level NEPA documents. The ski resorts and their associated 

roadless acres are displayed in Table 3-40. Individual maps comparing permit and allocation 

boundaries with IRA and CRA boundaries are also available in Appendix F of this document.

In the future, if the Forest Service authorizes a ski permit boundary to expand into a CRA, road 

construction could not occur on those CRA acres. However, like alternative 1, ski area

development could occur without road construction. It would be permissible to cut trees where 

incidental to the implementation of a permitted ski area management activity not otherwise 

prohibited in a CRA, such as to create a new ski run. Such ski area expansions without road 

construction could take place in upper tier acres as well as in regular CRA acres.

National Forest

Ski Area(s) Roadless Area(s)

Total Ski Area 

Acres Permitted 

prior to date of rule

Arapaho-Roosevelt National Forests

Loveland Bard Creek, Mount Sniktau 1,370

Winter Park Vasquez Adjacent Area 30

Grand Mesa, Uncompahgre, and Gunnison National Forests

Crested Butte Gothic 900

Pike-San Isabel National Forests

Ski Cooper Mad Creek DB & DB1 560

Routt National Forest

Steamboat Springs Long Park 180

White River National Forest

Arapahoe Basin Porcupine Peak 1,050

Aspen Mountain McFarlane 50

Beaver Creek Meadow Mountain A, B 510

Breckenridge Tenmile 150

Buttermilk Burnt Mountain 50

Copper Mountain Ptarmigan Hill 720

Snowmass Burnt Mountain 80

Vail Game Creek 900

TOTAL 6,550
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—235

Table 3-40. Ski area acreage in the IRAs but not included in CRAs

National Forest

Ski Area(s) 1 Colorado Roadless Area(s)

Ski Area 

Permitted

Acres 2

Additional 

Ski Area 

Allocation 

Acres3

Total Ski 

Area Acres 

Excluded 

from CRAs

Arapaho-Roosevelt National Forests

Grand Mesa, Uncompahgre, and Gunnison National Forests

Pike-San Isabel National Forests

Routt National Forest

San Juan National Forest (Draft Revised Forest Plan)

White River National Forest

TOTAL 6,550 1,710 8,260

Acres rounded to nearest 10 acres. Totals may not add due to rounding.

1Not all ski areas on NFS lands in Colorado are listed here because they either do not contain roadless acres within their permit 

or allocation boundary or are not currently operating.

2

Ski area permit acres within IRAs where permit acres authorized prior to [effective date of Colorado Rule].

3Acres allocated in forest plans to ski area management that adjoin permitted ski areas but are outside the current permit 

boundary.

Note: Expansion of Durango Mountain Resort is included within the draft revised forest plan for San Juan National Forest, draft 

preferred alternative. There are 90 IRA acres that would be excluded from the CRA acres.

The ski areas listed in Table 3-40 could have some increase in development of ski area facilities 

under alternative 2, because of the number of ski areas outside CRAs where road construction 

and tree-cutting, sale, and removal would be governed by forest plan direction. As areas 

allocated under a forest plan are not included within the CRA boundaries, there is potential for 

further development and expansion, compared to alternative 1, of an additional 1,710 acres. 

Alternative 2 would have a positive impact on the developed ski area recreation resource by 

removing some of the limitations to constructing ski area facilities imposed by the inability to 

construct roads and cut trees. Additionally, the authorization of roads in developed ski areas 

Loveland Bard Creek, Mount Sniktau 1,370 1,620 2,990

Winter Park Vasquez Adjacent Area 30 0 30

Crested Butte Gothic 900 0 900

Ski Cooper Mad Creek DB & DB1 560 0 560

Steamboat Springs Long Park 180 0 180

Durango Mountain Resort San Miguel 0 903 904

Arapahoe Basin Porcupine Peak 1,050 0 1,050

Aspen Mt McFarlane 50 0 50

Beaver Creek Meadow Mountain A, B 510 0 510

Breckenridge Tenmile 150 0 150

Buttermilk Burnt Mountain 50 0 50

Copper Mountain Ptarmigan Hill 720 0 720

Snowmass Burnt Mountain 80 0 80

Vail Game Creek 900 0 900
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

236—Chapter 3. Affected Environment and Environmental Consequences

would facilitate the implementation of required ski area vegetation management plans to 

improve forest health, remove hazard trees, and manage fuel hazards associated with the 

current mountain pine beetle epidemic affecting lodgepole pine within developed ski areas. 

This potential increase in road construction and tree removal is not certain. 

If road construction and tree removal are authorized in these developed ski areas and a decision 

is made to expand the permit boundary at Durango Mountain Resort and Loveland Ski Area, 

there would likely be a change of the ROS from semi-primitive non-motorized to semi-primitive

motorized or roaded natural within those areas. Such a project would require a subsequent 

NEPA environmental analysis.

Alternative 3 – Forest Plans (No Action)

The 8,300 acres within existing permitted ski area boundaries and those areas allocated in forest 

plans to ski area management would be managed the same in this alternative as in alternatives 

2 and 4 because they have been excluded from CRAs. Future development of these acres 

would require additional NEPA environmental analysis. 

This alternative would allow additional ski area expansion or development needing road 

construction in the analysis area. This would not be allowed under alternatives 1, 2 and 4 if the 

proposed development is within the alternatives‘ roadless areas. 

Alternative 4 – Colorado Roadless Rule with Public Proposed Upper Tier

The effects for alternative 4 are the same as described under alternative 2. This is due to the fact 

that the permitted ski area acres are removed from Colorado Roadless Areas. In the upper tier, 

including the expanded upper tier, ski area expansion could occur without road construction.

Recreation: Cumulative Effects

Generally, the most popular forms of outdoor recreation are activities that can be enjoyed 

without traveling far from home, do not require the purchase of additional gear, and do not 

require specialized skills to enjoy (Cordell and Overdevest 2001). The outdoor recreation 

activities with the highest growth in the past 20 years nationally include birding, day hiking, 

backpacking, snowmobiling, outdoor concerts/plays, walking for pleasure, camping in 

developed sites, canoeing or kayaking, running or jogging, downhill skiing, and swimming in 

natural waters (Cordell et al. 2004). These activities generally take place at developed recreation

facilities or require a constructed road or trail to facilitate the activity. It is expected that 

regardless of the activity, participation in outdoor recreation would continue to increase on 

public lands (Cordell et al. 2004).
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—237

WILDERNESS

In 1964, Congress established the National Wilderness Preservation System, composed of 

federally owned areas designated by Congress as ―wilderness areas‖ (P.L. 88-577). A wilderness 

is recognized as an area ―where the earth and its community of life are untrammeled by man, 

where man himself is a visitor who does not remain.‖ Wilderness areas generally appear to be 

affected by the forces of nature; have opportunities for primitive and unconfined recreation; are 

of sufficient size (typically greater than 5,000 acres) to be managed as wilderness; and contain 

other ecological, geological, scientific, educational, scenic, or historical values. Wilderness areas 

are managed to protect natural conditions and primeval character; motorized equipment and 

transport, development, and commercial enterprise are prohibited.

As part of the forest planning process, potential wilderness areas are identified (FSH 1909.12, 

chapter 70) using a three-step process: (1) identifying lands that satisfy the definition of 

wilderness found in section 2c of the 1964 Wilderness Act; (2) evaluating lands as to their 

wilderness potential; and (3) reviewing and approving wilderness recommendations. Generally, 

inventoried roadless areas serve as the pool for potential wilderness areas. 

This analysis evaluates the effects from the prohibitions on designated wilderness, 

recommended wilderness, and wilderness characteristics. 

Wilderness: Affected Environment 

The National Wilderness Preservation System was established in 1964 to preserve and protect a 

portion of the undeveloped Federal lands in their natural condition. Across the United States 

there are more than 110 million acres designated as wilderness within approximately 760 areas. 

There are a total of 36 designated wilderness areas in Colorado comprising 3,200,000 acres 

(Table 3-41). Congress has the sole authority to designate wilderness.

Wilderness character is often used to describe a wilderness area. Wilderness character is defined 

as untrammeled, natural, undeveloped, and having opportunities for solitude or primitive and 

unconfined recreation (Landres et al. 2005).

As defined in Landres et al. (2005), untrammeled means wilderness is essentially unhindered 

and free from modern human control or manipulation. Natural means wilderness ecological

systems are substantially free from the effects of modern civilization. Undeveloped means 

wilderness is essentially without permanent improvements or modern human occupation. 

Outstanding opportunities for solitude or a primitive and unconfined type of recreation means 

wilderness provides outstanding opportunities for people to experience solitude or primitive 

and unconfined recreation, including the values of inspiration and physical and mental 

challenge. These attributes are used to measure the potential consequences of the prohibitions 

of each alternative on the wilderness resource. However, the Wilderness Act does not constrain 

projects proposed adjacent to wilderness boundaries because of the mere presence of 

wilderness. The effects from projects adjacent to wilderness areas should not be the sole reason 

for deferring or declining a project proposal. 

Table 3-41 lists the existing wilderness areas in Colorado, as well as their size and the year they 

were established. Several of the wilderness areas have been enlarged by subsequent wilderness 

legislation. Information regarding the year individual legislation establishing the wilderness 

areas follows the table. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

238—Chapter 3. Affected Environment and Environmental Consequences

Table 3-41. Existing Wilderness Areas in Colorado (acres are rounded to nearest thousand)

Wilderness Acres Year Created

Buffalo Peaks 43,000 1993

Byers Peak 8,000 1993

Cache La Poudre 9,000 1980

Collegiate Peaks 167,000 1980

Comanche Peak 67,000 1980

Eagles Nest 133,000 1976

Flat Tops 235,000 1975

Fossil Ridge 33,000 1993

Greenhorn Mountain 22,000 1993

Holy Cross 123,000 1980

Hunter-Fryingpan 82,000 1978

Indian Peaks 78,000 1978

James Peak 14,000 2002

La Garita 129,000 1964

Lizard Head 42,000 1980

Lost Creek 120,000 1980

Maroon Bells-Snowmass 181,000 1964

Mount Evans 75,000 1980

Mount Massive 28,000 1980

Mount Sneffels 17,000 1980

Mount Zirkel 160,000 1964

Neota 10,000 1980

Never Summer 21,000 1980

Platte River 743 1984

Powderhorn 14,000 1993

Ptarmigan Peak 13,000 1993

Raggeds 65,000 1980

Rawah 73,000 1964

Sangre de Cristo 227,000 1993

Sarvis Creek 45,000 1993

South San Juan 159,000 1980

Spanish Peaks 19,000 2000

Uncompahgre 100,000 1980

Vasquez Peak 13,000 1993

Weminuche 489,000 1975

West Elk 176,000 1964

TOTAL 3,200,000

Five Colorado wildernesses were established with the signing of the Wilderness Act of 1964 

(P.L. 88-577); La Garita, Maroon Bells-Snowmass, Mt. Zirkel, Rawah and West Elk 

Wildernesses. Since 1964, several subsequent stand-alone Wilderness Acts and two State-wide 

Wilderness Acts have been enacted. In the 1980s, the Colorado Wilderness Act established 15 

new wilderness areas (P.L. 96-560) and the 1993 Colorado Wilderness Act enlarged many of the 

existing wildernesses and added 12 new wilderness areas (P.L. 103-77). In 2009, the Omnibus 

Public Lands Act was signed into law, which enlarged the Indian Peaks Wilderness by 1,000 

acres.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—239

Wilderness: Environmental Consequences 

All Alternatives 

Effects on designated wilderness areas depend on the prohibitions and exceptions for treecutting and road construction and reconstruction that could affect one of the wilderness 

attributes: untrammeled, natural, undeveloped, opportunities for solitude, or opportunities for 

primitive and unconfined recreation. None of the alternatives would directly affect existing 

wilderness because the management direction would not apply to designated wilderness areas.

Therefore, there would be no effects on the untrammeled, natural, undeveloped, or primitive 

and unconfined recreation opportunities within a wilderness area. However, activities 

permitted in roadless areas contiguous or adjacent to designated wilderness could affect 

opportunities for solitude and could affect the scenery as viewed from a wilderness area. The 

degree of effect would depend on the frequency, duration, extent, and type of activity that 

occurs.

All alternatives may have direct affects on wilderness character attributes, especially solitude 

and scenic values, and the ability for roadless areas to be recommended wilderness designation 

in the future. Roadless areas are the reservoir of undeveloped lands from which future 

wilderness designations are considered. Each roadless area is evaluated during the forest 

planning process to determine if it provides wilderness characteristics and whether or not it 

should be recommended for wilderness. Areas not recommended for wilderness could still be 

considered for wilderness by Congress. Impacts on the area‘s inherent wilderness character, its 

undeveloped nature, its naturalness, its natural ecosystem forces, and the opportunity to 

provide primitive and unconfined recreation would detract from future consideration of the 

area as wilderness.

Alternative 1 – 2001 Roadless Rule

In general, alternative 1 prohibits tree-cutting and road construction in IRAs and therefore, 

reduces the potential risk of impacts to adjacent wilderness areas. Where tree-cutting or road 

construction is permitted under exceptions near or adjacent to existing wilderness, there may be 

effects on wilderness depending on the scenic value of view-shed, distance from wilderness 

boundary, and natural drainage. Such activities would impact any future recommendations for 

wilderness areas. 

Those unroaded acres not included as IRAs would continue to be managed according to their 

respective forest plan direction. In some cases, that would be consistent with protecting 

wilderness character, but in others, activities including road construction and tree-cutting may 

be allowed. Appendix B provides a summary of the management of the unroaded acres under 

alternative 1.

Alternative 2 – Colorado Roadless Rule (Proposed Action)

In general, alternative 2 prohibits tree-cutting, road construction, and LCZs in CRAs, reducing 

the risk of impacts to adjacent Wilderness areas. Where tree-cutting or road construction is 

permitted under exceptions near or adjacent to existing wilderness, there may be effects on 

wilderness depending on the scenic value of view-shed, distance from wilderness boundary, 

and natural drainage. Such activities, especially those within a CPZ and those associated with 

coal activity, could impact future recommendations for specific wilderness areas. Activities 

within the CPZ may impact areas adjacent to Wilderness areas, affecting scenery and noise of 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

240—Chapter 3. Affected Environment and Environmental Consequences

those traveling within the Wilderness.

Those unroaded acres that are not included as IRAs but are included as CRA would be 

managed as roadless areas in alternative 2, and are likely to be more consistent with future 

wilderness designation than general forest plan direction.

For those acres included as upper tier in alternative 2, they would also be more consistent with 

future wilderness designation than either alternative 1 direction or general Colorado Rule 

direction due to the additional restrictions on activities. 

Alternative 3 –Forest Plans (No Action)

In general, alternative 3 allows more tree-cutting and road construction than alternatives 1, 2 or 

4, reducing potential wilderness eligibility on the impacted acres.

Alternative 4 – Colorado Roadless Rule with Public Proposed Upper Tier

In general, alternative 4 would preserve potential wilderness eligibility more than alternatives 

2, and 3 due to the amount of upper tier acres. 

Wilderness: Cumulative Effects 

All alternatives may compromise wilderness character and the untrammeled attribute of 

wilderness from (1) overall increased population growth to the State of Colorado, (2) increased 

highway and secondary roads allowing more vehicular traffic to areas near existing 

wildernesses, and (3) adjacent private lands that may be developed in the future and (4) 

increased recreation use in the nearby wildernesses.

Alternative 3 would potentially allow more roads for oil and gas leases. In addition, NFS lands

outside the analysis area and non-NFS lands may have increased road construction for oil and 

gas activities in the future. If so, these lands may have a cumulative effect on wilderness and 

roadless areas nearby.

Colorado Roadless Areas are managed under a variety of management prescriptions in existing

forest plans. Implementation of the 2001 Roadless Rule or the Colorado Roadless Rule would 

help establish a uniform approach to managing these areas. Because many Colorado Roadless 

Areas are adjacent to wilderness areas, large tracts of land would remain essentially unroaded 

and undeveloped. In the past, roadless areas were managed as a bank for future resource 

development or special designation. If these areas were managed for their own inherent values, 

there could be less pressure to designate these lands as wilderness or as other special 

designations to shield the land from development. The Colorado Roadless Rule may reduce 

controversy and result in more stability by recognizing those roadless areas with important 

wilderness character and those portions of roadless areas where multiple types of recreational 

use could occur.

RECOMMENDED WILDERNESS AREAS

Recommended Wilderness: Affected Environment

Recommended wilderness areas are lands identified as having undeveloped character and 

wilderness potential through forest planning. During forest planning, the current undeveloped 

lands within a forest are assessed using the three-step process to determine if they should be 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—241

recommended to Congress for the inclusion in the National Wilderness Preservation System. 

Recommended wilderness areas are managed to maintain wilderness character and values until 

such time as Congress acts upon the Agency recommendation or a different Agency 

recommendation is made. Roadless areas that are recommended for wilderness have 

management prescriptions that protect the wilderness character of the area, but these areas are 

not managed as wilderness. 

Table 3-42 identifies the currently recommended wilderness areas in Colorado by existing forest 

plan direction. Several of the older forest plans have no recommended wilderness acres because 

congressional actions have added those areas to the Colorado Wilderness system. In the future, 

when these forest plans are revised, additional recommended wilderness acres will likely be 

identified.

Table 3-42. Acres of Recommended Wilderness

Recommended Wilderness by National Forest Acres Year of Current

Forest Plan

Arapaho-Roosevelt 1997

GMUG 1983

Manti-La Sal

Pike-San Isabel 1984

Rio Grande 1996

Routt 1998

San Juan 1993

White River 2002

Total Recommended Wilderness Acres in Colorado 87,500

Acres are rounded to the nearest thousand acres.

Comanche Peak Adjacent Area Unit D 1,000

Comanche Peak Adjacent Area Unit F 1,000

Comanche Peak Adjacent Area Unit G 3,000

Mount Evans Adjacent Area Unit A 500

No recommended wilderness 0

No recommended wilderness in Colorado 0

No recommended wilderness

No recommended wilderness 0

No recommended wilderness

No recommended wilderness 0

Assignation Ridge 12,000

Eagles Nest - addition 1,000

Flattops - addition 2,000

Holy Cross - addition 8,000

Hunter Fryingpan - addition 4,000

Ptarmigan Peak - addition 3,000

Raggeds - addition 2,000

Red Table 50,000
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

242—Chapter 3. Affected Environment and Environmental Consequences

Recommended Wilderness: Environmental Consequences

Alternative 1 - 2001 Roadless Rule 

Under the exceptions permitted by alternative 1, road construction and reconstruction and treecutting could occur in areas recommended for wilderness through specific project planning or 

the forest planning process. However, this is unlikely to happen as existing plans generally 

exclude tree-cutting and road construction activities in recommended wilderness, unless a sitespecific amendment was completed. Alternative 1 would not directly affect any of the 

recommendations made in forest plans for recommended wilderness areas.

Alternative 2 - Colorado Roadless Rule (Proposed Action)

Roadless areas are managed under a variety of management prescriptions in existing forest 

plans. Implementation of alternative 2 with all 562,200 upper tier acres would help establish a 

uniform approach to managing areas already identified in forest plans and draft forest plans as 

being recommended for wilderness. Any changes to that direction would require a rule-making 

effort.

Alternative 3 - Forest Plans (No Action)

Under the existing plans, about 87,500 acres are recommended for wilderness (table 3- 43). 

Areas recommended for wilderness would be managed to protect and preserve existing 

wilderness character. Hence, they prohibit road construction and reconstruction, tree-cutting, or 

discretionary mineral activities. Recommendations for wilderness designation would be 

reviewed during the next round of forest planning, typically every 10 to 15 years.

Alternative 4 - Colorado Roadless Rule with Public Proposed Upper Tier 

Roadless areas are managed under a variety of management prescriptions in existing forest 

plans. Implementation of alternative 4 with 2.6 million acres in the upper tier would establish a 

uniform approach to managing over half the CRA acres. Any changes to that direction would 

require a rule-making effort. 

Recommended Wilderness: Cumulative Effects 

During future forest planning, roadless lands would be reexamined and evaluated for their 

wilderness potential. To the extent that these lands are not affected by development activities, 

they will be available for future consideration as wilderness. Because of the limited expected 

development activities across all alternatives in the next 15 years, a majority of the roadless 

areas should continue to exhibit wilderness characteristics into the future.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—243

OTHER DESIGNATED AREAS

Congressionally Designated Protection Areas – Affected Environment

In addition to existing wilderness and Forest Plan recommended wilderness, six 

Congressionally Designated Protection Areas (CDPAs) have been established on three forests in 

Colorado by the 1980 and 1993 Colorado Wilderness Acts and the James Peak Wilderness and 

Protection Area Act of 2002 (P.L. 107-216). The CDPAs total 165,000 acres (see Table 3-43). Each 

protected area has special provisions in legislative language that clarifies specific management, 

as outlined in Table 3-44. Five of the six CDPAs in Colorado prohibit tree-cutting and road 

construction; James Peak Protection Area allows tree-cutting for limited purposes.

Table 3-43. Congressionally Designated Protection Areas in Colorado

National 

Forest

Congressionally Designated 

Protection Areas

Date and 

Public Law Acres Special Provision

ArapahoRoosevelt

Bowen Gulch Protection Area 1993, 

Public Law 

103-77 

10,700 Prohibits timber harvesting (sec 6(d)), 

new road building (sec 6(f)) and 

withdrawal of mineral entry (sec 6(c)).

Allows motorized travel on established 

routes (sec. 6(g)) during periods of 

adequate snow cover. Mechanized 

travel shall be permitted (sec. 6(f)).

ArapahoRoosevelt

James Peak Protection Area 2002, 

Public Law 

107-216 

16,000 Allows for timber cutting for fuel

treatment, control of fire, and insect 

and disease control projects. No road 

building is allowed.

GMUG Fossil Ridge Recreation 

Management Area 

1993, 

Public Law 

103-77 

39,800 Prohibits timber harvesting (sec 5(d)), 

new road building (sec 5(f)) and 

withdrawal of mineral entry (sec 5(c)).

Allows motorized travel on established 

routes (sec. 5(g)). 

GMUG Tabeguache Area 1993, 

Public Law 

103-77 

17,000 Prohibits timber cutting or road 

building. Withdrawal of mineral entry 

(sec. 9(b)), managed to maintain 

presently existing wilderness character 

and potential inclusion in the National 

Wilderness Preservation System (sec. 

9(3)).

GMUG Roubideau Area 1993, 

Public Law 

103-77 

20,000 Prohibits timber cutting or road 

building. Withdrawal of mineral entry 

(sec. 9(b)), managed to maintain 

presently existing wilderness character 

and potential inclusion in the National 

Wilderness Preservation System (sec. 

9(3)).

San Juan Piedra Area 1993,

Public Law 

103-77 

63,000 Prohibits timber cutting or road 

building. Allows motorized use 

(snowmobiles) and motorized trail

maintenance on Trail 535 (sec. 9(4)).
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

244—Chapter 3. Affected Environment and Environmental Consequences

Congressionally Designated Protection Areas — Environmental 

Consequences 

All Alternatives

Similar to the congressionally designated wilderness areas, the CDPAs are not included in 

roadless areas being analyzed in this EIS. There would be no difference in management of these 

CDPAs under any of the alternatives as none of the alternatives would directly affect any 

CDPAs.

However, there could be indirect effects of the projected activities that vary by alternative on 

the characteristics in adjacent CDPAs. These effects would be similar to the effects of each 

alternative on adjacent wilderness. The main difference is that the Fossil Ridge Recreation Area, 

James Peak Protection Area, and Bowen Gulch Protection Area allow some motorized and 

mechanized travel and some other activities. Thus, increases in noise and human activities in 

adjacent roadless areas would not be expected to significantly detract from the values for which 

those areas were designated. The other three CDPAs, the Tabeguache Area, the Roubideau 

Area, and the Piedra Area are managed more similarly to wilderness and may be indirectly 

affected by increases in noise and human activities in adjacent roadless areas. The indirect 

impact would be minimal under alternative 1, and minimal under alternatives 2 and 4, except in 

the CPZ, and greatest under alternative 3, based on the relative amounts of road construction

and tree-cutting.

Congressionally Designated Wild & Scenic Rivers – Affected 

Environment

Colorado has only one congressionally designated river, the Cache la Poudre River on the 

Arapaho-Roosevelt National Forest west of Ft. Collins, Colorado. The river was designated by 

Congress as a Study River in 1975 and recommended for wild and scenic designation in 1986 

(P.L. 99-590). The designation protects 61 miles of river under Forest Service administration in 

the following classifications: 16 miles of Wild classification and 45 miles as Recreation 

classification. No road construction or tree-cutting are allowed in the wild corridor. In the 

recreation section of the wild and scenic river corridor, some roads and other activities may 

occur as long as the outstandingly remarkable values remain protected

Congressionally Designated Wild & Scenic Rivers – Environmental 

Consequences

All Alternatives

None of the alternatives would directly affect the stretch of the wild and scenic river corridor 

classified as wild, because the statute designating the river is more restrictive than any of the 

alternatives. Because the law does not allow activities that would degrade those values for 

which the river corridor was designated, and the law‘s restrictions take precedence over 

regulations and forest plan direction, none of the alternatives would directly affect the wild and 

scenic values in this corridor. 

However, as described for wilderness and other congressionally designated areas, activities 

allowed to occur on surrounding roadless area acres may indirectly affect the values associated 

with the wild river designation. Alternative 1 would have the least potential to affect wild river 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—245

values in that river corridor; alternatives 2 and 4 would increase the potential to affect those 

values; and alternative 3 would have the highest potential to affect those values. 

Congressionally Designated Trail, Continental Divide National Scenic 

Trail – Affected Environment

Congress enacted the National Trails System Act (P.L. 90-543) on October 2, 1978, which 

established a nationwide trail system and designated the Appalachian Trail and Pacific Crest 

Trail. The act describes national scenic trails ―will be extended trails so located as to provide for 

maximum outdoor recreation potential and for the conservation and enjoyment of the 

nationally significant scenic, historic, natural, or cultural qualities of the areas through which 

such trails may pass.‖

Congress amended the National Trails System Act with Public Law 95-625, on November 10, 

1978, to establish and designate the Continental Divide National Scenic Trail (CDNST) which 

traverses approximately 800 miles through Colorado along the Continental Divide. The 

Comprehensive Plan for the CDNST, amended on September 28, 2009, describes that the nature 

and purposes are to provide for high-quality scenic, primitive hiking and horseback riding 

opportunities and to conserve natural, historic, and cultural resources along the CDNST 

corridor. Under forest plan direction, the trail is managed to provide for primarily primitive

and semi-primitive non-motorized recreation opportunities and settings, and a scenic integrity 

level of high to very high. The direction would be followed under any of the four alternatives. 

Information can be found within the Colorado Roadless Area Profiles located at 

www.roadless.fs.fed.us. Specific CDNST information is found at www.online at 

http://www.fs.fed.us/cdt.

Other Congressionally Designated Trails – Environmental 

Consequences 

All Alternatives

None of the alternatives would directly affect the scenic values for which the CDNST was 

designated because management direction contained in the statutes associated with this 

designated trail overrides any existing forest plan direction or rule.

Potential indirect impacts on the high to very high scenic values along this trail corridor could 

vary by alternative depending on the amount of road construction or tree-cutting within view 

of the CDNST. Among the alternatives, alternative 1 would have the least potential to affect 

those scenic and other values along the CDNST from adjacent land management activities 

because this alternative projects the least amount of road construction and tree-cutting 

activities. This is followed by alternative 4, alternative 2 and alternative 3 with the highest 

potential to affect scenic and other values due to the highest level of projected activities.

Administratively Designated Areas – Affected Environment

Administratively designated areas are those designated by the Secretary of Agriculture or a 

designated officer, such as the Chief of the Forest Service, a regional forester, or a forest 

supervisor. There are two types of administratively designated areas in the analysis area: 

research natural areas (RNAs) and special interest areas (SIAs). 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

246—Chapter 3. Affected Environment and Environmental Consequences

Research Natural Areas

The RNAs in Colorado form a long-term network of ecological reserves designated for nonmanipulative research, education, and the maintenance of biodiversity. The RNAs are selected 

to preserve a spectrum of relatively pristine areas that represent a wide range of natural 

variability within natural ecosystems and environments and may have special or unique 

characteristics of scientific importance. The desired condition for RNAs is to maintain natural 

conditions by allowing ecological processes to prevail with minimal human intervention. There 

are RNAs within roadless areas on seven of the eight national forests in Colorado; there are 

none on the small portion of the Manti-La Sal National Forest that occurs in the Colorado. 

Table 3-44 lists the RNAs on each national forest fully or partially within a roadless area, along 

with the roadless area name. 

Table 3-44. Research natural areas within roadless areas

National forest Research natural area IRA CRA

Arapaho-Roosevelt Boston Peak Fen Green Ridge West Green Ridge West

Arapaho-Roosevelt Mt. Goliath Mt. Evans Adjacent Area Mt. Evans Adjacent Area

Arapaho-Roosevelt Lone Pine North Lone Pine North Lone Pine

Arapaho-Roosevelt North St. Vrain North St. Vrain RNA, North 

St. Vrain

North St. Vrain

GMUG Gothic Gothic Mountain Gothic

Pike-San Isabel Hurricane Canyon East Pikes Peak Pikes Peak East

Rio Grande Finger Mesa Pole Mountain/Finger Mesa Pole Mountain/Finger Mesa

Rio Grande Mill Creek Crestone Crestone

Routt Kettle Lakes Kettle Lakes Kettle Lakes

San Juan Williams Creek Williams Creek White Fir 

Natural Area

Graham Park

White River Main Elk Creek Elk Creek B Elk Creek B

White River Hoosier Hoosier Ridge Hoosier Ridge

White River Battlement Mesa Housetop Mountain Housetop Mountain

Management direction for specific RNAs differs among the various national forests. Table 3-45

lists the management direction in each forest plan concerning road construction and tree-cutting

in RNAs. 

Table 3-45. Research natural area forest plan direction

National Forest Tree-cutting Road construction or reconstruction

Arapaho-Roosevelt No tree-cutting Roads prohibited

GMUG No tree-cutting Roads restricted; generally, physical improvements, such as 

roads are not permitted

Pike-San Isabel No tree-cutting Roads restricted; generally, physical improvements, such as 

roads are not permitted

Rio Grande No tree-cutting Roads restricted; prohibit motorized and mechanized use except 

when necessary for research or educational access

Routt No tree-cutting Roads prohibited

San Juan No tree-cutting Roads restricted; generally, physical improvements, such as 

roads are not permitted

White River No tree-cutting Roads restricted; prohibit motorized and mechanized use except 

when it provides necessary access for scientific, administrative, 

emergency, or educational purposes
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—247

For all forests, the forest plan direction for RNAs does not allow tree-cutting. Under all 

alternatives, the forest plan direction must be followed; therefore, there would be no treecutting allowed in RNAs under any alternative. Although there is some variability in forest plan 

direction for road construction in RNAs, no road construction in RNAs is projected to occur in 

roadless areas under any alternative. There are no oil, gas, or coal leases within the RNAs, and 

no mining sites or other land uses that are subject to reserved or outstanding rights. There 

would be no difference in effects between alternatives.

Special Interest Areas

The SIAs are identified in the forest plans for each national forest. SIAs are designated for their 

unique or outstanding botanical, geological, historical, paleontological, cultural, scenic, 

recreational, zoological (species or habitat diversity), or other significant values. The SIAs may 

be managed as interpretive sites for public recreation or education and may be relatively small 

or fairly large. 

The desired condition in SIAs is to maintain or restore the natural or near-natural conditions 

and protect the significant values for which the SIA was established. Losses of vegetation in 

SIAs as a result of insect-disease outbreaks or wildland fires are generally accepted. If activities 

are allowed in SIAs, they usually must maintain or restore the natural conditions and protect 

threatened, endangered, or sensitive species habitat and the values of the SIA. Generally, roads 

and facilities may be constructed in SIAs to enhance the values for which the SIA was 

designated, for interpretive or educational purposes, or to correct resource damage. 

There are 23 SIAs within all or portions of roadless areas on six of the eight national forests in 

Colorado; they do not occur in roadless areas on the Manti-La Sal or the Pike-San Isabel. Table 

3-46 lists the SIAs on the six national forests where they occur in all or portions of a roadless 

area.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

248—Chapter 3. Affected Environment and Environmental Consequences

Table 3-46. Special interest areas within roadless areas

Management direction for SIAs differs among the various forests. Table 3-47 summarizes the 

management direction for road construction and tree-cutting in SIAs for the forest plans with 

SIAs in roadless areas. 

National Forest Special interest area IRA CRA

Arapaho-Roosevelt James Peak James Peak James Peak

Arapaho-Roosevelt Homestead Meadows Lion Gulch Lion Gulch

Arapaho-Roosevelt Grays Peak Mt. Sniktau Mt. Sniktau

Arapaho-Roosevelt Niwot Ridge Indian Peaks Adjacent 

Areas

Indian Peaks Adjacent 

Areas

Arapaho-Roosevelt Arapaho National 

Recreation Area

Indian Peaks Adjacent 

Areas

Indian Peaks Adjacent 

Areas

GMUG Ophir Needles Ophir Needles Not in a CRA

GMUG Slumgullion Slide Cannibal Plateau Cannibal Plateau

GMUG Alpine Tunnel Romley Mirror Lake

Rio Grande Bachelor Loop Wason Park Wason Park

Rio Grande Blowout Pass Wightman Fork/Upper 

Burro

Wightman Fork/Upper 

Burro

Rio Grande Devil’s Hole Alamosa River Alamosa River

Rio Grande John Charles Fremont Deep Creek/Boot 

Mountain

Deep Creek/Boot 

Mountain

Rio Grande

Wagon Wheel Gap 

Watershed Experiment 

Station

Snowshoe Mountain Snowshoe Mountain

Routt California Park

Sugarloaf North and 

South, Nipple Peak North 

and South, and Shield 

Mountain

Sugarloaf North and 

South, Nipple Peak North 

and South and Shield 

Mountain

Routt Black Mountain Sugarloaf South Sugarloaf South

Routt Little Snake Elkhorn Elkhorn

Routt Windy Ridge Barber Basin Barber Basin

Routt Teller City Never Summer South Never Summer South

San Juan Falls Creek Archaeological 

Area Not in IRA Hermosa

White River Main Elk Creek Elk Creek B Elk Creek B

White River Porcupine Tenderfoot Mountain Tenderfoot Mountain

White River Independence Pass North Independent B North Independent B

White River Colorado Midland Railroad Wildcat Mountain C Wildcat Mountain C

GMUG Alpine Tunnel Romley Mirror Lake

Rio Grande Bachelor Loop Wason Park Wason Park
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—249

Although there is some variability in forest plan direction in SIAs, no road construction or treecutting activities is projected to occur in SIAs under any alternative. There are no oil, gas, or 

coal leases within the SIAs, and no mining claims, federal highways, or other developments in 

SIAs subject to reserved or outstanding rights. There is no difference between the four 

alternatives. 

Table 3-47. Special interest area forest plan direction

National forest Road construction or reconstruction Tree-cutting

Arapaho-Roosevelt Roads restricted; new facilities may be 

constructed to enhance the values for which 

the SIA was designated, for interpretive or 

educational purposes or to correct resource 

damage; most SIAs are non-motorized

Tree-cutting restricted

GMUG Roads restricted Tree-cutting prohibited; prohibit any direct 

habitat manipulation

Rio Grande Roads restricted; Recreation Opportunity 

Spectrum class is semi-primitive motorized;

developed facilities must meet management 

objectives

Tree-cutting prohibited

Routt Roads generally allowed but only under some 

specific circumstances; construct new roads 

only when consistent with SIA values, such 

as interpretation or education, or to meet 

other resource objectives such as oil and gas

leasing

Tree-cutting generally not restricted 

except for regulated commercial timber

purposes; use only those vegetation 

management practices necessary to meet 

specific resource objectives of maintaining 

or restoring the values for which the SIA

was established

San Juan Roads restricted; develop transportation 

system only to enhance cultural resource 

interpretation or maintenance opportunities

Tree-cutting restricted; allow tree removal 

only for such purposes as public safety, 

improvement of aesthetics, insect and 

disease control, ruins research and 

maintenance, ruins reconstruction, or 

wildlife habitat improvement

White River

2.1 Management 

Area

Roads restricted; regulate motorized and 

mechanized travel where necessary to 

protect the values for which the individual 

area was proposed or established; long-term 

maintenance of roadless area characteristics

emphasized

Tree-cutting restricted; allow vegetation 

management practices necessary to meet 

specific resource objectives of maintaining 

the values for which the individual area 

was proposed or established; long-term 

maintenance of roadless area 

characteristics emphasized

White River

3.1 Management 

Area

Roads restricted; construct new roads only 

when necessary for interpretive or 

educational purposes or to correct resource 

damage from existing roads; long-term 

maintenance of roadless area characteristics

emphasized

Tree-cutting restricted; allow vegetation 

manipulation when necessary to reduce 

fuel loads, maintain or restore natural 

conditions, or enhance other values for 

which the individual area was proposed or 

established; long-term maintenance of 

roadless area characteristics emphasized 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

250—Chapter 3. Affected Environment and Environmental Consequences

Administratively Designated Areas - Environmental Consequences 

All Alternatives

None of the alternatives project any road construction or reconstruction, or any tree-cutting 

activities within the RNAs or SIAs. Thus, there would be no difference in effects predicted to 

occur in roadless area RNAs or SIAs under any of the alternatives. 

Under all alternatives, roads may be constructed in RNAs and SIAs in roadless areas if 

necessary to meet statutory obligations or reserved or outstanding rights (described in chapter 

2, Alternatives Considered in Detail section). However, none of those types of activities 

currently occur in the RNAs or SIAs, and none are foreseeable in the next 15 years. 

Under alternative 3, road construction could potentially occur in the future in RNAs or SIAs in 

roadless areas, where it is not entirely prohibited. Some forest plans allow roads or facilities to 

be constructed in RNAs or SIAs, although the values for which the area was established would 

need to be maintained. Road construction and tree-cutting (other than for incidental uses) 

would be unlikely to occur in those particular areas, in order to protect the special values for 

which these areas are administratively designated. As there are no direct or indirect effects to 

RNAs or SIAs expected within the roadless areas under any alternative, there would be no 

potential for cumulative effects.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—251

ROADLESS AREA CHARACTERISTICS

Roadless Area Characteristics: Affected Environment

As discussed and described in chapter 1, there are nine roadless area characteristics identified 

and defined in the 2001 Roadless Rule and referred to in the proposed Rule. Roadless area 

characteristics are resources or features that are often present in or characterize roadless areas.

These resources and features are:

1. High quality or undisturbed soil, water, and air;

2. Sources of public drinking water;

3. Diversity of plant and animal communities;

4. Habitat for threatened, endangered, proposed, candidate, and sensitive species and for 

those species dependent on large, undisturbed areas of land;

5. Primitive, semi-primitive nonmotorized and semi-primitive motorized classes of 

dispersed recreation;

6. Reference landscapes;

7. Natural appearing landscapes with high scenic quality;

8. Traditional cultural properties and sacred sites; and

9. Other locally identified unique characteristics.

In an increasingly developed and fragmented landscape, large unfragmented tracts of land 

become increasingly important for the very resources and features described in the roadless 

area characteristics. Of all management activities, tree-cutting, sale or removal and road 

construction/reconstruction generally have the greatest likelihood of altering and fragmenting 

roadless areas, resulting in the loss of these nine characteristics. The exceptions in each 

alternative of this proposed rule and the acres to which they apply are different. This analysis 

focuses on the effects of each alternative on roadless area characteristics.

Other activities may also compromise roadless area characteristics; such as, oil and gas

pipelines or electrical power lines. Alternatives 2 and 4 contain specific prohibitions on the use 

of linear construction zones and the location of oil and gas pipelines, electrical power lines, and 

telecommunication lines within CRAs; whereas alternatives 1 and 3 do not. Under alternatives 1 

and 3, these features would only be prohibited if their development would not meet a desired 

future condition in the forest plan.

When considering the nine roadless area characteristics, each individual roadless area is unique.

The Colorado Roadless Areas are described in the Roadless Profiles found on the following web 

site: www.roadless.fs.fed.us. These profiles describe each roadless area and the roadless area 

characteristics within each CRA. A table in Appendix A and each CRA profile contain a crosswalk between the IRAs and the CRAs in order to display the overlap and differences between 

the CRA and IRA boundaries and roadless area characteristics.

Roadless Area Characteristics: Environmental Consequences

Alternative 1 - 2001 Roadless Rule 

The substantially altered acres within the IRAs have lost some of their roadless area 

characteristics; approximately 11% of the total IRA acres. Tree-cutting would continue to occur on 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

252—Chapter 3. Affected Environment and Environmental Consequences

these acres under this alternative. Due to the limited projected tree-cutting, sale or removal and 

road construction or linear construction zones there would be limited impact beyond the 

substantially altered areas; likely less than 1% of additional acreage would be impacted by this 

alternative within the next 15 years, including those lands under an existing oil, gas or coal lease. 

Most of the IRA acres that currently exhibit high quality roadless area characteristics would

retain those into the future. Approximately 4% of the 409,500 that are not within the IRAs under 

this alternative have tree-cutting projected within the next 15 years and would lose some of 

their roadless area characteristics under this alternative. 

Alternative 2 - Proposed Colorado Roadless Rule (Proposed Action)

In this alternative, with the restrictions on tree-cutting, sale or removal, road construction, and 

linear construction zones, about 98% of the 4,186,000 acres within the CRAs are not projected to 

have ground disturbing activities and are likely to retain their existing roadless area 

characteristics over time. The 458,800 acres that are already substantially altered within the 

IRAs that are not within the CRAs would likely continue to have reduced roadless area 

characteristics, depending on land management plan direction. Approximately 4% of the 

substantially altered acres have projected tree-cutting in the next 15 years. 

Future activities within CRAs could have potential effects on the undeveloped and natural 

qualities of roadless area characteristics; however, such acreage is expected to be limited in any 

specific area and the temporary roads are required to be decommissioned after use including 

those for oil, gas, and coal leases. Short-term roadless area characteristics could be negatively 

impacted but through restoration activities and time, roadless area characteristics would be 

protected over the long-term within the CRA‘s. Such activities are unlikely to affect natural 

ecosystem forces or opportunities for primitive and unconfined recreation.

Alternative 3 - Forest Plans (No Action)

Some existing forest plan management prescriptions limit tree-cutting, sale or removal and road 

construction or reconstruction. There are 13% of the IRA acres (541,700) and 13% the CRA acres 

(532,400 acres) that prohibit or largely limit tree-cutting, sale or removal and 6% of the IRA 

acres (258,500 acres) and 6% the CRA acres (257,300 acres) that have forest plan language 

prohibiting road construction or reconstruction. Many of the acres where road construction is 

restricted are the same acres where tree-cutting, sale or removal is limited. There is no specific 

forest plan language limiting the use of linear construction zones or the placement of oil and gas

pipelines, electrical power lines or telecommunication lines within the roadless areas.

In considering the entire analysis area for all alternatives (4,653,100 acres), approximately 10% 

are substantially altered by past management activities. With the projections, up to an 

additional 5% may lose some of their roadless area characteristics within the next 15 years. 

Approximately 85% of the total acres within the IRAs and CRAs would retain their existing 

roadless character into the future under this alternative. 

Alternative 4 - Colorado Roadless Rule with Public Proposed Upper Tier Acres

The effects would be similar to alternative 2, but because there are more upper tier acres with 

less activity, more than 99% of the 4,186,000 acres within the CRAs are likely to retain their 

existing roadless area characteristics over time. The 458,800 acres that are already substantially 

altered within the IRAs that are not within the CRAs would likely continue to have reduced 

roadless area characteristics, depending on land management plan direction. Approximately 4% 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—253

of the substantially altered acres have projected tree-cutting in the next 15 years.

Roadless Area Characteristics: Cumulative Effects

Colorado Roadless Areas are managed under a variety of management prescriptions in existing 

forest plans. Implementation of the 2001 Roadless Rule or the Proposed Colorado Roadless

Rule would help establish a uniform approach to managing these areas over the long term. 

Because many CRAs are adjacent to wilderness areas, large tracts of land would remain 

essentially unroaded and undeveloped. 

Future forest plan revisions or amendments can further restrict tree-cutting, sale or removal or 

road construction or reconstruction beyond the limitations in the alternatives. In addition, forest 

plans would continue to allow or restrict a range of other activities on these lands. The upper 

tier acres identified in alternatives 2 and 4 cannot be changed, either the identified acreage or 

the prohibitions, by a forest plan revision. The Colorado Roadless Rule would need to be 

modified for a change to occur in the upper tier acreage and direction.

In the past, roadless areas were managed as a bank for future resource development or special 

designation. The Agency anticipates that future proposed project activities in an individual 

roadless area that may affect roadless area characteristics through tree-cutting, sale or removal 

or road construction and other development activities would still see intense public scrutiny, 

administrative appeals, and in some cases, legal challenge. However, the Agency believes that 

changes to individual roadless areas would be incrementally small, changing a portion of the 

area and not the entire area, and would be infrequent and often short-term. Short-term impacts 

under all alternatives include temporary road construction that would be required to be 

decommissioned after use and ultimately roadless area characteristics would be restored within 

the IRAs or CRA‘s.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

254—Chapter 3. Affected Environment and Environmental Consequences

REFERENCE LANDSCAPES

This section addresses the effects of alternatives on changes in opportunities to use roadless 

areas as reference landscapes. One of the nine roadless area characteristics is the ability for 

roadless areas to be used as reference landscapes. Reference landscapes contribute to the body 

of knowledge about the effects of forest management activities over long periods of time and on 

large landscapes, providing comparison areas for evaluation and monitoring. 

Reference Landscapes: Affected Environment

Roadless areas in Colorado currently provide a natural setting, or baseline, that may be useful 

as a comparison to study the effects of more intensely managed areas. Widespread interest 

exists in obtaining information about large-scale ecological patterns, processes, and 

management activities (Bormann et al. 1999). Issues such as viability of wide-ranging animals, 

watershed cumulative effects, and restoration of fire dependent ecosystems, require research 

and monitoring at large scales to significantly address this interest. Roadless areas enable 

monitoring of long-term environmental issues, including climate change; and provide the 

opportunity to gain an improved understanding of the effect of past events on the landscape. 

Roadless areas in Colorado provide large areas for the long-term study of trends in ecosystem

conditions. 

Reference Landscapes: Environmental Consequences 

All Alternatives

Retaining roadless area acreage would provide reference landscapes for long-term study where 

comparisons of natural settings are needed. Where additional road construction, tree-cutting, 

oil and gas or coal development activities are projected to occur in roadless areas, the quality of 

those roadless areas as natural setting reference landscapes would be, at least in the short term, 

degraded or lost. Where a range of management treatments are needed to be applied and 

tested, only alternative 3 would allow this activity. 

Alternative 1- 2001 Roadless Rule 

Average annual projections of activities in IRAs under this alternative are minimal relative to 

the 4.24 million roadless acres (see Analysis Framework section) and most acreage could serve 

as a natural setting for comparison. The IRAs that contain substantially altered acreages and 

developed ski areas currently provide minimal value as natural setting reference landscapes. 

The newly identified roadless acreage, not within IRA‘s could potentially be degraded under 

this alternative. 

Alternative 2- Colorado Roadless Rule (Proposed Action)

Average annual projections of activities in CRAs under this alternative are minimal relative to 

the 4.19 million roadless acres (see Analysis Framework section). Most of the areas within the 

CRAs and particularly the upper tier acres would have little to no activity and be retained as 

natural setting reference landscapes. The substantially altered acres and other IRA acres not 

included in CRAs would not add to or subtract from the value of the CRAs as natural setting 

reference landscapes but could serve as areas where management treatments could be applied 

and tested. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—255

Alternative 3- Forest Plans (No Action)

Average annual projections of activities in IRAs under this alternative are marginal relative to 

the 4.24 million roadless acres (see Analysis Framework section). Those areas where there 

would be no management activities would continue to serve as natural setting reference 

landscapes. The individual forest plan direction would offer the greatest flexibility to allow for 

additional activities within roadless area to continue various experiments and comparisons 

through time, activities that would be prohibited in alternatives 1, 2, and 4.

Alternative 4 –Colorado Roadless Rule with Public Proposed Upper Tier 

The effects on reference landscapes of alternative 4 are similar to alternative 2, but with the 

greater number of acres in the upper tier with more restrictions on tree-cutting, sale and 

removal and road construction, there would be larger acres intact to serve as natural setting 

reference landscapes. There would be less acreage within this alternative where management 

activities could be applied and tested other than the substantially altered acreage that is not 

within the CRAs. 

Reference Landscapes: Cumulative Effects

This evaluation considered the past, ongoing, and foreseeable activities that are likely to have 

effects on roadless areas and influence their value as reference landscapes. Refer to Appendix E, 

the cumulative effects, for a description of those actions and associated effects most relevant to 

this EIS. 

Most of the roadless areas border congressionally designated wilderness or similarly designated 

areas (e.g. protection areas, as described in the Other Congressionally Designated Areas and 

Trails section). Cumulatively, this adds to the total acreage that can be used for large scale 

research and monitoring, using these combined areas as natural setting reference landscapes. 

Residential populations are continuing to expand along the borders of roadless areas, which is 

detracting from their value as reference landscapes. Human land use activities, particularly 

recreation activities including some illegal motorized use, are expected to continue to become 

more prevalent in portions of some roadless areas that are within those wildland-urban 

interface zones. This cumulatively would result in fewer roadless area acres being suitable as 

reference landscapes for research and monitoring of natural ecological processes. The 

cumulative effect would be most evident under alternative 3, where the least amount of 

roadless area acreage would be available in the long term as a reference landscape representing 

natural ecosystem processes. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

256—Chapter 3. Affected Environment and Environmental Consequences

CULTURAL RESOURCES

Introduction

Cultural resources, also known as heritage resources, refer to areas, sites, buildings, art, 

architecture, memorials, and objects that have scientific, historic, or cultural value. They link 

people to their cultural history, provide insight into how people lived in the past, and reveal 

past and ongoing relationships between people and the natural world. Many of the nation‘s 

cultural resources are located on public lands, with NFS lands containing more than 330,000 

known sites. 

Traditional cultural properties and sacred sites are also considered cultural resources and may 

exist within roadless areas in Colorado. Traditional cultural properties are places, sites, 

structures, districts, or objects that are historically significant in the beliefs, customs, and 

practices of a community. Sacred sites are places that are determined sacred by virtue of their 

established religious significance to or ceremonial use by an Indian religion. Past consultations 

with tribes and rural communities in Colorado indicate that certain tribes and ethnic groups 

have some specific traditional use areas within the roadless areas. Members of the various Ute 

Tribes are known to use some roadless areas in Colorado for traditional plant gathering and 

hunting. Because of cultural sensitivities and the desires of traditional tribal practitioners, exact 

areas for these types of activities often are not publicly disclosed. Evaluating the existence and 

significance of traditional cultural properties and sacred sites requires consultation with tribal 

members who possess traditional knowledgeable of specific areas. Traditional cultural 

properties and sacred sites have not yet been extensively inventoried on NFS lands, especially 

in roadless areas. 

The Forest Service inventories and takes actions to protect historic properties in accordance 

with the National Historic Preservation Act, Archaeological Resources Protection Act, Executive 

Order 11593 (Protection and Enhancement of the Cultural Environment), Executive Order 13007 

(Indian Sacred Sites), and other related legal requirements. Effects from federal activities on 

traditional cultural properties are considered under the National Historic Preservation Act. 

When the Forest Service authorizes actions on NFS lands, the agency must assess the potential 

effects of those actions on historic properties and seek ways to avoid or minimize adverse 

effects. Inventories and evaluations of effects of land management activities on cultural 

resources are completed during analysis of the proposed site-specific activities; measures are 

designed to avoid or minimize harm to those resources. If human remains are discovered before 

or during project implementation on NFS lands, the Forest Service consults with culturally 

affiliated tribes and takes appropriate actions, in accordance with the Native American Graves 

Protection and Repatriation Act. Federal agencies are to accommodate access to and ceremonial 

use of Indian sacred sites by Indian religious practitioners, and are to avoid adversely affecting 

the physical integrity of such sacred sites when practicable.

The Forest Service stabilizes and restores cultural resource sites that have been damaged or 

neglected, interprets sites for public education, and provides sites for public use and enjoyment 

through historic cabin rentals. It is important to maintain the integrity of and sometimes 

interpret cultural resource sites for future generations. NFS lands contain many of the bestpreserved heritage sites that remain in the United States, in some of the least disturbed natural 

settings. These sites provide opportunities for Americans to learn about their cultural heritage 

(USDA Forest Service 1999). Heritage tourism is one of the fastest growing sectors of the 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—257

tourism industry, and it is ranked among the top two or three reasons that people take 

vacations (USDA Forest Service 1999). 

Cultural Resources: Affected Environment 

Of the more than 30,000 cultural resource sites on NFS lands in Colorado, more than 17,600 

(approximately 59 percent) are either considered significant and eligible for inclusion or listed 

on the National Register of Historic Places (NRHP), or their significance is unknown and they 

are managed as though eligible for inclusion on the NRHP. Of the 30,000 sites identified on NFS 

lands in Colorado, more than 1,400 are currently known to exist within IRAs and more than 

1,200 are currently known to exist within CRAs in Colorado. Many of these cultural resource 

sites are eligible for inclusion on the NRHP. Sites include historic, prehistoric, and traditional 

cultural properties. Additional cultural resources undoubtedly exist within these roadless areas 

but have yet to be discovered or documented (data obtained from the USDA Forest Service 

Region-2 INFRA-heritage database 2008).

The laws, regulations, and executive orders previously listed, along with several others, require 

the Forest Service to consult with federally recognized tribes, based on a unique government-togovernment relationship and trust responsibility. There are two resident tribes in Colorado, 

both retaining some of their traditional land base as reservations via a series of treaties, 

agreements, and laws. The Ute Mountain Ute and Southern Ute Tribes (consisting originally of 

the Weeminuche, Capote, Tabeguache, and Mouaches Bands)—each a ―domestic sovereign‖ 

nation—have reserved some specific off-reservation hunting rights in Colorado and retain 

inherent aboriginal rights throughout their traditional territory. Many other tribes located 

outside Colorado maintain tribal interests, including aboriginal and ceded territories, and retain 

inherent aboriginal rights within the State. 

Cultural Resources: Environmental Consequences 

All Alternatives

All alternatives require compliance with existing laws and regulations; therefore, before any 

management actions take place the standard process for considering effects would be 

conducted as required by the implementing regulations for the National Historic Preservation 

Act. In most cases, a cultural resource inventory would be conducted. Impacts would be 

avoided or mitigated. Tribal consultation is an integral part of the planning process for 

management actions; as well as consultations with the State Historic Preservation Officer and 

other interested parties.

Forest Service land management practices have the potential to affect buried or surface remains 

of archaeological sites, historic sites, and sites of traditional or religious importance to tribes. 

Whenever roads or other facilities are constructed, there may be a variety of associated impacts 

on cultural resources that affect the integrity of those sites. The risk of adverse impacts from 

authorized activities in roadless areas would be relatively low in all alternatives based on 

projections of activity levels. 

Fires can damage historic and prehistoric buildings and structures, culturally modified trees, 

artifacts, features, and other surface remains. By removing vegetation, fires expose sites and 

make them more vulnerable to erosion damage and vandalism. Recreation activities, ongoing 

permitted activities, and ongoing authorized activities can impact cultural resources; these 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

258—Chapter 3. Affected Environment and Environmental Consequences

activities do not vary by alternative.

Impacts on tribal governments and tribal practices from the Colorado roadless rulemaking

process are not expected because of consultation requirements with individual tribes. The 

Forest Service has been consulting with Colorado-affiliated tribes regarding this proposed 

rulemaking action and analysis process. Concerns raised by some tribes regarding tribal land 

uses and access in roadless areas do not vary by alternative. If access or land ownership 

adjustments are proposed in the future, additional tribal consultation and analysis is required 

before a decision is made. 

Alternative 1 – 2001 Roadless Rule 

Alternative 1 would result in the lowest risk of adverse effects on cultural resources from 

ground-disturbing activities. The effects and adverse impacts are minimized on historic 

landscapes, potential sacred sites, and traditional cultural properties. With the minimal amount 

of human development or land use activities, there would be little affect to traditional uses by 

tribes or rural communities, such as traditional gathering of plants, hunting, fishing, or spiritual 

practices that may occur in roadless areas. This alternative would provide for maintenance of 

the current condition of cultural resources in the roadless areas.

Alternative 1 provides less opportunity to the public for heritage tourism or educational and 

interpretive opportunities except for the substantially altered acres that are roaded within the 

IRAs and where new roads could occur within the analysis area outside of the IRA‘s under this 

alternative. There would be a slightly greater risk of experiencing negative impacts to cultural 

resources from wildland fires with less tree-cutting projected for community protection, which 

pose a risk of adverse effects on cultural resources. There may be small, localized impacts from 

a number of ongoing activities, although the magnitude of human activities in roadless areas 

would continue to be much lower than on other NFS lands.

Alternative 2 - Colorado Roadless Rule (Proposed Action)

This alternative maintains a number of prohibitions and limitations on development activities 

in roadless areas. Compared to the other alternatives, alternative 2 would result in a higher risk 

of adverse impacts on cultural resources from ground-disturbing activities than alternative 1. 

The effects and adverse impacts on historic landscapes, potential sacred sites, and traditional 

cultural properties, traditional uses by tribes or rural communities, such as traditional gathering 

of plants, hunting, fishing, or spiritual practices are minimal. Overall, alternative 2 would 

provide for satisfactory maintenance of the current condition of cultural resources in the 

roadless areas. 

Alternative 2 would provide a slight potential increase in heritage tourism and interpretation 

opportunities compared to alternative 1 in the substantially altered acres not within the CRAs

because additional road construction could occur. By allowing for more treatments for 

hazardous fuels, this alternative would also reduce the risk of roadless areas experiencing highseverity wildland fires, which can cause adverse effects on cultural resources. There may be 

small, localized impacts from a number of ongoing activities, although the magnitude of human 

activities in roadless areas would continue to be much lower than on other NFS lands.

Alternative 3 – Forest Plans (No Action) 

Compared to the other alternatives, alternative 3 would result in the highest risk of adverse 

impacts on cultural resources from ground-disturbing activities. Potential impacts on traditional 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—259

uses by tribes or rural community groups would also be higher under this alternative. There 

would be more potential for damage or loss of cultural resources. Overall, it is expected that 

activities authorized under alternative 3 would continue to provide for satisfactory maintenance 

of the current condition of cultural resources in the roadless areas. 

Alternative 3 would provide the greatest opportunity to increase heritage tourism and 

interpretation, compared to the other three alternatives. By allowing for more treatments for 

hazardous fuels purposes, this alternative would also reduce the chance of roadless areas 

experiencing high-severity wildland fires, which can cause adverse effects on cultural resources. 

There may be small, localized impacts from a number of ongoing activities, although the 

magnitude of human activities in roadless areas would continue to be lower than on other NFS

lands.

Alternative 4 - Colorado Roadless Rule with Public Proposed Upper Tier 

This alternative maintains a number of prohibitions and limitations on development activities 

in roadless areas; increased prohibitions in the upper tier acres. Compared to the other 

alternatives, alternative 4 would result in a lower risk of adverse impacts on cultural resources 

from ground-disturbing activities than alternatives 2 or 3. The effects and adverse impacts on 

historic landscapes, potential sacred sites, and traditional cultural properties, traditional uses by 

tribes or rural communities, such as traditional gathering of plants, hunting, fishing, or spiritual 

practices are minimal. This alternative would provide for maintenance of the current condition 

of cultural resources in the roadless areas.

Alternative 4 would provide a slight potential increase in heritage tourism and interpretation 

opportunities compared to alternative 1 in the substantially altered acres not within the CRAs 

by allowing additional road construction. By allowing for treatments for hazardous fuels in the 

CRA acres that are not upper tier, on these acres there is a reduced chance of roadless areas 

experiencing high-severity wildland fires, which can cause adverse effects on cultural resources. 

There may be small, localized impacts from a number of ongoing activities, although the 

magnitude of human activities in roadless areas would continue to be much lower than on other 

NFS lands.

Cultural Resources – Cumulative Effects 

Given the widespread destruction of cultural resources located on private lands and the rapidly 

growing interest in heritage tourism nationwide, cultural resources on NFS lands is likely to 

become more valuable in the future. Potentially there could be an increase in hazardous fuels 

treatments due to the bark beetle epidemic in Colorado and an increase in oil and gas

development, as well as other energy-related activities such as geothermal leasing on adjacent 

lands surrounding roadless areas. These activities would contribute to an overall increase in 

ground-disturbing activities and alteration of natural and cultural landscapes, which in turn 

would add to potential for damage to cultural resources. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

260—Chapter 3. Affected Environment and Environmental Consequences

LANDS - SPECIAL USE AUTHORIZATIONS

Introduction

The Forest Service issues special use authorizations (SUAs) for third party owned facilities 

located on National Forest System (NFS) lands. These SUAs include temporary permits, 

permits, term permits, leases and easements. All of these require some type of access to the 

facility for operation and maintenance. The facilities may need some incidental tree removal 

periodically for continued safe operation, or under certain emergency conditions. There are also 

SUAs issued for access to private and other ownerships. Recreation-related permits are 

discussed separately in the recreation section of the EIS. 

Lands Special Use Authorizations: Affected Environment

There are approximately 140 different types of lands uses that can be authorized on NFS lands.

In Colorado, there are approximately 3,900 lands SUAs issued to individuals, business entities, 

State and local governments and other federal agencies. Uses include, but are not limited to, 

roads, reservoirs, weather stations, snotel sites29, communication sites, railroads, service 

buildings of all types, electric transmission and distribution lines, telecommunication facilities 

(copper phone and fiber optic lines), oil and gas pipelines, ditches and other water conveyance 

structures. The authorized uses provide a variety of products to individuals and the general 

public throughout the United States and can impact NFS lands. 

As private land is developed adjacent to and on inholdings within NFS land, demand for 

authorization for uses has grown. The Alaska National Interest Lands Conservation Act of 1980 

(ANILCA) requires the agency to provide for access to inholdings based on the reasonable use 

and enjoyment of the property. Proposed SUAs adjacent to private land may include: water 

systems, wells, fences and access roads to support and enhance the activity on private lands.

Proponents for any SUA are required to submit a proposal, with an explanation of the purpose 

and need for the project or facility; a justification for the need for use of NFS lands; the public 

need for and benefit from the facility; and the appropriateness of the use for that particular

management area, based on the forest plan, or other planning documents. The FS accepts only 

proposals for facilities where the proponent has satisfied the criteria that they are not able to 

accomplish the use on non-NFS lands (FSH 2709.11, chapter 10, 12.32a – Appropriate use of 

National Forest System Lands; 36 CFR 251.54(e) (5) (i) and (ii)).

Lands Special Use Authorizations: Environmental Consequences 

All Alternatives

It is important to note that all discussions about future use and occupancy of IRAs and CRAs 

are purely speculative. Proposals for third party use and occupancy on NFS all come from 

outside the agency. The agency recognizes the increased oil and gas leasing activity, and so 

anticipates need for future transportation of product. The agency recognizes current increased 

growth in the rural west in and around the National Forests, and anticipates proposals for 

additional access and facilities for those developed lands. Going hand in hand with that 

 

29 Automated system of snowpack and related climate sensors
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—261

expansion, is the need for more municipal water. The agency sees many communities 

expanding their municipal watershed areas, and including more NFS lands in their municipal 

watershed. This could result in less access for traditional lands use authorizations, and infringe 

more on roadless areas. The agency recognizes current trends for exploration of renewable 

energy sources, and anticipates proposals for siting of those facilities on NFS lands. Siting of 

renewable facilities on NFS lands necessitates connection to the national power grid with 

existing or additional electric power lines. But trends and anticipation do not necessarily equate 

to action on the part of individuals or companies. Many entities would prefer to avoid locating 

facilities on NFS, and certainly outside of roadless areas, but for some facilities, that is nearly 

impossible. Linear facilities in particular, often have no other options. And for existing holders 

of water conveyance system SUAs, expansion of those facilities to meet a growing need 

necessitates continued work with the agency, and work on the facility as it is currently 

located—no matter if it is in a roadless area or not. Projections are highly speculative and they 

are summarized in Tables 3-4 and 3-8. Due to the speculative nature of the projections for the

reasons outlined above, differences among alternatives are discussed qualitatively, based on 

restrictions and exceptions under the different alternatives. 

No alternative revokes, suspends or modifies any permit or other legal instrument authorizing 

the occupancy and use of NFS lands prior to the effective date of the rule. Third party owned 

facilities that are authorized by SUA all require some type of access; however, it is not 

necessarily road access. Existing SUAs that authorize roaded access will continue to authorize 

roaded access and allow construction or reconstruction of roads under all alternatives. 

Authorized access roads are constructed to minimum standards, based on site specific analysis 

and resource conditions. 

Future authorization of any land use under an SUA varies by alternative. In most cases, roaded 

access for all facilities could be allowed for health, safety and emergency reasons that without 

intervention could cause the loss of life or property. In alternatives 2 and 4, these must be 

temporary roads and could not be constructed in the upper tier acres.

This section of the EIS analyzes the following land SUA facilities: oil and gas pipelines from 

sources located outside of roadless areas, electric power lines and telecommunications facilities, 

water conveyance structures, and a fourth category of all other land uses (including renewable 

energy facilities such as wind and solar). Oil and gas pipelines are assumed to be co-located 

with roads for existing leases within roadless areas and are analyzed in the oil and gas section 

of this EIS (Table 3-17).

Forest plan direction that discourages or restricts the location of certain SUA facilities is 

followed in all alternatives and does not vary by alternative. 

Oil and Gas Pipelines from Sources Located Outside of Roadless Areas

There are existing oil and gas leases within and on lands adjacent to IRAs and CRAs. Pipelines 

are a necessary component of infrastructure for production and transportation of natural gas 

and fulfillment of lease rights. Construction or reconstruction of pipelines for existing leases 

within roadless areas varies slightly by alternative and are assumed to be co-located with roads 

(see Table 3-17).

Agency policy reflects Bureau of Land Management (BLM) policy that recognizes authorized oil 

and gas pipeline construction does not require a road-- the area of disturbance for the 

installation of the pipeline is considered a linear construction zone. This analysis follows that 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

262—Chapter 3. Affected Environment and Environmental Consequences

policy and all pipelines located within roadless areas from sources outside of roadless areas are 

constructed or reconstructed using linear construction zones; as dictated by pipeline direction in 

each of the four alternatives.

Alternative 1- 2001 Roadless Rule 

There is no rule language limiting the use of linear construction zones and no rule language 

limiting the location of future oil and gas pipelines in IRAs from sources outside of IRAs. 

Within the limits of forest plan direction, oil and gas pipelines can be constructed in IRAs from 

oil and gas leases located outside of IRAs using linear construction zones. Forests project 0.7 

miles of LCZ annually to construct oil and gas pipelines from sources outside of roadless areas

and project no LCZ miles in the analysis area outside of the IRAs.

There is no restriction on future oil and gas pipelines under this alternative on the roadless 

acres newly identified and added to alternatives 2 and 4.

Alternative 2 – Proposed Colorado Roadless Rule (Proposed Action)

Construction of an oil and gas pipeline from a source or sources located exclusively outside of a 

CRA is prohibited after the [effective date of the rule] unless they connect to infrastructure 

within a CRA and the Regional Forester determines such a connection would cause 

substantially less environmental damage. Once it is determined that the pipeline would be 

located in a CRA, a linear construction zone can be used for its construction with a 

determination by the Regional Forester. The upper tier acres follow this same direction. 

If it is determined that the pipeline would not be located within a CRA, the decision may 

necessitate longer routes, and larger pipelines to increase capacity for the future. This may have 

an economic effect on the proponent and all other agencies involved because of limited siting 

locations.

Alternative 3 – Forest Plan Direction (No Action)

This alternative is the same as alternative 1 where LCZs are not limited. 

Alternative 4 – Proposed Colorado Roadless Rule with Public Proposed Upper 

Tier

This alternative is the same as alternative 2. 

Electrical Power Lines and Telecommunication Lines

Electrical power lines and telecommunication lines currently are located in IRAs and CRAs. The 

agency will continue to receive proposals as energy sources are identified and developed. These 

energy sources need to be connected to the electrical grid. 

Alternative 1- 2001 Roadless Rule 

There is no rule language limiting the location of future electrical power lines and 

telecommunication lines in IRAs or limiting the use of linear construction zones for their 

construction, reconstruction or maintenance. If uses are authorized in IRAs in the future, there 

is no provision for road construction for the construction, operation or maintenance of electrical 

power lines or telecommunication lines. Within the limits of forest plan direction, electrical 

power lines and telecommunication lines could be constructed in IRAs using linear construction 

zones. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—263

If roaded access would be necessary the route would be required to be located outside IRAs. 

Relocation outside an IRA would result in increased construction and operation and 

maintenance costs for the proponent. Higher costs would ultimately be borne by the utility 

customers. Relocation outside an IRA could also cause greater environmental impacts if the 

route is significantly longer than it would have been if routed through the IRA.

Alternative 2 – Proposed Colorado Roadless Rule (Proposed Action)

Electrical power lines and telecommunication lines would only be authorized within CRAs if a 

Responsible Official determines there is no opportunity for the project to be implemented 

outside of a CRA without causing substantially greater environmental damage. Once it is 

determined that the location would be within a CRA, the Regional Forester must determine a 

linear construction zone can be utilized for the construction, reconstruction, or maintenance of 

existing or future authorized electrical power lines or telecommunication lines. The upper tier

acres follow this same direction. 

If roaded access would be necessary the route would be required to be located outside CRAs. 

Relocation outside a CRA would result in increased construction and operation and 

maintenance costs for the proponent. Higher costs would ultimately be borne by the utility 

customers. Relocation outside a CRA could also cause greater environmental impacts if the 

route is significantly longer than it would have been if routed through the CRA.

Alternative 3 – Forest Plan Direction (No Action)

Other than forest where plan direction discourages or restricts the location of certain SUA 

facilities or restricts road construction, electrical power lines and telecommunication lines can 

be constructed through IRAs. Roaded access or linear construction zones can be used. This can 

benefit the proponent and the consumer by placing the electrical power line or 

telecommunication line in the most economically viable location for connection to the electrical 

grid.

Alternative 4 – Proposed Colorado Roadless Rule with Public Proposed Upper 

Tier

This alternative would have the same effects as alternative 2. 

Water Conveyance Structures

As water needs increase throughout the country and drought cycles continue, holders are 

asking for authorization to expand and enlarge existing reservoirs and water conveyance 

structures. The agency also anticipates an increase in proposals for new reservoirs and the 

associated water conveyance systems on NFS lands in Colorado, including roadless areas. The 

location of water conveyance structures is only limited by forest plan direction and does not 

vary by alternative. What does change by alternative is how the water conveyance structures 

are constructed, reconstructed or maintained. Three of the alternatives allow for road 

construction for at least some of the future water conveyance structure SUAs. All of the 

alternatives allow for linear construction zones for at least some of the future water conveyance 

structure SUAs. 

Alternative 1- 2001 Roadless Rule 

If uses are authorized in IRAs in the future, there is no provision for road construction for the 

construction, operation or maintenance of water conveyance SUAs. Linear construction zones 

are not prohibited under this alternative so conceivably, any water conveyance structure could 

be constructed in an IRA under this alternative. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

264—Chapter 3. Affected Environment and Environmental Consequences

If roaded access would be necessary, future water conveyance structures could not be located in 

IRAs. Not allowing roaded access to future proposed uses could cause public hardships or 

greater environmental damage to land outside of an IRA (i.e. higher customer rates, longer and 

more expensive construction of the linear facility, etc.). 

Alternative 2 – Proposed Colorado Roadless Rule (Proposed Action)

If uses are authorized in CRAs in the future, the Regional Forester would be required to

determine if road construction and linear construction zones are allowed. Water uses are

limited to authorized water conveyance structures operated pursuant to a pre-existing water 

court decree [as of the effective date of the rule]. In the upper tier acres, only linear construction 

zones could be used.. 

If roaded or linear construction zone access would be necessary for future water conveyance 

structures that do not currently have a pre-existing water court decree, they could not be 

located in CRAs. This could cause public hardships (i.e. higher customer rates, longer and more 

expensive construction of the linear facility, etc.) if the alternate location outside of CRAs 

proved to be more expensive or had more environmental effects. 

For currently authorized and future authorized water conveyance structures operated pursuant 

to a pre-existing water court decree, roads would be allowed. This would be beneficial to the 

proponents for these new facilities because it does not limit their most modern means of 

construction, operation and maintenance.

Alternative 3 – Forest Plan Direction (No Action)

Other than forest plan direction that discourages or restricts the location of certain SUA facilities 

or restricts road construction, water conveyance structures can be located in IRAs. This can 

benefit the proponent by placing the water conveyance structure in the most feasible and 

economically viable location.

Alternative 4 – Proposed Colorado Roadless Rule with Public Proposed Upper 

Tier

This alternative is the same as alternative 2. There are many more upper tier acres in this 

alternative than alternative 2. Water conveyance structures in the upper tier acres can only use 

linear construction zones for their construction, reconstruction or maintenance. 

All Other Land Uses

As alternative energy sources are explored, proposals for wind energy testing and eventual 

build out, and solar facilities may become more prevalent. To date proposals for wind, solar, 

and geothermal development have focused on NFS lands adjacent to private land that is 

already being developed on ridge tops and on the National Grasslands. Subject to forest plan

direction, special use authorizations for wind and solar facilities could be allowed under all 

alternatives though unlikely under alternatives 1, 2 and 4. Depending on the alternative, road 

construction to these facilities may or may not be allowed. Depending on the alternative, a 

linear construction zone may or may not be allowed for the construction or maintenance of 

these facilities. 

Alternative 1- 2001 Roadless Rule 

If uses are authorized in IRAs in the future, there is no provision for road construction for the 

construction, operation or maintenance of SUAs. Linear construction zones are allowed under 

this alternative. Some SUAs may be able to be constructed or periodically maintained using a 

linear construction zone as opposed to a road. If roaded access would be necessary, there will be 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—265

economic issues for proposed uses that would normally have been located in or near IRAs, if 

now their route would need to be located outside IRAs and that relocation increased 

construction and operation and maintenance costs. Not allowing roaded access to future 

proposed uses could cause public hardships or greater environmental damage (i.e. higher 

customer rates, longer and more expensive construction of the linear facility, etc.) if there were 

additional economic or environmental effects outside of an IRA. However, by not allowing 

additional land uses in IRAs some of the roadless area characteristics may be preserved.

Alternative 2 – Proposed Colorado Roadless Rule (Proposed Action)

Alternative 2 does not allow for roaded access or linear construction zones for any other future 

uses. This would necessitate siting all new facilities outside of CRAs if they would require 

motorized roaded or linear construction zone access for construction, operation and 

maintenance. This would limit options for siting, and could cause economic issues for the 

proponent by limiting options, and environmental concerns for the public and the agency. Not 

allowing additional land uses in CRAs may preserve some of the roadless area characteristics.

Continued avoidance of CRAs for certain authorized third party uses necessitates siting in areas 

adjacent to the CRAs. Allowing additional facilities outside of CRAs may conflict with visual 

and noise objectives for the individual CRA. Site specific NEPA analysis for these uses would

allow for mitigation for potentially conflicting adjacent uses.

Alternative 3 – Forest Plan Direction (No Action)

Forest plans may allow for all these uses, and the associated road construction or linear 

construction zones. Forest plans are normally silent on linear construction zones, and do not 

specifically prohibit them. If not allowed under the current forest plan management direction, 

the Plan may be amended if necessary, with site and project specific NEPA. 

Alternative 4 – Proposed Colorado Roadless Rule with Public Proposed Upper 

Tier

This alternative is the same as alternative 2. 

Lands Special Use Authorizations: Cumulative Effects 

Continued population growth, more need for municipal, agricultural and domestic water, 

development and sale of inholdings, subdividing of long time historic ranch lands, push for 

domestic, renewable, and low-carbon energy sources and the need for connection of those 

sources to electrical grids, need to get products to market via pipelines, power lines, 

telecommunication lines and roads all may affect management of NFS both within and adjacent 

to IRAs and CRAs.

Overall environmental cumulative effects of allowing roaded access to certain described uses, 

and prohibiting roaded access to other similar uses may simply limit siting options and 

environmentally preferable locations that exist within IRAs and CRAs. Economically, 

alternatives 1, 2 and 4 limit options for proponents which may make any future proposal more 

expensive to implement and operate. Socially, benefits and drawbacks exist, depending on 

social values. Another key factor to remember is that all of these uses, no matter where they are 

proposed or are currently located on NFS, trigger some type of site specific NEPA analysis for 

changes to existing uses or proposed new uses. Site specific analysis identifies design criteria, 

Best Management Practices, and monitoring for construction, operation, and maintenance 

which is appropriate for that use and location. Those measures are all required through the 

SUA that authorizes the use and occupancy. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

266—Chapter 3. Affected Environment and Environmental Consequences

LIVESTOCK MANAGEMENT

Livestock grazing is authorized on lands identified through agency planning processes to be 

suitable and capable for such use. Management of livestock grazing in roadless areas is based 

on site-specific analysis, allotment management plans, permit requirements, and forest plan

management direction, in accordance with statute, regulations, and agency policies. 

Livestock Management - Affected Environment

Livestock grazing is managed in portions of many of the roadless areas, as displayed in Table 3-

48. In addition to actively grazed allotments (lands allocated to grazing management), there are 

a number of vacant allotments where there is no current grazing permit in effect but where 

livestock grazing may be permitted in the future. Permitted livestock may include cattle, sheep, 

or other kinds of livestock such as horses. 

Table 3-48. Rangeland and Livestock Management Acres (3,446,167 acres in Analysis Area)

Forest Allotment 

Status IRA/CRA Common CRA Not IRA IRA Not CRA

Arapaho-Roosevelt Active 40,585 322 1,544

Vacant 83,710 757 1,168

GMUG Active 690,928 106,078 252,431

Vacant 36,821 2,712 17,972

Manti-La Sal Active 7,230 449 3,853

Vacant 0 0 0

PSICC Active 136,894 60,080 28,351

Vacant 0 0 0

Rio Grande Active 376,700 2,477 10,620

Vacant 47,910 308 777

Routt Active 366,122 1,365 9,085

Vacant 44,066 105 1,139

San Juan Active 234,141 53,354 61,110

Vacant 207,559 38,080 14,426

White River Active 400,148 2,603 3,220

Vacant 97,236 817 914

Total R2 Colorado Active 2,252,748 226,728 370,214

Vacant 517,302 42,779 36,396

All 2,770,050 269,507 406,610

% of Total Allotment Acres 80.4% 7.8% 11.8%

GMUG = Grand Mesa, Uncompahgre, and Gunnison. PSICC = Pike-San Isabel, Cimarron, Comanche. Totals may 

not add due to rounding.

Livestock grazing use in roadless areas occurs on open grasslands, meadows, riparian areas, 

shrublands, and to a lesser degree in forested areas containing sufficient herbaceous (grassy or 

non-woody) understory vegetation. More than 70 percent of the roadless areas are dominated 

by forest cover types where there is less forage than in grass and forb cover types available for 

livestock grazing. Roadless areas contain relatively small portions of open grasslands, 

meadows, and other expanses of herbaceous or shrubby vegetation. Thus, authorized livestock 

grazing use occurs less extensively in the roadless areas than many other portions of the 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—267

National Forests and National Grasslands in Colorado. 

Livestock management is an important traditional and cultural use of NFS lands, including 

roadless areas. In addition, proper management of livestock grazing plays a critical role in 

rangeland ecosystem health and sustainability, offering potential beneficial effects such as 

maintaining soil quality, biodiversity, wildlife forage habitat, water retention and release 

processes, and some visual and recreational qualities. On the other hand, depending on the 

timing, location, and intensity of permitted livestock grazing, this use can result in detrimental 

impacts on the abundance and diversity of native plant communities; soil, water and riparian

conditions; wildlife and fisheries habitat features; and visual and recreational resources. 

Livestock Management - Environmental Consequences 

All Alternatives

Tree-cutting, sale or removal and road construction/reconstruction activities that differ by 

alternative can affect rangeland vegetation. Those activities can also effect the proper 

management of livestock in the roadless areas. However, those who have grazing permits 

(permittees) for allotments in roadless areas have been able to effectively manage their livestock 

in those areas over long time periods without the necessity of additional roads. Permittees

typically rely on pack and saddle stock to manage the livestock and maintain their range 

improvement structures. In specific instances, a permit may include authorized use of 

motorized vehicles to access specific locations for specific needs associated with their permit. 

Such access would not require construction of a road, but would allow time-specific, overground motorized access to an area. Rangeland management personnel on the National Forests 

in Colorado do not foresee a need for additional roads in roadless areas in support of livestock 

grazing management in those areas over the next 15 years under any alternative. 

The limited roads available in most roadless area grazing allotments can cause increases in 

operating costs for permit holders because of the increased costs of transporting livestock and 

allotment management materials into unroaded portions of the allotment. However, most 

permit holders operating in these areas have already factored in these costs and are accustomed 

to operating under the given conditions and restrictions in roadless areas. For some permittees, 

the added costs of operating in roadless areas are offset by lower costs associated with 

operating in other more roaded areas outside the roadless areas. Roads can also increase 

livestock management costs because they increase the potential for the public to leave livestock 

gates open, cut fences, damage water developments, harass or harm livestock, or disrupt 

grazing systems.

In general, the more potential for road construction, tree-cutting, and related management 

activities in roadless areas, the greater potential there may be for the detrimental effects on 

livestock grazing management (such as leaving gates open, cutting fences, etc.). The alternatives 

allow road construction in roadless areas for specific purposes, and they all limit road 

construction for other purposes. Within the analysis area under any of the alternatives, there is 

limited road construction projected. The road construction is distributed across the analysis

area. Under all alternatives, the roadless areas would be expected to continue to contain 

significantly lower road densities than adjacent NFS lands, excluding wilderness areas. 

Under all alternatives, new roads would generally be closed to public motorized access, and 

most of those roads would be closed and decommissioned after the road is no longer needed for 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

268—Chapter 3. Affected Environment and Environmental Consequences

authorized uses. Although increases in road miles under any alternative could potentially 

increase unauthorized public motorized use, illegal public use of single-use roads in the 

analysis area would not be likely to occur extensively or frequently in any specific grazing 

allotment. Therefore, under any alternative, there would be a low likelihood that the projected 

new roads would significantly affect authorized livestock management use. There may be a 

slightly higher risk of road-related impacts on livestock grazing management under alternative 

3, because of the higher number of projected road miles under that alternative, but this 

difference from the other alternatives is not significant. 

Tree-cutting, sale or removal activities in roadless areas and in the analysis area, as well as 

various fuel management activities, vary by alternative, affecting from approximately 2,300 to 

16,900 acres per year. The tree-cutting, sale or removal is distributed through the analysis area 

under each of the alternatives. Tree-cutting activities have the potential to disturb livestock and 

alter their distribution patterns, as well as the potential for fences to be cut or gates to be left 

open. Immediately after some forest management treatment projects, livestock grazing may be 

restricted from the disturbed areas that are being reseeded and revegetated. However, recent 

tree-cutting activities, such as for fuel reduction treatments, have not typically resulted in 

significant adverse impacts on grazing management in the treatment area. 

Tree-cutting activities tend to open forest canopies, which leads to increases in the abundance of 

forage vegetation for livestock and grazing wildlife species. The prescribed burning that often 

follows tree-cutting for hazardous fuels usually results in further increasing the growth and 

abundance of herbaceous forage vegetation. In addition, if forest treatments in roadless areas 

reduce the severity and size of a wildland fire, the treatments would likely have beneficial 

effects in protecting fences and other livestock grazing management facilities in the treated area. 

Overall, the agency has found that forest management activities to reduce fuel accumulations 

can be conducted in a manner that is compatible with permitted livestock grazing, although 

some permit adjustments are sometimes needed.

While alternative 3 would pose the highest potential for adverse impacts on livestock grazing 

management, there would be no substantial difference in risk to livestock operations under any 

of the alternatives. Under all alternatives the risk would be low for the potential tree-cutting 

activities to result in significant adverse impacts on livestock management.

Livestock Management - Cumulative Effects 

Other public land use activities that occur in the analysis area would have similar effects on 

livestock grazing operations in those allotments that are within roadless areas. For example, 

motorized and non-motorized recreation activities have a similar potential for incidences of 

leaving gates open, cutting fences, harassing or killing livestock, and other effects previously 

described. Recreational use, along with oil, gas, and coal activities, are expected to increase over 

the next 15 years, which would increase potential risks to livestock operations. However, 

human activity in roadless areas would likely continue to be less frequent and less extensive 

compared to activities on more intensively managed lands outside roadless areas. Thus, overall, 

those other activities in roadless areas that are not expected to differ by alternative would not 

substantially affect ongoing or future livestock operations that are authorized in the roadless 

areas. 

Climate change may also impact livestock grazing. Some climate projections indicate increasing 

drought, which can impact water availability for livestock and forage production. In addition, 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—269

drought may provide opportunities for the establishment of invasive plant species, which can 

also reduce forage production. Some projections indicate that there may be increasing wildfires, 

which can pose dangers to livestock. However, the aftermath of fires may see increased forage 

production due to increased sunlight and nutrients to ground vegetation.

Because of the low risk of measurable direct and indirect effects of the alternatives on permitted 

livestock operations, and the low magnitude and frequency of other activities in roadless areas 

likely to substantially alter permitted livestock operations, no significant cumulative effects 

would be anticipated under any of the alternatives. 

ABANDONED MINES AND PUBLIC SAFETY

Abandoned Mines and Public Safety: Affected Environment

Colorado‘s abandoned mine land inventory database shows a total of 21,880 abandoned mine 

features including holes, dumps, and associated facilities occurring on Colorado NFS lands with 

4,229 (19%) of these occurring within the analysis area (Colorado Division of Reclamation Mine 

and Safety 2008 and 2009 USFS-AMLI data). This can be further broken down to 1,694 holes 

ranging from small prospect pits to open shafts and adits, 940 waste and tailings dumps of 

varying sizes, and 1,595 structural features such as head frames and ore bins. More than one 

feature may exist at any one site, and therefore, these total features should not be confused with 

total sites.

Within the IRAs there are 3,266 total features and within the CRAs are 2,887 total features.

Overall, the IRAs in alternatives 1 and 3 include 379 more abandoned mined land features than 

do alternatives 2 and 4 due to the inclusion of the substantially altered acres. The Forest Service 

inventory of abandoned mines on NFS lands is an ongoing process where more sites may still 

be identified than are reclaimed, and therefore, the number of abandoned mine sites within 

roadless areas in Colorado may increase. 

Abandoned mines, quarries, and other mineral sites that pose human health, environmental, or 

safety risks may require some type of reclamation or mitigation. If the sites exist and are 

releasing, or have the potential to release, a hazardous substance, they would require some type 

of response action under the Comprehensive Environmental Response, Compensation and 

Liability Act of 1980 (P.L. 96-510, Stat. 2767; 42 U.S.C. 9601, 9603, 9607, 9620) (CERCLA) (USDA 

Office of Inspector General 1996).

. This act addresses emergency response, site remediation and 

spill prevention. The Forest Service has authority for CERCLA enforcement on NFS lands under 

Executive Order 12580, sec. 2(j). An Engineering Evaluation/Cost Analysis (EE/CA) or 

remedial investigation/feasibility study (RI/FS) would include provisions for proposed road 

construction if needed for CERCLA response actions, consistent with the National Contingency 

Plan, 40 CFR Part 300.

Also, inventoried roadless areas may contain sites that require some type of reclamation to 

resolve violations of the Clean Water Act.

It is common for an abandoned mine to have a road in place from initial development of the 

mine. Some road reconstruction may be needed to improve access to the mine itself to 

accomplish reclamation goals. However, the road improvements are only temporary, as closing 

and reclaiming the mine roads is integral to achieving the overall reclamation goals of the 

abandoned mine land program.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

270—Chapter 3. Affected Environment and Environmental Consequences

Abandoned Mines and Public Safety: Environmental Consequences

All Alternatives

All alternatives allow construction or reconstruction of roads needed to conduct a response 

action under CERCLA or to conduct a natural resource restoration action under CERCLA, Oil, 

and Hazardous Substance Liability – Sec. 311 of the Clean Water Act, or the Oil Pollution Act.

Therefore, under all alternatives, the Forest Service will continue to respond to CERCLA

violations that are encountered at abandoned mines within roadless areas in Colorado. 

Construction or reconstruction of temporary roads for this activity would be permissible. The 

exact number of identified sites that may result in CERCLA violations is not known until site 

specific assessments are completed.

It is expected that most non-CERCLA environmental issues at abandoned mines can be 

addressed by means that do not require road construction or reconstruction.

SOCIAL VALUES

Introduction

The social implications of roadless area management in Colorado are of interest to local 

residents surrounding the roadless areas, users of roadless areas, and people throughout the 

country who value or are interested in roadless area resources. Policy decisions that influence 

the management of roadless areas attempt to balance the wide variety of uses and values 

individuals hold for national forest resources. It is unlikely that any alternative selected in this 

process would satisfy the needs of all those interested in management of roadless areas in 

Colorado. Each alternative entails a compromise between people‘s competing uses and values 

of roadless areas. 

This section includes a description of counties and state-wide demographics and trends within 

Colorado, environmental justice considerations, and potential impacts by alternative on various 

interest groups and their values.

Social Values: Affected Environment 

Demographic information describes the social and economic conditions and trends of human 

populations in specific geographic areas. It allows the decision maker and public to understand 

how population trends influence or are influenced by public land management. 

The population variables considered in this analysis include population and growth trends, age 

composition, racial diversity, and poverty level. Where possible, explanations of trends that are 

not typical for Colorado are provided. Otherwise, trends are assumed to reflect some preference 

or response to natural, physical, or political frameworks, and would be expected to continue in 

the future. 

Population numbers and composition can influence the ability of the area to absorb or adapt to 

changes as well as change the demands locals have for forest products and opportunities. It is 

important to consider any potential changes within the context of trends or changes that are 

occurring outside of Forest Service control, for example the movement of retirees into Colorado 

or changes in preferred recreational activities.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—271

Colorado Populations and Growth Trends

There are 64 counties in Colorado. Table 3-49 highlights the 41 counties with roadless area acres, 

including inventoried roadless area (IRAs) and Colorado roadless areas (CRAs), and the 

percentage of NFS acres within each county in roadless areas. Counties without roadless area 

acres are not included in the analysis. Of the 41 counties with roadless area acres, 16 counties 

have 35 percent or more of the NFS lands within the county in roadless areas. In Moffat, Las 

Animas, and Mesa counties, over half of the NFS lands in the county are within roadless areas. 

There are fewer total acres of CRAs based on adjustments of CRA boundaries compared to IRA 

boundaries. However, in Dolores, Jefferson, Las Animas, Montezuma, Montrose, Ouray, Park, 

Pueblo and San Miguel Counties there are more total CRA acres than IRA acres; due to the 

unroaded areas outside IRAs that were included in CRAs (refer to Appendix A, IRA and CRA 

acres and names). 

Table 3-49. Colorado counties with IRA and CRA acres

County

National Forest 

System lands

IRA acres, 

alternatives 

1 and 3

Percent of NFS

acres that are 

w/in IRAs

CRA acres, 

alternative 2

Percent of NFS

acres that are 

w/in CRAs

Archuleta 430,000 125,500 29% 109,400 25%

Boulder 138,000 22,600 16% 22,000 16%

Chaffee 457,000 180,000 39% 189,600 41%

Clear Creek 175,000 62,800 36% 59,000 34%

Conejos 301,000 65,700 22% 64,000 21%

Costilla 1,000 - - 500 50%

Custer 162,000 60,900 38% 75,200 46%

Delta 192,000 85,300 44% 77,900 41%

Dolores 335,000 69,700 21% 88,800 27%

Douglas 142,000 57,500 40% 61,800 44%

Eagle 596,000 231,000 39% 229,900 39%

El Paso 101,000 12,000 12% 22,200 22%

Fremont 100,000 43,200 43% 48,500 49%

Garfield 516,000 85,400 17% 85,400 17%

Grand 572,000 182,500 32% 185,400 32%

Gunnison 1,276,000 501,900 39% 398,400 31%

Hinsdale 559,000 133,100 24% 125,500 22%

Huerfano 141,000 47,200 33% 51,200 36%

Jackson 333,000 60,500 18% 59,900 18%

Jefferson 105,000 27,400 26% 29,000 28%

La Plata 404,000 191,700 47% 199,400 49%

Lake 162,000 53,900 33% 55,900 35%

Larimer 648,000 154,800 24% 152,400 24%

Las Animas 22,000 13,300 60% 14,900 68%

Mesa 548,000 288,200 53% 283,900 52%

Mineral 525,000 207,000 39% 202,300 39%

Moffat 42,000 28,200 67% 28,100 67%

Montezuma 257,000 40,900 16% 52,200 20%

Montrose 327,000 21,900 7% 33,200 10%

Ouray 132,000 11,600 9% 21,500 16%

Park 650,000 132,900 20% 170,300 26%

Pitkin 496,000 104,700 21% 104,800 21%
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

272—Chapter 3. Affected Environment and Environmental Consequences

County

National Forest 

System lands

IRA acres, 

alternatives 

1 and 3

Percent of NFS

acres that are 

w/in IRAs

CRA acres, 

alternative 2

Percent of NFS

acres that are 

w/in CRAs

Pueblo 33,000 9,500 29% 17,600 53%

Rio Blanco 359,000 169,700 47% 169,600 47%

Rio Grande 280,000 87,600 31% 86,600 31%

Routt 583,000 222,100 38% 215,000 37%

Saguache 932,000 304,900 33% 231,200 25%

San Juan 174,000 62,200 36% 68,900 40%

San Miguel 177,000 18,600 11% 21,800 12%

Summit 313,000 59,100 19% 57,000 18%

Teller 125,000 14,100 11% 17,400 14%

TOTAL 13,885,000 4,249,000 31% 4,186,000 30%

Totals may not add due to rounding

Source – County data is from USDOC Census Bureau, 2000 census. Roadless area data is from the GIS roadless areas database, 

April 2008

In general, the population within Colorado has been increasing since 1900. Colorado saw rapid 

growth in the 1980s and early 1990s. More recently, the rate of growth has leveled off, but the 

population is still increasing. Figure 3-1 shows the population trend for Colorado from 1900 to 

2000 and then projected through 2030. 

Figure 3-1. Colorado estimated population from 1900 to 2000 and projected for 2010 to 2030

*Source: State of Colorado, Division of Local Affairs - State Demography Office Website, 4/11/08

Overall, Colorado‘s population increased about 2 percent between 2000 and 2005, from about 

4,338,800 to 4,718,600, and is expected to continue growing at 2 percent until 2020 when growth 

slows slightly to 1.6 percent. Within the counties with roadless area acres in them, Archuleta, 

Chaffee, Custer, Delta, Douglas, Eagle, Garfield, Grand, Lake, Mesa, Montrose, Park, San 

Miguel, and Summit counties are projected to have higher growth rates than the State average, 

but the trend is similar in that growth will continue and begin to decline between 2015 and 

2020. Reasons for the growth in Colorado include the oil and gas boom on the western slope as 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—273

well as the continued influx of retirees into the State (Colorado Department of Local Affairs, 

State Demography Office 2008). 

Age Composition

Figure 3-2 highlights the age distribution estimates for Colorado for 1990 and 2000 and 

projections to 2030. As with the national trend of the aging baby boomers, Colorado is expecting 

a significant increase in the over 65 age category beginning in 2010. The Colorado Demography 

Office is predicting that between 2000 and 2030, Colorado‘s population of people 65 and above 

will triple in size from 400,000 to 1.2 million (Colorado Department of Local Affairs, State 

Demography Office 2010). This growth is greater than would be expected merely from the 

aging of Colorado‘s current population, indicating that retirees from outside Colorado will be 

moving to the State. It is expected that this retiree population will be an economic driver, 

creating between .3 and .4 jobs per person over 65. The majority of these jobs would be service 

oriented or within the health care industry.

Figure 3-2. Colorado population by age, estimated for 1990 and 2000, projected for 2010 to 2030 

Source: State of Colorado, Department of Local Affairs - www.dlg.oem2.state.co.us/demog/, 4/11/08

The recession that began in December 2007 has slowed economic growth in Colorado and has 

slowed some of the expected flow of retirees into the State. But as the nation and Colorado 

continues to regain economic health, the retiree trends are expected to return to previous rates.

Racial Diversity

Racial diversity is displayed for the current population in Colorado and projected through 2030 

in Figure 3-3. Overall, Colorado has limited diversity relative to the entire U.S. However, the 

trend in Colorado, as with the national trend, is toward more racially diverse populations. The 

State average is not reflective of many individual counties in Colorado. Counties in the southern 

San Luis Valley, as well as many counties on the western slope, have significantly higher 

Hispanic populations than the State average. 

In some cases, demands for resource opportunities in roadless areas may change over time as 

the numbers of different racial and ethnic groups increase in communities around national 

forests. Different ethnic groups often have different ways of recreating on or using public lands. 

-

1,000,000

2,000,000

3,000,000

4,000,000

5,000,000

6,000,000

7,000,000

8,000,000

1990 2000 2010* 2020* 2030*

Year Estimated and *Projected

Estimated and Projected Population

65-90+ years

55-64 years

40-54 years

20-39 years

0-19 years
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

274—Chapter 3. Affected Environment and Environmental Consequences

Current Forest Service management and assumptions about how people use the national forest 

is likely to change as the population surrounding the forest changes. For example, limits on 

group sizes and numbers of vehicles allowed within developed sites may not be reflective of 

larger family gatherings that some people desire to hold on public lands (Chavez 2000, Chavez 

2005).

The following discussion of environmental justice includes more specific information on racial 

diversity, as well as the poverty level for each county with roadless area acres (roadless area 

counties). 

Figure 3-3. Colorado population by racial group estimated for 2000 to 2005 and projected for 2010 

to 2030

*Source: State of Colorado, Department of Local Affairs - State Demography Office Website 4/11/08

For more detailed information, Appendix G social and economic data tables, includes maps displaying demographic

information for all counties in Colorado. 

Environmental Justice

Executive Order (EO) 12898 directs federal agencies to focus attention on the human health and 

environmental conditions in minority and low-income communities. The purpose of EO 12898 

is to identify and address, as appropriate, disproportionately high and adverse human health or 

environmental effects on minority and low-income populations. 

Table 3-50 was developed from 2000 Census Bureau data. It highlights the minority group 

composition of the roadless area counties compared to Colorado State statistics. A minority 

population exists if the minority population of the affected area exceeds 50 percent or the

minority population percentage of the affected area is meaningfully greater than the minority 

population percentage in the general population or other appropriate unit of geographic 

analysis (Council on Environmental Quality 1997). The table shows that Alamosa, Eagle, 

Huerfano, Lake, Las Animas, Pueblo, Rio Grande, and Saguache Counties have minority 

0%

20%

40%

60%

80%

100%

2000 2005 2010* 2015* 2020* 2025* 2030*

Population Estimated and Projected*

Percent of Population

Hispanic Origin

Asian/Pacific Islander, nonhispanic

American Indian, non-hispanic

Black, non-hispanic

White, non-hispanic
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—275

populations larger than the State average, and Conejos and Costilla County in the San Luis 

Valley have the largest minority populations. Table 3-50 also displays the percent of individuals 

living below the poverty level by county and by State, and displays the percentage of 

households that heat with wood as their primary heat source, which is another low income

indicator. In some areas of the State, the percentage of households heating with wood is an 

important factor to consider when looking at potential impacts of Forest Service actions because 

many low income families gather and use wood as their primary source of affordable heat. 

Table 3-50. Environmental justice statistics for roadless area counties in Colorado

State/

County

2000 

population

Percent 

Black or 

African 

American

Percent 

American 

Indian,

Alaska 

Native

Percent 

Asian, 

Native 

Hawaiian, 

other 

Pacific 

Islander

Percent 

some 

other 

race

Percent 

two or 

more 

races

Percent 

Hispanic 

or Latino, 

any race

Percent 

below 

poverty 

level

Percent 

heat 

with 

wood

Colorado 4,301,261 3.7% 0.7% 2.3% 0.1% 2.8% 17.1% 9.3% 1.0%

Alamosa 14,966 1.0% 2.3% 1.0% 20.3% 4.2% 41.4% 21.3% 5.3%

Archuleta 9,898 0.4% 1.4% 0.3% 7.0% 2.6% 16.8% 11.7% 9.0%

Boulder 291,288 0.9% 0.6% 3.1% 4.7% 2.2% 10.5% 9.5% 0.5%

Chaffee 16,242 1.6% 1.1% 0.5% 4.2% 1.7% 8.6% 11.7% 6.5%

Clear Creek 9,322 0.3% 0.7% 0.4% 1.0% 1.2% 3.9% 5.4% 4.8%

Conejos 8,400 0.2% 1.7% 0.2% 21.5% 3.6% 58.9% 23.0% 11.1%

Costilla 3,663 0.8% 2.5% 1.1% 29.5% 5.2% 67.6% 26.8% 12.2%

Custer 3,503 0.4% 1.1% 0.3% 0.7% 1.6% 2.5% 13.3% 6.8%

Delta 27,834 0.5% 0.8% 0.3% 4.3% 1.8% 11.4% 12.1% 6.7%

Dolores 1,844 0.1% 2.0% 0.4% 0.6% 1.7% 3.9% 13.1% 8.6%

Douglas 175,766 1.0% 0.4% 2.6% 1.4% 1.9% 5.1% 2.1% 0.3%

Eagle 41,659 0.3% 0.7% 0.9% 10.8% 1.9% 23.2% 7.8% 1.9%

El Paso 516,929 6.5% 0.9% 2.8% 4.7% 3.9% 11.3% 8.0% 0.3%

Fremont 46,145 5.3% 1.5% 0.6% 1.2% 1.8% 10.3% 11.7% 2.2%

Garfield 43,791 0.4% 0.7% 0.5% 6.5% 1.8% 16.7% 7.5% 2.7%

Gilpin 4,757 0.5% 0.8% 0.9% 1.5% 1.9% 4.2% 4.0% 9.6%

Grand 12,442 0.5% 0.4% 0.8% 2.0% 1.1% 4.4% 7.3% 6.6%

Gunnison 13,956 0.5% 0.7% 0.6% 1.4% 1.7% 5.0% 15.0% 7.6%

Hinsdale 790 0.0% 1.5% 0.3% 0.4% 0.5% 1.5% 7.2% 14.8%

Huerfano 7,862 2.7% 2.7% 0.5% 9.4% 3.7% 35.1% 18.0% 4.4%

Jackson 1,577 0.3% 0.8% 0.1% 1.5% 1.3% 6.5% 14.0% 4.8%

Jefferson 527,056 0.9% 0.8% 2.4% 3.2% 2.2% 10.0% 5.2% 0.5%

Lake 7,812 0.2% 1.3% 0.4% 18.0% 2.6% 36.1% 12.9% 4.8%

La Plata 43,941 0.3% 5.8% 0.5% 3.9% 2.3% 10.4% 11.7% 5.9%

Larimer 251,494 0.7% 0.7% 1.6% 3.4% 2.2% 8.3% 9.2% 0.7%

Las Animas 15,207 0.4% 2.5% 0.6% 10.0% 3.8% 41.5% 17.3% 2.9%

Mesa 116,255 0.5% 0.9% 0.6% 3.7% 2.0% 10.0% 10.2% 1.7%

Mineral 831 0.0% 0.8% 0.0% 0.1% 2.2% 2.0% 10.2% 19.4%

Moffat 13,184 0.2% 0.9% 0.4% 3.2% 1.8% 9.5% 8.3% 2.0%

Montezuma 23,830 0.1% 11.2% 0.3% 4.3% 2.4% 9.5% 16.4% 8.9%

Montrose 33,432 0.3% 1.0% 0.5% 5.7% 2.5% 14.9% 12.6% 6.7%

Ouray 3,742 0.1% 0.9% 0.4% 0.5% 1.7% 4.1% 7.2% 9.2%

Park 14,523 0.5% 0.9% 0.4% 1.2% 1.8% 4.3% 5.6% 8.8%

Pitkin 14,872 0.5% 0.3% 1.2% 2.4% 1.3% 6.5% 6.2% 2.8%

Pueblo 141,472 1.9% 1.6% 0.7% 12.9% 3.4% 38.0% 14.9% 0.6%

Rio Blanco 5,986 0.2% 0.8% 0.3% 2.0% 1.7% 4.9% 9.6% 3.7%

Rio Grande 12,413 0.3% 1.3% 0.2% 21.4% 2.8% 41.7% 14.5% 6.9%

Routt 19,690 0.1% 0.5% 0.5% 0.7% 1.3% 3.2% 6.1% 4.5%
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

276—Chapter 3. Affected Environment and Environmental Consequences

State/

County

2000 

population

Percent 

Black or 

African 

American

Percent 

American 

Indian,

Alaska 

Native

Percent 

Asian, 

Native 

Hawaiian, 

other 

Pacific 

Islander

Percent 

some 

other 

race

Percent 

two or 

more 

races

Percent 

Hispanic 

or Latino, 

any race

Percent 

below 

poverty 

level

Percent 

heat 

with 

wood

Saguache 5,917 0.1% 2.1% 0.5% 23.0% 3.1% 45.3% 22.6% 7.6%

San Juan 558 0.0% 0.7% 0.5% 0.7% 0.9% 7.3% 20.9% 11.1%

San Miguel 6,594 0.3% 0.8% 0.8% 3.4% 1.1% 6.7% 10.4% 7.8%

Summit 23,548 0.7% 0.5% 0.9% 4.0% 2.1% 9.8% 9.0% 2.7%

Teller 20,555 0.5% 1.0% 0.7% 0.9% 2.0% 3.5% 5.4% 6.3%

Source: USDOC Census Bureau, 2000 census; For more detailed information, Appendix G, social and economic data tables, includes 

maps displaying demographic information for all counties in Colorado. 

The State had about 9 percent of the total population living below the poverty level in 2000. 

Alamosa, Conejos, Costilla, Saguache, and San Juan counties all had individual poverty rates of 

20 percent or higher in 2000. In addition, Conejos, Costilla, and Saguache Counties also had 

higher levels than the State average of households heating with wood. The aforementioned

counties are within the southern San Luis Valley in southern Colorado, and have historically 

seen lower income levels and higher minority populations than the rest of Colorado.

Within the southern San Luis Valley, many rural Hispanic families continue to live in 

traditional ways on lands farmed by their ancestors. Many families operate outside the cash 

economy, relying on access to public lands for resources they need. Their uses include

subsistence hunting and gathering, gathering wood for heating and cooking, grazing small 

herds of domestic animals under permit, and gathering traditional cultural products (Romero et 

al. 2001).

Civil Rights

A civil rights impact analysis was completed for this proposed rulemaking process and 

approved by the WO Civil Rights Department. The document is available in the EIS record and 

summarized here.

The Colorado Roadless Proposed Rule and EIS have been reviewed and analyzed to ensure 

compliance with Departmental Regulation (DR) 4300-4, Civil Rights Impact Analysis; 7 CFR 

15d, Nondiscrimination in Programs and Activities Conducted by the United States Department 

of Agriculture DR 1512-1 Regulatory Decision-Making requirements and to identify actual or 

potential adverse effects based on race, sex, national origin, age, and disabilities.

Purpose of a Civil Rights Impact Analysis (CRIA)

The CRIA describes the civil rights implications of policies, actions or decisions that will affect 

the USDA workforce or federally conducted or assisted programs and activities. The CRIA 

provides information about the potential adverse effects of a decision, program, or activity; how 

and to what degree the effects would be demonstrated; and whether the originally planned 

policy, action, decision, program, or activity should be modified or otherwise changed if 

possible to ensure increased benefits or more effective outcomes.

The CRIA helps to advise USDA policy makers, managers, and administrators about whether 

the action or decision would have the effect of unintentionally or otherwise illegally 

discriminating against USDA customers based on race, sex, national origin, age, and disabilities.

Also, the CRIA serves to advise USDA policy makers, managers, and administrators of the 

effectiveness of decisions as related to ensuring efficient, appropriate allocation or distribution 

of goods and services in a manner that ensures compliance with all the laws, rules and 

regulations under which USDA must operate.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—277

USDA Civil Rights Policy

The Civil Rights Policy for the USDA, Departmental Regulation 4300-4 dated May 30, 2003, 

states that the following are among the civil rights strategic goals; (1) Managers, supervisors, 

and other employees are held accountable for ensuring that USDA customers are treated fairly 

and equitably, with dignity and respect; and (2) equal access is assured and equal treatment is 

provided in the delivery of USDA programs and services for all customers. This is the standard 

for service to all customers regardless of race, sex, national origin, age, or disabilities.

Colorado Roadless Rule CRIA

Disparate impact, a theory of discrimination, has been applied to the Colorado Roadless Rule in 

order to determine if there are negative effects that may unfairly and inequitably impact 

beneficiaries of program development, administration, and delivery. The objectives of this 

review and analysis are to prevent disparate treatment and minimize adverse Civil Rights 

impacts that may have caused an effect of discrimination against minorities, women or persons 

with disabilities and to ensure compliance with all Civil Rights statutes, Federal regulations, 

and USDA policies and procedures.

The Colorado Roadless Rule CRIA, using USDA Forest Service Civil Rights and 

Social/Economic direction, Executive Order 12989, Council of Environmental Quality National 

Environmental Policy Act direction and required analysis within the FEIS, sought to determine 

whether:

all minorities, women and persons with disabilities are provided the same opportunities 

to participate in the Colorado Roadless rulemaking process;

all minorities, women and persons with disabilities are provided the same or improved 

opportunities to access information about or have access to roadless areas as managed 

under the Colorado Roadless Rule.

The CRIA revealed no adverse effects associated with the Colorado Roadless rulemaking

process or the final rule on the participation of any persons or groups based on race, sex, 

national origin, age, or disabilities. The process was open to the participation of all individuals 

or groups. There were no known barriers at the public meetings; 

all were open to the public,

all were advertised locally through Forest networks, and 

all meeting facilities were accessible to the public including persons with disabilities. 

Under all four alternatives, there would be no difference in opportunities for women, 

minorities, or persons with disabilities.

Social Values and Interests

Social concerns are broad and complex enough that they do not constitute a single issue that can 

be easily measured and addressed. Generally, the values people hold with respect to forest 

resources are the measures used to assess if alternatives will have positive or negative impacts 

on various individuals or groups. There are many definitions of value; for this analysis it is 

assumed that we can understand forest values, such as biological diversity, recreation, or 

subsistence, by understanding what is important to people (USDA Forest Service 2003b).

Forest values represent the importance and worth that people have assigned to Colorado 

roadless areas. Table 3-51 lists, in alphabetical order, major categories of forest values that 

individuals may hold for any forest resource or opportunity. People can hold multiple values 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

278—Chapter 3. Affected Environment and Environmental Consequences

for the same resource, or may hold very separate values for specific places or experiences. The 

same place or roadless area will have different values for different people.

Table 3-51. Examples of forest values 

Forest value Description of why people hold this value

Aesthetic Value the forest because of the scenery, sights, sounds, smells, etc.

Biological diversity Value the forest because it provides a variety of fish, wildlife, plant life, etc.

Cultural Value the forest because it is a place to practice and pass down wisdom, knowledge, and 

traditions

Economic Value the forest because it provides timber, minerals, oil/gas/coal, or tourism opportunities (for 

outfitters/guides)

Future Value the forest because it allows future generations to experience the forest as it is now

Historic Value the forest because it has places and things from natural and human history that are 

important

Intrinsic Value the forest in and of itself, just to know it exists, no use is needed to gain value

Learning Value the forest because one can learn about the environment through scientific observation 

or experimentation

Life sustaining Value the forest to produce, preserve, clean, and renew air, soil, and water

Recreation Value the forest because it provides a place for outdoor recreation activities

Spiritual Value the forest for sacred, religious, or spiritually special places, and for providing a feeling of 

reverence and respect for nature

Subsistence Value the forest because it provides necessary food and supplies to sustain life for individuals

Therapeutic Value the forest for physical and/or mental health

Source: Brown and Reed 2000, page 243

Conflicts can occur when individuals or groups hold different forest values for the same 

resource or place. It is difficult to measure forest values, so specific information is limited, yet it 

is differences in values that create resource management conflicts. Resolving issues resulting 

from conflicting forest values is a political problem and cannot be corrected by simply counting 

or measuring the values more rigorously (USDA Forest Service 1995a). The debate about 

roadless area conservation reflects the broader question of how demands for the many values 

that national forests and grasslands provide should be met. Much of the public comment during 

the 2001 Roadless Rule development was rooted in the more fundamental issues of how NFS

lands should be managed and how to balance commodity and non-commodity values. Those

issues are discussed at length in the 2001 Rule FEIS and associated specialist report 

(http://roadless.fs.fed.us/documents2.shtml). 

The values and interests included in this analysis are based on the many responses to comments 

the public has provided during the 2001 Roadless Rule comment periods, the 2006 Colorado 

Task Force public hearings, the 2007 Colorado Rulemaking Notice of Intent comment period, 

and the comment period for the Draft Environmental Impact Statement. The identified values 

and interests are not based on a random sample; people who chose to respond to a Forest 

Service comment period are self-selected. By focusing on those who commented, the analysis 

focuses on those people who hold strong values regarding roadless area resources. 

This analysis centers on nine broad categories of roadless values/interests, based on the 

comments received. The categories, defined in Table 3-52, are used to display the differences 

between alternatives, and do not define specific individuals or groups. 

Several assumptions underlie this analysis:

People make choices or reflect their preferences based on what is important to them 

(Kleindorfer et al. 1993).
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—279

An individual may hold one or more of the values/interests in roadless areas described 

in this section. Consequently, the impacts of the alternatives on specific individuals may 

be cumulative, mixed, or singular, depending on how many different values the 

individual holds. For example, a person may hold values similar to those of the 

preservation category when considering wildlife habitat, but may hold values similar to 

the non-motorized recreation category when considering access to recreational 

opportunities. 

Management actions within roadless areas that are inconsistent with people‘s forest 

values are perceived by them as threatening and undermining to their values. 

The ability of forest users to continue to engage in current or future use of roadless area 

lands and to maintain the quality of their experience is tied to the ecological health of the 

natural resources found there.

The majority of uses occurring in roadless areas begin with developed infrastructure 

outside of the roadless area (road, trailhead, campground, boat ramp, etc.).

Table 3-52. Forest value/interest categories used for Colorado roadless area analysis

Value/Interest category Defined for Colorado roadless area analysis

Conservation Values the balancing of roadless area management between management of resources for 

various land uses and areas where natural processes dominate.

Industry access Values commercial activities such as timber, oil and gas development, mining, coal

extraction, utilities, and other uses where appropriate in roadless areas. Values future 

access as needed to facilitate continued resource development and support for resource 

jobs and income.

Preservation Values roadless areas for the natural processes and opportunities provided without 

additional management or infrastructure development. Much of the value is in knowing 

roadless areas exist and are protected from future development, rather than associated 

with actual use or visitation. 

Recreational use –

motorized

Values focus on maintaining current motorized use of roadless areas for recreational 

opportunities, as well as, where appropriate, increasing backcountry motorized 

opportunities in the future, which may be trails/single track rather than roads.

Recreational use –

non-motorized

Values maintaining or expanding non-motorized opportunities in roadless areas. There is 

some division in this category between those interested in mechanized use (mountain 

bikes) and those who would like to limit access to hiking and horses. Overall the desire is 

for quiet/non-motorized experiences in roadless areas.

Roaded access Values gaining access via roads to the forest, including roadless areas. For some, driven 

by need or disability, the desire for roaded access is due to the inability to get into the 

forest without the road system. For others, roaded access is the preferred method of travel, 

and the travel itself is the recreational experience.

Tourism (including ski 

resorts)

This category is another commercial interest, but capitalizes on the roadless area as a 

natural amenity that attracts customers to the area for leisure activities. Scenery is of 

concern to this category, but the value of road construction depends on the types of 

experiences the operation is providing.

Wilderness Values roadless areas as land that can be included within the wilderness system in the 

future. This category focuses on future primitive and protected wilderness experiences and 

wilderness resources.

Wildland-urban interface This category is specific to those activities in WUI (community protection zone per 

alternatives 2 and 4) or areas identified in a CWPP that overlap in roadless areas where 

fuel treatments are desired to reduce wildland fire hazards. This category values reducing 

wildland fire hazards for houses and communities. This category does not focus on 

individuals living within the WUI.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

280—Chapter 3. Affected Environment and Environmental Consequences

Social Values: Environmental Consequences

All Alternatives

None of the alternatives would change the demographic conditions and trends described in the 

affected environment. The increasing and changing population growth, along with changes in 

age and racial diversity, would have some impacts on NFS lands in terms of the types of 

resources and opportunities people demand from their public lands. The effects of increasing 

demands for the resources in roadless areas are discussed in other sections of this EIS. 

Public comments revealed strong support for roadless protection from individuals and groups 

who view the highest value of roadless areas in Colorado to be maintained through 

preservation/non-development, as well as strong support for roadless management from 

individuals and groups who view a balanced management approach that allows some 

development and extractive uses to be the best use of the roadless areas. 

Each of the four alternatives differs in the balance points between key conflicting values. Effects 

on values and interests are described in terms of the nine key categories outlined in Table 3-52. 

The analysis presented by alternative below uses public comments for each category to describe 

the potential effects of and differences between the four alternatives.

Alternative 1 – 2001 Roadless Rule

In terms of environmental justice indicators, the southern San Luis Valley appears to be an area 

where access to NFS lands is important for families to maintain their rural lifestyle. Alternative 

1 would not allow additional road construction, but would not close or limit use of existing 

roads in roadless areas (substantially altered areas), so fuel wood gathering from an existing 

road system could continue. It is likely the local district would continue to plan vegetation 

management projects along existing road systems, so future fuel wood would likely be 

available. If the majority of these projects were for community wildfire protection, families 

interested in gathering fuel wood would have a short commute to those project areas. The 

actual availability of fuel wood is dependent on district ranger decisions, but fuel wood would 

likely be available in the future. Using public comments received on the DEIS, the impacts of 

alternative 1 on the nine categories of social values and interests are as follows.

Conservation. In the conservation balance between land use management and allowing natural 

processes to dominate, this alternative offers a limited ability to actively manage forest 

resources now and in the future, focusing more heavily on allowing natural processes to 

dominate. While the limitation on road construction could prevent future resource damage, the 

majority of land use management within the IRAs would also be limited. The newly identified 

roadless acres that are not within IRAs could be actively managed under this alternative as 

allowed by forest plan direction.

Industry Access. The potential economic impacts to industry access into roadless areas are 

considered specifically in the Economic Values section of this analysis. Because of limited road 

construction exceptions, alternative 1 limits future commercial activity such as timber harvest, 

and coal and oil/gas extraction. Some limited timber harvest may occur in the substantially 

altered acres as well as within the newly identified roadless areas that are not IRAs where 

harvesting is allowed by forest plan direction. The majority of IRA acres would remain roadless 

with restrictions on activities thereby limiting future commercial activity. 

Preservation. Limits on future activity will maintain the majority of acres in IRAs in their 

current condition, allowing natural processes to take place. Some tree-cutting, and existing 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—281

roaded access would continue on substantially altered acres which would detract from roadless 

area characteristics. Depending on forest plan direction, there may be tree-cutting and road 

construction in the newly identified roadless acres that are not within IRAs which could detract 

from roadless area characteristics. None of the IRA acres would have the additional restrictions 

provided for upper tier acres.

Recreational use – motorized. Any additional road construction in IRAs under alternative 1 

would be limited and likely not change the current level of roaded access. Overall, forest travel 

management decisions may have more impacts on motorized travel than a roadless rule. There 

would be no impact on off-road motorized recreation use within IRAs. The newly identified 

roadless areas that are not within IRAs could for provide opportunities for road construction for 

motorized recreational use in the future.

Recreational use – non-motorized. Similar to the motorized category, the forest travel 

management decisions will have a greater impact on the non-motorized recreation use than a 

roadless rule. None of the IRA acres would have the additional restrictions provided for upper 

tier acres.

Roaded access. This alternative is the most restrictive for this category in terms of the 

exceptions, but does not include the additional restrictions on road construction provided on

upper tier acres. Even though the majority of roads constructed under any alternative would 

likely be closed to public motorized use, alternatives 1, 2 and 4 all limit the possibility for future 

NFS roads within roadless areas. The newly identified roadless areas that are not within IRAs 

could continue to provide new roaded access according to forest plan direction. As with the 

recreational use categories, the travel management plans will have a greater impact on roaded 

access than a roadless rule. 

Tourism. The impacts on tourism parallel those of the recreational categories. Tourism 

operations that focus on motorized opportunities on roads would continue to operate on 

existing roads or on new roads constructed in the newly identified roadless areas that are not 

within IRAs and use existing access points and motorized trails. New roads constructed under 

exceptions in the rule may or may not be closed to motorized use by the general public. Nonmotorized tourism opportunities may be enhanced by limitations on new roads and tree-cutting 

to although the additional restrictions provided for upper tier acres would not be in place. 

Specific to the ski industry, alternative 1 may limit future expansions into IRA acres 

surrounding existing permit boundaries.

Tourism operations of all kinds in Colorado use the scenery on NFS lands to advertise. 

Alternative 1 would continue to limit additional road construction and tree-cutting in roadless 

areas which may maintain scenery. However, with recent beetle epidemics, much of the scenic

quality of NFS lands will be altered inside and outside roadless under any alternative. 

Wilderness. No wilderness is recommended and no activities are allowed that would change 

the current status of a recommended wilderness. For future wilderness potential, alternative 1 is 

viewed by some groups as the best alternative, although the additional, more wilderness-like

restrictions provided for upper tier acres would not exist under alternative 1. Projected road 

construction and tree-cutting levels under this alternative would generally be less than under 

the other alternatives. Alternative 1 would allow use and maintenance of existing roads and 

some tree-cutting, sale or removal within substantially altered acres and the character of those 

areas would continue to be inconsistent with wilderness. Roadless areas will continue to be 

open to motorized and mechanized trail use unless otherwise closed by forest travel 

management plans. Motorized and mechanized use detracts from the wilderness experience 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

282—Chapter 3. Affected Environment and Environmental Consequences

within IRAs. In addition, the newly identified roadless acres that are not within IRAs could 

have some road construction and tree-cutting activities that could render those 409,500 acres not 

suitable for recommendation as wilderness in the future. 

Wildland-urban interface. Alternative 1 offers limited flexibility and access to address 

wildland-urban interface (WUI) concerns. Future fuels projects would be limited to those areas 

that can be accessed via existing road systems, or to tree-cutting activities within substantially 

altered acres. The Economic Values and Fire and Fuels sections of this analysis address the 

potential community impacts in more detail.

Alternative 2 – Colorado Roadless Rule (Proposed Action)

Using public comments received on the DEIS the impacts of alternative 2 on the nine categories 

of social values and interests are described as follows.

Conservation. In the conservation balance between land use management and allowing natural 

processes to dominate, this alternative would offer a limited ability to actively manage forest 

resources now and in the future. The majority of active management would be for treatments 

within the CPZ to address wildfire concerns of at-risk communities, within the North Fork Coal 

mining area for access to future coal reserves, and for water conveyance structures associated 

with existing water rights. The majority of CRAs, including those new CRA acres, would retain 

roadless area characteristics, and those acres in the upper tier would have additional 

restrictions. The substantially altered acres would be open for additional management 

according to the forest plan direction.

Industry Access. The potential economic impacts to industry from limited access into roadless 

areas are considered specifically in the Economic Values section of this analysis. Because of 

limited road construction exceptions and the additional restrictions on the upper tier acres, 

alternative 2 limits commercial activity such as timber harvest, and coal and oil/gas extraction. 

Existing lease activity would continue, but future leases would prohibit road construction. Coal 

exploration would continue on the 20,000 acres within the North Fork Coal mining area, but 

would not be allowed elsewhere in the CRAs. Some timber cutting would be allowed in CPZs 

and to protect municipal watersheds. The substantially altered acres would be open for access 

in accordance with forest plan direction.

Preservation. Alternative 2 allowances for additional road construction and tree-cutting, sale or 

removal would be focused within the CPZ around communities. Other exceptions for coal

development or water conveyance would be limited or spread over several CRAs. Removing 

the substantially altered acres from CRAs reduces the total acres included under a roadless rule, 

although adding the additional 409,500 unroaded acres into CRAs increases the restrictions of 

future road construction and tree-cutting on those acres. The restriction on additional oil and 

gas pipelines from sources outside of CRAs through a CRA would also prevent some pipeline 

activity in a CRA that could be allowed under alternative 1. Additional restrictions on activities 

in upper tier acres would further increase the preservation of roadless area characteristics. 

Recreational use – motorized. There would be little difference from the impacts stated under 

alternatives 1, above. Any additional road construction in CRAs under alternative 2 would be 

limited and likely not change the current level of roaded access. Overall, forest travel 

management decisions may have more impacts on motorized travel than a roadless rule. There 

would be no impact on off-road motorized recreation use within CRAs. Any additional road 

construction would generally be temporary and closed to public motorized use, so there would 

be no increase in roaded opportunities. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—283

Recreational use – non-motorized. As stated under alternative 1, above, the forest travel 

management decisions will have a greater impact on the non-motorized recreation use than a 

roadless rule. The road construction/reconstruction restrictions on upper tier acres in 

alternative 2, would restrict most road construction activity, and benefit non-motorized 

recreation values.

Roaded access. Like alternative 1, alternative 2 would not provide additional road access.

Public motorized access would not be allowed on the roads constructed under the exceptions of 

the proposed rule. In addition, the newly identified roadless acres would be included within the 

CRAs and would limit additional roaded opportunities on those 409,500 acres, and the upper 

tier acres would be managed with further restrictions on potential road construction.

Tourism. As with the recreational categories, there is not much additional roaded access. 

Specific to the ski industry, this alternative would allow limited expansions of ski areas not 

allowed in alternative 1 (see Developed Ski Areas section for details). Alternative 2 may create 

some short term declines in scenery within the CPZ. Over time, the temporary roads and treecutting allowed within the CRA acres may provide for improved scenery compared to the rest 

of the CRA acres depending on the outcome of the beetle epidemics. 

Wilderness. The exceptions for road construction and tree-cutting in alternative 2 are viewed by 

some groups as not offering the same protection for potential future wilderness as alternative 1. 

CRAs do not include the substantially altered acres which, under alternative 1, are not required 

to be returned to a roadless state. Over all, alternative 2 has 57,600 fewer acres within the 

roadless inventory than alternative 1. Alternative 2 would protect 409,500 unroaded acres as 

CRAs that would not be protected under alternatives 1 or 3. The additional protection under 

alternative 2 could increase the areas‘ potential for future wilderness over that of alternatives 1 

or 3. Wilderness interests concerned that management of the 409,500 acres under forest plan

direction would open those acres for additional activities would prefer alternative 2. In 

addition, additional protections for upper tier acres in alternative 2 would retain more roadless 

area characteristics over time on those acres than alternative 1. 

Wildland-urban interface. Alternative 2 offers some flexibility and local direction to address 

WUI concerns. Future fuels projects in CRAs would be limited to the CPZ area and municipal 

water supply systems. This alternative provides communities with opportunities to reduce 

wildland fire hazards with temporary road construction and tree-cutting, sale or removal just 

the CPZ, except where CPZ acres overlap upper tier acres. 

Alternative 3 – Forest Plans (No Action)

Under this alternative, all IRAs would be managed under the existing forest plan direction. 

Most of the forest plans would continue to allow families to have adequate opportunities to 

collect fuel wood in the roadless areas. Road construction restrictions for each forest plan are 

generally described in Appendix B, forest plan management area direction. Using public 

comments received on the DEIS, the impacts of alternative 3 on the nine categories of social

values and interests are described as follows.

Conservation. In the conservation balance between land use management and allowing natural 

processes to dominate, this alternative offers the most flexibility to actively manage forest 

resources now and in the future. It provides less emphasis on allowing natural processes to 

dominate compared to alternatives 1, 2 or 4. While some forest plans have restrictions on new 

road construction in roadless areas that could prevent future resource impacts, there may be 

more land management activities than in either alternative 1, 2 or 4 (based on the projections of 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

284—Chapter 3. Affected Environment and Environmental Consequences

activities described in the Analysis Framework section). See Appendix B, forest plan 

management area direction, for specific forest plan information.

Industry Access. Alternative 3 would offer industry the most flexibility to access timber and 

oil/gas, coal or mineral resources within IRAs, in accordance with forest plan direction. 

Preservation. Depending on individual forest plan direction, alternative 3 would likely have the 

potential for the greatest impact to roadless area characteristics over the long-term. 

Recreational use – motorized. While the majority of projected new road construction would 

likely be closed to public motorized use, alternative 3 would allow for new NFS roads in IRAs 

as in accordance with forest plan direction, travel management plans, and budgets. Outside of 

the possibility of new road construction, alternative 3 is similar to alternatives 1, 2 and 4 in 

terms of providing for motorized trail opportunities in IRAs. 

Recreational use – non-motorized. Alternative 3 could detract the most from non-motorized 

recreation values. As stated in the motorized category, new road construction could occur in 

IRAs or in the CRAs under alternative 3 and could remain open to public use depending on 

forest travel management decisions. Any new road construction in roadless areas would 

negatively impact non-motorized opportunities in the short-term and, if those roads remain

open for public motorized use, the impact would be longer-term.

Roaded access. Alternative 3 could allow additional NFS roads open for public use, of the 

alternatives; this is the only one that has the potential to construct new roads in roadless areas 

that could likely be open for public use, thus increasing future roaded access.

Tourism. Alternative 3 projects the most additional road construction and tree-cutting, sale or 

removal which may impact scenery in the short-term. As with the other alternatives, many of 

the roads would likely be closed to public motorized use. In terms of providing a roadless 

experience, alternative 3 has the most potential to impact such experiences in specific locations. 

Specific to the ski industry, existing and future ski resorts that wanted to expand or construct 

infrastructure in roadless areas would need to be consistent with the forest plan, but would not 

be limited by specific roadless rule direction under alternative 3.

Wilderness. Those areas identified in forest plans as recommended wilderness would continue 

to be managed according to forest plan direction under alternative 3. This alternative may 

impact future areas from being recommended for wilderness due to projected road 

construction, tree-cutting, sale or removal, and other management activities.

Wildland-urban interface. Alternative 3 offers the most flexibility to address WUI concerns. 

Future fuels projects would be scheduled as needed and as budgets allowed. Road construction 

and tree-cutting, sale or removal would take place as allowed under the forest plans and as 

needed to access specific WUI locations as outlined by local community wildfire protection 

plans. 

Alternative 4 – Colorado Roadless Rule with Public Proposed Upper Tier

Using public comments received on the DEIS, the impacts of alternative 4 on the nine categories 

of social values and interests are described as follows:

Conservation. In the conservation balance between land use management and allowing natural 

processes to dominate, this alternative offers a limited ability to actively manage forest 

resources now and in the future. The majority of active management is for treatments within the

CPZ to address wildfire concerns of at-risk communities, within the North Fork Coal mining

area for access to future coal reserves, and for water conveyance structures associated with 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—285

existing water rights. The majority of CRAs, including those new CRA acres, would retain 

roadless area characteristics, and those acres in the upper tier would have additional 

restrictions. The substantially altered acres would be open for management in accordance with

forest plan direction.

Industry Access. The potential economic impacts to industry from limited access into roadless 

areas are considered specifically in the Economic Values section of this analysis. Because of 

limited road construction exceptions and the additional restrictions on the upper tier acres, 

alternative 4 limits tree-cutting and removal on more acres than any of the other alternatives. 

Like alternatives 1 and 2, existing lease activity would continue, but future leases would

prohibit road construction. Coal exploration would continue on the 20,000 acres within the 

North Fork Coal mining area, but would not be allowed elsewhere in the CRAs. The

substantially altered acres would be open for access in accordance with forest plan direction.

Preservation. The allowances in alternative 4 for road construction and tree-cutting, sale or 

removal would be focused within the CPZ around communities. Other exceptions for coal

development or water conveyance would be limited or spread over several CRAs. Removing 

the substantially altered acres from CRAs reduces the total acres included under a roadless rule, 

although adding the additional 409,500 unroaded acres into CRAs increases the restrictions of 

future road construction and tree-cutting on those acres. The restriction on additional oil and 

gas pipelines from sources outside of CRAs through a CRA would also prevent some pipeline 

activity in a CRA that could be allowed under alternative 1. Alternative 4 would provide 

additional limitations on road construction/reconstruction and tree-cutting on more upper tier

acres than alternative 2. 

Recreational use – motorized. There would be little change for this category between 

alternatives 1, 2 and 4. Any additional road construction would generally be temporary and 

closed to public motorized use, so there would be no increase in roaded opportunities. 

Recreational use – non-motorized. Similar to the motorized category, the forest travel 

management plans will be of concern to the non-motorized category, and may have a greater 

impact on the non-motorized current and future roadless opportunities depending on future 

travel management decisions. The upper tier acres in alternative 4, which restrict most road 

construction activity, may be preferred by the non-motorized users.

Roaded access. Like alternatives 1 and 2, alternative 4 would not provide additional roaded 

opportunities. The majority of road construction allowed under the exceptions would not be 

open for public motorized access. In addition, the newly identified roadless acres would be 

included within the CRAs and would limit additional roaded opportunities on those 409,500 

acres, and road construction on upper tier acres would be very limited.

Tourism. As with the recreational categories, there is not much additional roaded access

expected under alternative 4. Specific to the ski industry, this alternative would allow limited 

expansions of ski areas not allowed in alternative 1 (see Developed Ski Areas section for 

details). Alternative 4 may create some short term declines in scenery within the CPZ. Over 

time, the temporary roads and tree-cutting allowed within the CRA acres may provide for 

improved scenery compared to the rest of the CRA acres depending on the outcome of the 

beetle epidemics. 

Wilderness. The additional circumstances for road construction and tree-cutting in alternative 2 

and 4 are viewed by some groups as not offering the same protection for potential future 

wilderness as alternative 1. CRAs do not include the substantially altered acres which, under 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

286—Chapter 3. Affected Environment and Environmental Consequences

alternative 1, are not required to be returned to a roadless state. And, over all, alternative 4 has 

57,000 less acres within the roadless inventory than alternative 1. Alternative 4 would add an 

additional 409,500 unroaded acres as CRAs. The additional acres would not be managed as 

roadless under alternatives 1 or 3 so alternative 4 could increase the future wilderness potential 

of the 409,500 acres over that under alternatives 1 or 3. Wilderness interests concerned that 

management of the additional acres under forest plan direction would open those acres for 

more activities would prefer alternative 2 or 4. In additional, upper tier acres in alternative 4 are 

more restrictive than alternative 1 and would retain more roadless area characteristics over 

time, but some people may feel other acres of roadless areas are more suitable for upper tier 

status to serve as future wilderness than the upper tier presented in alternative 4.

Wildland-urban interface. Alternative 4 offers limited flexibility for addressing local WUI

concerns. Future fuels projects in CRAs would be limited to the CPZ areas that do not overlap 

with the upper tier acres. Temporary roads and tree-cutting to reduce fuels could be allowed in 

about half the 1⁄2-mile CPZ. No tree-cutting, sale or removal would be allowed on any CPZ acres 

within the upper tier.

Social Values: Cumulative Effects

Growth in population, influx of retirees, changes in diversity, and other demographic trends are 

outside of Forest Service control, but could greatly impact the demands placed on national 

forest resources, both inside and outside of roadless areas. 

Population growth is resulting in the conversion of existing open spaces and ranches into 

subdivisions and ranchettes. This may limit the opportunity for private lands to supply 

recreation areas or meet other demands for open space and push additional demand onto 

public lands. Possible impacts include increasing demands for open space recreation resources 

in roadless areas adjacent to private lands. Future development of private lands adjacent to 

roadless areas is expected to increase the WUI acreage in roadless areas, requiring more 

vegetation treatment to address concerns of wildland fire hazard. 

Future changes expected in recreation activities and equipment would change the way people 

use roadless areas. The current user conflicts on NFS lands between motorized, mechanized, 

and non-motorized users would likely increase in the future, both inside and outside roadless 

areas. Additional management tools would be required to address these conflicts.

Public demands and market values for energy resources such as oil, gas and coal are expected 

to increase, which can increase the demand for industry access to public lands as discussed in 

the Leasable Minerals (Energy Resources) and Economic Values sections. 

As these trends play out in Colorado, more types of people with different values would be 

affected and the values people hold for roadless areas would likely change. It is unlikely that 

there will be agreement in the future on how roadless areas should be managed. 

Under any alternative, the debate is likely to continue. The issues of debate will be different 

depending on which alternative is selected.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—287

ECONOMICS

This section provides a description of current economic conditions in Colorado and the 

potential changes to those conditions given alternative roadless area management.

In the course of public involvement, two issues regarding the economic implications in 

Colorado were raised frequently and are analyzed in this section; energy development and 

community protection from wildfire. Other common resource management activities and 

outputs including recreation use (tourism), water yield, livestock grazing and wood products 

were also considered, but not at the same level of detail. Resource sections analyzing these 

fields in this document generally found that activities and outputs would vary little among the 

alternatives considered. With little change to these resources, no change in quantitative 

economic effects is expected or can be modeled in this analysis.

The notable exception is commercial wood products (outputs) produced from roadless areas. As 

highlighted in the Vegetation section of this document, wood production would vary by 

alternative when only considering roadless areas, but Forest-wide commercial timber

production levels would remain constant. Production that could not be obtained from roadless 

areas under a more restrictive alternative would be obtained from non-roadless areas. Overall, 

the value of wood production would remain unchanged among alternatives.

As a result of these considerations, energy development and community protection from 

wildfire are the only issues that varied by alternative and could be analyzed quantitatively for 

this economic section. Some topics that could not be quantified and valued in monetary terms 

are discussed and analyzed qualitatively. 

The economic consequences of implementing each alternative are categorized as either impact 

or efficiency effects. Impact effects, sometimes called distributional effects, include 

consequences to jobs and labor income in specified areas of the State. These effects also include 

consequences to Colorado State and local governments in the form of Federal payments and 

taxes. Procedures for estimating jobs and income were based on economic models of Colorado 

economies using an input/output economic model and local Colorado data sources. Methods 

for estimating fiscal consequences to Colorado State and local governments were based on fiscal 

models using current tax and Federal revenue sharing structures.

Efficiency effects analysis, referred to in this report as benefits and costs, considers both 

financial and economic benefits and costs of each alternative. Benefits and costs include 

discussions of market and non-market goods and services, including roadless area 

characteristics, options for future use of roadless areas, and ecosystem function. The benefit and 

cost discussion provided in this section is a summary of the larger treatment of benefits and 

costs provided in the Regulatory Impact Analysis (Miller 2010).

Economics: Affected Environment

Economic Impacts

All of the economic impacts presented in this report occur in Colorado. The Colorado economy 

is diverse, ranging from urban centers along the Front Range (the urban development from the 

Denver metro area north to Fort Collins and south to Pueblo) to rural communities in the 

mountains and plains. Known world-wide for skiing and outdoor recreation, Colorado enjoys a 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

288—Chapter 3. Affected Environment and Environmental Consequences

strong tourism industry. It also benefits from substantial cable and satellite, defense, 

technology, and mining industries. Roadless area management, as described in this document, 

directly affects only one of these sectors –mining (natural gas and coal) – but indirectly affects 

many others. Table 3-53 displays the Colorado economy 30 using metrics of production value, 

employment, and labor income. 

Table 3-53. Value of Production, Employment, and Labor Income in the Colorado Economy (2006)

Industry

2006

Value of 

Production

($ millions)

Employment

(jobs)

Labor 

Income

($ millions)

Agriculture 5,554 47,044 824

Mining 12,361 24,191 3,091

Utilities 5,173 8,421 1,155

Construction 30,908 229,465 12,373

Manufacturing 61,010 157,037 11,216

Transportation & Warehousing 12,920 79,545 4,942

Trade 39,816 398,601 15,745

Finance, insurance, & real estate 48,183 239,346 11,770

Professional services 37,524 270,801 19,521

Administrative & waste services 11,602 168,875 5,350

Educational, health, & social services 23,237 289,192 12,123

Arts, entertainment, & recreation 4,285 67,908 1,719

Accommodation & food services 13,005 229,075 4,450

Other services 53,745 245,328 15,509

Government 46,566 416,486 27,266

Totals 405,890 2,871,314 147,053

Source: Minnesota IMPLAN Group, Inc. 2008 & & Colorado Department of Local Affairs, State Demography 

Office 2006.

Agriculture comprises establishments primarily engaged in growing crops, raising animals, 

harvesting timber, and harvesting fish and other animals from a farm, ranch, or their natural 

habitats.

Mining comprises establishments that extract naturally occurring mineral solids, such as coal

and ores; liquid minerals, such as crude petroleum; and gases, such as natural gas. The term 

mining is used in the broad sense to include quarrying, well operations, beneficiating (e.g., 

crushing, screening, washing, and flotation), and other preparation customarily performed at 

the mine site, or as a part of mining activity.

Utilities comprise establishments engaged in the provision of the following utility services: 

electric power, natural gas, steam supply, water supply, and sewage removal. Within this 

 

30 The data and models used in this analysis are comparable to those used in the July 2008 DEIS. Any analysis 

results that differ from those in the DEIS are the result of updated resource projections. See the economic specialist 

report for details.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—289

sector, the specific activities associated with the utility services provided vary by utility: electric 

power includes generation, transmission, and distribution; natural gas includes distribution; 

steam supply includes provision and/or distribution; water supply includes treatment and 

distribution; and sewage removal includes collection, treatment, and disposal of waste through 

sewer systems and sewage treatment facilities.

Construction comprises establishments primarily engaged in the construction of buildings or 

engineering projects (e.g., highways and utility systems). Establishments primarily engaged in 

the preparation of sites for new construction and establishments primarily engaged in 

subdividing land for sale as building sites also are included in this sector. 

Manufacturing comprises establishments engaged in the mechanical, physical, or chemical 

transformation of materials, substances, or components into new products. The assembling of 

component parts of manufactured products is considered manufacturing, except in cases where 

the activity is appropriately classified in Construction. Establishments in the Manufacturing 

sector are often described as plants, factories, or mills and characteristically use power-driven 

machines and materials-handling equipment. 

Transportation and Warehousing includes industries providing transportation of passengers 

and cargo, warehousing and storage for goods, scenic and sightseeing transportation, and 

support activities related to modes of transportation. Establishments in these industries use 

transportation equipment or transportation related facilities as a productive asset. The type of 

equipment depends on the mode of transportation. The modes of transportation are air, rail, 

water, road, and pipeline.

Trade comprises establishments engaged in wholesaling merchandise, generally without 

transformation, and rendering services incidental to the sale of merchandise. The merchandise 

described in this sector includes the outputs of agriculture, mining, manufacturing, and certain 

information industries, such as publishing. Trade also includes those establishments that sell 

merchandise, generally without transformation, and attract customers using methods such as 

advertising, point-of-sale location, and display of merchandise. A store retailer has a selling 

place open to the public; merchandise on display or available through sales clerks; facilities for 

making cash or credit card transactions; and services provided to retail customers.

Finance, Insurance and Real Estate comprises establishments primarily engaged in financial 

transactions (transactions involving the creation, liquidation, or change in ownership of 

financial assets) facilitating financial transactions and/or establishments primarily engaged in 

financial transactions (transactions involving the creation, liquidation, or change in ownership 

of financial assets) and/or in facilitating financial transactions.

Professional Services (Prof, Scientific, & Tech Services) comprises establishments that specialize 

in performing professional, scientific, and technical activities for others. These activities require 

a high degree of expertise and training. Activities performed include: legal advice and 

representation; accounting, bookkeeping, and payroll services; architectural, engineering, and 

specialized design services; computer services; consulting services; research services; 

advertising services; photographic services; translation and interpretation services; veterinary 

services; and other professional, scientific, and technical services.

Administrative and Support; Waste Management and Remediation Services comprises 

establishments performing routine support activities for the day-to-day operations of other 

organizations. The establishments in this sector specialize in one or more of these support 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

290—Chapter 3. Affected Environment and Environmental Consequences

activities and provide these services to clients in a variety of industries and, in some cases, to 

households. Activities performed include: office administration, hiring and placing of 

personnel, document preparation and similar clerical services, solicitation, collection, security 

and surveillance services, cleaning, and waste disposal services.

Educational, Health and Social Assistance comprises establishments that provide instruction 

and training in a wide variety of subjects. This instruction and training is provided by 

specialized establishments, such as schools, colleges, universities, and training centers. Also 

included are establishments providing health care and social assistance for individuals. The 

sector includes both health care and social assistance because it is sometimes difficult to 

distinguish between the boundaries of these two activities. All industries in the sector share this 

commonality of process, namely, labor inputs of health practitioners or social workers with the 

requisite expertise. 

Arts, Entertainment, and Recreation include a wide range of establishments that operate 

facilities or provide services to meet varied cultural, entertainment, and recreational interests of 

their patrons. This sector comprises (1) establishments that are involved in producing, 

promoting, or participating in live performances, events, or exhibits intended for public 

viewing; (2) establishments that preserve and exhibit objects and sites of historical, cultural, or 

educational interest; and (3) establishments that operate facilities or provide services that enable 

patrons to participate in recreational activities or pursue amusement, hobby, and leisure-time 

interests.

Accommodation and Food Services comprises establishments providing customers with 

lodging and/or preparing meals, snacks, and beverages for immediate consumption. The sector 

includes both accommodation and food services establishments because the two activities are 

often combined at the same establishment. 

Other Services comprises establishments engaged in providing services not specifically 

provided for elsewhere in the classification system. Establishments in this sector are primarily 

engaged in activities, such as equipment and machinery repairing, promoting or administering 

religious activities, grant making, advocacy, and providing dry cleaning and laundry services, 

personal care services, death care services, pet care services, photofinishing services, temporary 

parking services, and dating services.

Government consists of establishments of federal, state, and local government agencies that 

administer, oversee, and manage public programs and have executive, legislative, or judicial 

authority over other institutions within a given area. These agencies also set policy, create laws, 

adjudicate civil and criminal legal cases, provide for public safety and for national defense. 

Energy Minerals

Energy minerals provided to the US economy from any source, including roadless areas in 

Colorado, has national as well as local implications. This section briefly describes the economic

context within which natural gas and coal from Colorado roadless areas are provided to the 

nation.

Natural Gas

The demand for natural gas in the US is projected to grow by 0.8 percent annually over the next 

20 years. Although, natural gas heats most American homes, it also generates about 20 percent 

of the nation‘s electricity (USDOE, Energy Information Administration 2008). Fifty percent of 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—291

projected increases in natural gas consumption are driven by electric power generation 

(USDOE, Energy Information Administration 2008). Most new electricity generation capacity is 

expected to be fueled by natural gas because natural-gas-fired generators are projected to have 

advantages over coal-fired generators that include lower capital costs, higher fuel efficiency, 

shorter construction lead times, and lower emissions. 

Colorado has the sixth largest reserves of natural gas in the U.S. behind Texas, Wyoming, New 

Mexico, Oklahoma, and the Gulf of Mexico (Cappa et al. 2007). Two prominent areas of known 

and high potential unconventional natural gas on the western slope of Colorado are the 

Piceance and Paradox Basins. Including conventional and unconventional gas fields, Colorado 

is the sixth largest gas producing State in the nation. In 2008, Colorado wells produced 1.45 

trillion cubic feet of natural gas, or 5 percent of US production (Colorado Department of Natural 

Resources, Oil and Gas Conservation Commission 2009; USDOE, Energy Information 

Administration 2009). 

Coal 

Coal has been a vital energy source throughout the history of this county. In the last 30 years, 

coal production has shifted from traditional eastern states to abundant coalfields in the western 

United States. Starting in the 1970‘s, increasingly more stringent restrictions on atmospheric 

emissions of sulfur dioxide at power plants often made western coal the most cost effective 

choice for meeting sulfur dioxide limits without the installation of expensive retrofits. Because 

western sub bituminous coal is cleaner than coal found in the eastern US, the demand for coal 

from Colorado and Wyoming is expected to claim a larger share of the national coal market in 

years to come. 

Colorado ranks sixth nationally among coal-producing states (National Mining Association 

2009). Coal production in the State is dominated by mines in four counties: Routt, Moffat, Delta 

and Gunnison. Reserves under roadless areas are found only in Gunnison County. In the last 

decade, State-wide production has doubled, growing from 20 to nearly 40 million tons. About 

60 percent of State-wide coal is shipped out of Colorado, most going to Midwestern and 

southern states. The remainder of state production stays in Colorado, supplying several coalfired electric generation plants (Colorado Department of Natural Resources, Geological Survey 

2007). 

The Economic Impact Areas in Colorado

An economic model of four model areas was developed using an input/output model. The data 

set used in this analysis was developed specifically for Colorado using 2006 employment data 

from the Colorado Department of Local Affairs, State Demography Office. Model production 

value, employment, and labor income was further customized to capture economic conditions 

and interactions in the oil, natural gas, and coal mining industries (McDonald et al. 2007).

Production for the energy sectors within the mining industry was based on average prices for 

2006 reported by the Colorado Oil & Gas Conservation Commission (oil and gas) and the 

Colorado Geological Survey (coal).

To provide a State-wide context for the analysis, all Colorado counties were grouped into four 

model areas. Table 3-54 summarizes the counties in each of these model areas. Figure 3-4

displays the county composition of each area.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

292—Chapter 3. Affected Environment and Environmental Consequences

Table 3-54. Colorado Counties by Economic Impact Model Area

Model Area Counties

Energy Roadless1 Delta, Garfield, Mesa, Montrose, Rio Blanco

Rural Roadless1Alamosa, Archuleta, Chaffee, Conejos, Costilla, Custer, Dolores, 

Eagle, Fremont, Grand, Gunnison, Hinsdale, Huerfano, Jackson, 

La Plata, Lake, Las Animas, Mineral, Moffat, Montezuma, Ouray, 

Park, Pitkin, Rio Grande, Routt, Saguache, San Juan, San 

Miguel, Summit, Teller

Front Range Metro2Adams, Arapahoe, Boulder, Broomfield, Clear Creek, Denver, 

Douglas, El Paso, Gilpin, Jefferson, Larimer, Pueblo, Weld

Eastern Plains Baca, Bent, Cheyenne, Crowley, Elbert, Kiowa, Kit Carson, 

Lincoln, Logan, Morgan, Otero, Phillips, Prowers, Sedgwick, 

Washington, Yuma

1 Oil, gas, and coal production for Gunnison and Pitkin Counties has been moved into the Energy Roadless 

Counties model to better account for economic interactions.

2

Some counties contain roadless areas.

Natural gas and coal resources potentially affected by roadless area management are primarily 

located in five western slope counties (Energy Roadless): Delta, Garfield, Mesa, Montrose, and 

Rio Blanco. Natural gas and coal resources are found in numerous other locations around the 

State of Colorado, but these locations are either 

not affected by roadless management alternatives or 

are isolated with somewhat small deposits. 

Pitkin and Gunnison counties are exceptions to this characterization. Important natural gas and 

coal resources associated with roadless areas are located in the northwest corners of Pitkin and 

Gunnison Counties. Development of these resources would likely impact jobs and labor income

in the Energy Roadless counties rather than in the counties where the deposits are located. For 

these reasons, the economic impacts for oil, gas and coal are modeled using the Energy 

Roadless counties, but to fully account for the production, employment, and labor income of all 

coal mining operations in Gunnison County, the Energy Roadless model has been adjusted to 

include mines located in Gunnison County. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—293

Figure 3-4. Colorado Roadless Analysis: Economic Impact Model Areas

The Energy Roadless model area includes a variety of communities, ranging from small towns, 

such as Somerset, to the economic center of western Colorado in Grand Junction. In prior years, 

this area was primarily defined by retirees, tourism, and agriculture. With the recent energy 

boom, however, the area has developed into the center of energy development in western 

Colorado. Table 3-55 provides a picture of economic indicators by industrial sector.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

294—Chapter 3. Affected Environment and Environmental Consequences

Table 3-55. Value of Production, Employment, and Labor Income in the Energy Roadless Model 

Area (2006)

Industry

2006

Value of 

Production

($ millions)

Employment

(jobs)

Labor 

Income

($ millions)

Agriculture 472.6 5,472 87.4

Mining 5,101.9 7,027 662.1

Utilities 294.2 780 65.8

Construction 2,393.5 18,153 942.6

Manufacturing 1,822.3 6,561 294.6

Transportation & Warehousing 647.5 4,897 238.8

Trade 1,772.7 21,824 713.5

Finance, insurance, & real estate 1,723.5 9,799 378.7

Professional services 791.3 7,540 358.4

Administrative & waste services 415.2 6,370 189.1

Educational, health, & social services 1,141.4 15,642 603.4

Arts, entertainment, & recreation 119.3 2,559 42.3

Accommodation & food services 586.4 11,322 192.1

Other services 856.6 10,674 292.5

Government 1,903.3 19,836 1,039.2

Totals 20,041.8 148,457 6,100.5

Source: Minnesota IMPLAN Group, Inc. 2008 & & Colorado Department of Local Affairs, State Demography Office 2006. 

To put the Energy Roadless model area in perspective, Table 3-56 summarizes the same 

economic variables for all model areas in Colorado. The Front Range Metro area dominates the 

Colorado economy in all respects with over 80 percent of production, jobs, and labor income. 

The Rural Roadless model area, with 30 counties, follows in economic importance. The Energy 

Roadless area, with only five counties, trails only slightly in the size of its economy and includes 

roadless areas in all counties. The Eastern Plains of Colorado complete the picture with about 

two percent of State-wide totals. 

Table 3-56. Comparison of the Energy Roadless model area with other roadless model areas 

(2006)

Model Area 

2006

Value of Production Employment Labor Income

($ millions) Percent (jobs) Percent ($ millions) Percent

Energy Roadless 20,041.8 5% 148,457 5% 6,100.5 4%

Rural Roadless 32,551.7 8% 279,280 10% 10,657.4 7%

Front Range Metro 343,794.5 85% 2,366,618 82% 127,871.0 87%

Eastern Plains 9,502.1 2% 76,959 3% 2,423.7 2%

Colorado 405,890.1 100% 2,871,314 100% 147,052.8 100%

Source: Minnesota IMPLAN Group, Inc. 2008 & & Colorado Department of Local Affairs, State Demography 

Office 2006.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—295

Table 3-57 focuses on the mining industry in each model area of Colorado. The Energy Roadless 

area has greater production than any other part of the State. This is notable given the large oil 

and gas fields north of Denver that have been producing for many years. Employment in the 

Energy Roadless area ranks second to the Front Range Metro area, primarily because of Denverbased corporate headquarters for mining companies doing business in Colorado and other parts 

of the US. For the same reason, income in the Energy Roadless area trails the Front Range Metro 

area.

Table 3-57. Comparison of the Mineral Industry in roadless model areas (2006)

Model Area 

2006

Value of Production Employment Labor Income

($ millions) Percent (jobs) Percent ($ millions) Percent

Energy Roadless 5,101.9 35% 7,027 29% 662.1 21%

Rural Roadless 4,383.4 30% 3,371 14% 331.7 11%

Front Range Metro 4,466.1 31% 12,694 52% 2,005.4 65%

Eastern Plains 690.6 5% 1,110 5% 106.0 3%

Colorado 14,641.9 100% 24,202 100% 3,105.2 100%

Source: Minnesota IMPLAN Group, Inc. 2008 & Colorado Department of Local Affairs, State Demography Office 2006.

In a recent study of the Colorado oil and gas industry (McDonald et al. 2007), it was estimated 

that over two percent of State-wide employment and three percent of earnings were supported 

by oil and gas development and production. When compared with the travel industry, oil and 

gas provided 56 percent fewer jobs, but only 14 percent less income. As energy development 

continues in the State, especially on the western slope, these differences can be expected to 

narrow. 

Coal Industry in the Energy Roadless Area

The coal industry in the Energy Roadless area constitutes a sizeable share of the economy. 

When considering the production and employment at the mines plus all other secondary 

effects, the industry generates 2,200 jobs and a total of $130 million in labor income. 

State and Local Government Fiscal Health and Energy Minerals

Sizeable revenues accrue to state and local governments from the production of energy 

resources on Federal lands. These revenues are important contributions to the fiscal health of 

small and large governmental entities alike. Royalties of 12.5 percent are paid on production 

value from Federal mineral leases. Half of these revenues are paid to the states where 

production originated. In Colorado, these revenues are allocated to a variety of State funds, 

including the State Public School Fund, and to local jurisdictions. Federal Mineral Lease 

payments to Colorado totaled $128.7 million in 2007. In 2008, $254.9 million was paid to 

Colorado (Colorado Department of Local Affairs, Division of Local Governments 2009). 

The State of Colorado levies a severance tax that applies to energy mineral production. These 

revenues are distributed among State funds and local jurisdictions similar to Federal Mineral 

Lease payments. Oil, gas, and coal accounted for $135 million – 99 percent of all severance tax 

collections in 2007 (Colorado Department of Local Affairs, Division of Local Governments 

2009). In 2008, State-wide collections jumped to $151 million, of which $148 million were from 

oil, gas, and coal production.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

296—Chapter 3. Affected Environment and Environmental Consequences

Values at Risk of Wildfire

High-country communities in Colorado are rich in amenities and have always attracted new 

residents. In recent decades, however, the in-migration of full-time residents and proliferation 

of second homes with seasonal residents have reached new levels. Whether they come to stay 

seasonally or year-round, the economy of these towns has become highly dependent upon their 

presence and activities (Lloyd Levy Consulting 2004). As a result, these economies are 

characterized by strong lodging, food service, recreation, and real estate industries. 

While the juxtaposition of public lands has been a strong factor in the growth of mountain 

communities, it also comes with liabilities. Many mountain communities are becoming 

particularly susceptible to natural disturbances, such as mountain pine beetle infestations and 

drought. When the threat becomes reality and wildfire hits these communities – where 

landscapes are a critical foundation for life and livelihood – the results can be devastating. 

A vibrant community is healthy in both its public and private sectors. The values at risk can 

include such things as citizen health, reliable water and power supplies, infrastructure (both 

public and private), business activity, and general quality of life. Community infrastructure is 

the most visible and quantifiable value at risk. Homes, schools, retail shops, office buildings, 

libraries, hospitals, and police stations are just a few examples of infrastructure at risk of 

wildfire loss. Should these assets be lost, impacts would not be limited to the owners of affected 

properties. Property tax revenues, employment, income, health care, emergency services, and 

the general welfare of communities may all be affected.

Damage or loss of private homes to wildfire is one of the most common and visible effects of 

wildfires to communities. As such, homes provide a good indicator of more comprehensive 

community values at risk of wildfire. Table 3-58 displays the 2009 county assessor valuation of 

non-agricultural, single residence homes in Colorado counties containing IRAs or CRAs 

(Colorado Department of Local Affairs, Division of Property Taxation 2010). In addition, the 

table also displays an estimate of home values within 500 meters (about 0.3 mile) of public 

forest land in each county (USDA Forest Service 2010). It also puts these values in context by 

comparing the estimated home value with total valuation in the county. This analysis provides 

a very conservative indication of vulnerability to the tax base in each county. The infrastructure 

value of homes in this setting averages only 2.8% of total valuation across all counties with 

either IRAs or CRAs, but it exceeds 10% in Eagle, San Miguel, Summit, and Teller Counties. The 

higher the ratio, the greater the vulnerability of local government community services, and 

other economic activities, to losses by a potential wildfire. Table 3-58 does not imply that all 

properties are at risk equally. It should also be noted that the share of residential valuation to 

total valuation is not equivalent to the share of total property taxes paid by residential owners 

to local governments. Even with the caveats, Table 3-58 offers an indication of vulnerability 

among counties with IRA or CRA lands.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—297

Table 3-58. Estimated Non-agricultural Single-Family Residences and Valuation within 500 Meters of Forested Public Lands in Counties 

with Inventoried Roadless Areas (2009)

County

All 

Properties Non-agricultural Single-Family Residences

Estimated Non-agricultural Single-Family Residences 

within 500 Meters of Forested Public Lands

Total

Valuation

Total 

Valuation 

Improvement 

Valuation Number

Average 

Improvement 

Valuation

Share of 

Total 

Properties*

Number of 

Properties

Estimated 

Improvement 

Valuation

Share of 

County 

Total 

Valuation

$ millions $ millions $ millions number dollars percent number $ millions percent

Archuleta 824.6 152.7 108.1 6,020 17,962 17.6% 1,061 19.1 2.3%

Boulder 6,914.3 2,654.4 1,500.1 80,896 18,543 4.8% 3,905 72.4 1.0%

Chaffee 449.1 160.9 98.8 10,703 9,227 7.8% 831 7.7 1.7%

Clear Creek 563.4 102.6 79.0 4,494 17,577 68.6% 3,084 54.2 9.6%

Conejos 63.4 19.4 16.0 2,599 6,153 7.8% 202 1.2 2.0%

Costilla 132.0 5.4 4.5 931 4,832 0.2% 2 0.0 0.0%

Custer 102.4 38.1 31.2 2,711 11,524 13.6% 370 4.3 4.2%

Delta 774.7 134.9 95.0 8,868 10,712 5.0% 446 4.8 0.6%

Dolores 103.1 9.2 5.8 772 7,458 9.3% 72 0.5 0.5%

Douglas 5,790.5 2,573.5 1,868.8 88,955 21,008 1.3% 1,199 25.2 0.4%

Eagle 3,917.7 1,452.2 929.8 14,467 64,268 44.3% 6,412 412.1 10.5%

El Paso 8,236.8 3,196.3 2,460.7 172,414 14,272 0.0% - - 0.0%

Fremont 478.5 168.8 126.4 14,819 8,529 2.9% 435 3.7 0.8%

Garfield 5,500.8 538.6 357.1 14,410 24,782 14.3% 2,066 51.2 0.9%

Gilpin 414.3 57.4 45.3 3,152 14,381 76.6% 2,416 34.7 8.4%

Grand 1,063.6 318.5 228.2 9,357 24,388 33.8% 3,164 77.2 7.3%

Gunnison 1,234.3 270.6 183.5 6,790 27,024 19.6% 1,333 36.0 2.9%

Hinsdale 309.2 27.9 18.4 1,135 16,231 71.2% 808 13.1 4.2%

Jefferson 9,224.5 3,834.3 2,574.2 173,268 14,857 2.1% 3,689 54.8 0.6%

La Plata 3,740.1 523.9 332.0 15,879 20,911 18.9% 2,997 62.7 1.7%

Lake 115.3 47.4 34.8 3,102 11,213 26.6% 824 9.2 8.0%

Sources Colorado Department of Local Affairs, Division of Property Taxation 2010 and U.S. Department of Agriculture, Forest Service 2010.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

298—Chapter 3. Affected Environment and Environmental Consequences

Table 3-58. (cont’d). Estimated Non-agricultural Single-Family Residences and Valuation within 500 Meters of Forested Public Lands in 

Counties with Inventoried Roadless Areas (2009)

County

All 

Properties Non-agricultural Single-Family Residences

Estimated Non-agricultural Single-Family Residences 

within 500 Meters of Forested Public Lands

Total

Valuation

Total 

Valuation 

Improvement 

Valuation Number

Average 

Improvement 

Valuation

Share of 

Total 

Properties*

Number of 

Properties

Estimated 

Improvement 

Valuation

Share of 

County 

Total 

Valuation

$ millions $ millions $ millions number dollars percent number $ millions percent

Larimer 5,439.9 1,918.6 1,459.2 100,811 14,475 5.2% 5,277 76.4 1.4%

Las Animas 897.2 49.1 42.1 9,261 4,541 0.0% 4 0.0 0.0%

Mesa 2,776.5 903.1 621.7 44,025 14,121 1.5% 648 9.1 0.3%

Mineral 42.5 15.3 12.1 1,188 10,174 33.7% 401 4.1 9.6%

Moffat 564.7 51.3 41.7 3,780 11,040 0.2% 7 0.1 0.0%

Montezuma 698.3 107.2 74.7 6,951 10,749 3.9% 272 2.9 0.4%

Montrose 659.7 215.8 155.4 11,494 13,518 0.8% 94 1.3 0.2%

Ouray 234.5 75.8 48.0 2,243 21,417 33.5% 750 16.1 6.9%

Park 572.2 221.4 166.4 10,985 15,150 30.1% 3,311 50.2 8.8%

Pitkin 3,888.7 1,743.0 688.6 5,062 136,036 46.2% 2,339 318.2 8.2%

Pueblo 1,479.8 560.2 494.3 52,063 9,494 0.8% 419 4.0 0.3%

Rio Blanco 1,201.3 32.1 24.3 2,018 12,062 1.8% 37 0.4 0.0%

Rio Grande 231.9 51.4 41.0 4,604 8,899 6.3% 289 2.6 1.1%

Routt 1,646.2 460.6 277.8 7,898 35,171 9.7% 766 26.9 1.6%

Saguache 66.5 14.5 11.9 - - 0.0% - - -

San Juan 113.1 11.7 6.3 510 12,380 45.2% 230 2.9 2.5%

San Miguel 1,289.5 344.1 217.2 2,647 82,073 66.1% 1,749 143.6 11.1%

Summit 2,036.6 796.8 499.1 13,700 36,433 79.9% 10,945 398.8 19.6%

Teller 535.1 182.0 142.2 10,524 13,515 46.4% 4,884 66.0 12.3%

TOTAL 74,326.8 24,041.5 16,121.9 925,506.0 827,101.7 7.3% 67,737.9 2,067.6 2.8%

Sources Colorado Department of Local Affairs, Division of Property Taxation 2010 and U.S. Department of Agriculture [USDA], Forest Service 2010.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—299

Benefits and Costs

Unlike the previous section which dealt with regional economic impacts of jobs, income, taxes, 

payments, and assets, this section considers benefits and costs realized by all citizens in 

Colorado and across the nation.

Benefits and costs are divided into two parts: 1) those which are financial and captured in the

fiscal records of the Forest Service and 2) those which are realized by any organization or 

individual. Financial considerations include revenues and costs from the perspective of the 

Forest Service or other government agencies. Other benefits and costs can be realized by users 

of roadless areas in national forests, including backpackers, hunters, viewers of wildlife, 

permitted outfitters and guides, ski areas, ranchers, timber processors, and water users. Other 

benefits and costs can also be realized by those who never set foot in Colorado roadless areas 

who desire the retention of wildland characteristics for their children. 

In considering non-financial benefits and costs of roadless area management, both market and 

non-market goods and services can vary widely. Market goods or services are those for which 

one can observe transactions in the marketplace. Water rights, ski lift tickets, and the sale of 

cattle which graze on public lands are some examples of market values that are not captured in 

the financial records of government agencies. When road building and vegetative treatments 

are not allowed, these values may be minimal or non-existent. With roads and treatment 

options, these uses of roadless areas have a greater opportunity to develop and market values 

are realized.

Goods and services not found in the marketplace are also affected by roadless area 

management. Non-market goods and services are those for which there are no observable 

transactions. The value of these benefits are often estimated by economists using ―willingness to 

pay‖ concepts (Peterson et al. 1988). Examples of non-market benefits include dispersed 

recreation, viewing scenery and wildlife, solitude, health benefits, biological diversity, and 

ecosystem functions. Another group of benefits includes those who desire to retain options for 

the future use, either for themselves or for others. All of these pertain to roadless areas in 

Colorado, and can potentially be affected by road or vegetative treatment activities.

Economic Impacts: Environmental Consequences

Energy Minerals

The economic impacts of each alternative are based upon projections of energy mineral

development and production over a 15-year period. See the individual resource sections for 

details and specific assumptions applied to the projections. Projected oil and gas development 

for Colorado roadless areas is specific to each basin and forest. Most projected activity relevant 

to Colorado roadless areas occurs on the Grand Mesa-Uncompahgre-Gunnison (GMUG) and 

White River (WR) National Forests and in the Piceance Basin. 

Oil and gas development and production on the San Juan National Forest in the San Juan Basin 

are projected to not vary by alternative in 1, 2, and 4. Acres within roadless areas boundaries 

change by alternative, but total oil and gas activity in the San Juan Basin is not expected to 

change by alternative (Holm 2009). Alternative 3 may see additional leases in the future, but 

within the timeframe for this analysis it is not likely, and would therefore be the same as 

alternatives 1, 2, and 4. For these reasons, consequences of alternative roadless management in 

southwestern Colorado are not presented in this report as they are assumed to not change 
Roadless Area Conservation; National Forest System Lands in Colorado DEIS

300—Chapter 3. Affected Environment and Environmental Consequences

between alternatives over the timeframe considered.

While oil and gas extraction in roadless areas is characterized by changes in annual production, 

coal extraction in roadless areas is characterized by constant production over differing lengths 

of time. All recoverable coal reserves in roadless areas are assumed to be economically viable. 

These coal reserves are located in Gunnison County adjacent to the Elk Creek and West Elk 

mines.

Output, employment, and labor income effects in the five-county area from oil and gas and 

from coal production are shown in Table 3-59. Output, employment, and labor income impacts 

have been estimated for the Piceance Basin by applying both development and production 

activities to the Energy Roadless model. To facilitate comparisons with the DEIS, the model and 

model year remain unchanged in the Revised DEIS.

All indicators are expressed on an average annual basis over a 15-year analysis period (2010-

2024). Only those impacts associated with development and production from roadless areas are 

included.

Table 3-59 shows the direct, indirect, and induced effects for output (production value), 

employment, and labor income by alternative. Direct effects are realized by drilling and 

extraction companies from the sale of oil, natural gas, coal, and well drilling services. Indirect 

effects are realized by local companies that provide goods and services to the extraction and 

drilling industries. Induced effects result from local spending of employee income paid by the 

companies directly and indirectly affected by extraction and well drilling activities. 

Alternative 3 has the largest total effects on output, employment, and labor income. 

Alternatives 2 and 4 have the next largest effects. Compared with alternative 3, output would be 

lower by about 6 percent each year and employment and income would be lower by about 3 

percent. Alternative 1 has the smallest effects. Compared with alternative 3, output would be 

lower by about 30 percent each year, employment by about 35 percent, and labor income by 35 

percent each year over the 15 year analysis period.

Coal would provide about three quarters of the labor income under alternatives 2, 4 and 3, and 

60 percent under alternative 1. Coal would also provide nearly 70 percent of the employment

and half of the production value under alternatives 2, 4 and 3. 

Economic impacts displayed in Table 3-59 are substantially larger than those presented in the 

DEIS. Impacts attributable to oil and gas are very similar to those estimated in the DEIS for 

alternatives 2, 4 and 3. However, impacts under alternative 1 are nearly three times larger. In 

the DEIS, the 2001 rule was in effect and severely limited the leasing of roadless acres. In the 

RDEIS, the 2001 rule is no longer in effect in Colorado and leasing of these lands has already 

occurred. Limitations on road activity for future leases would not occur until a Colorado rule is 

in effect. Leases awarded prior to the decision can be developed according to lease stipulation 

under any alternative, resulting in much higher projections of drilling and production under 

alternative 1 than estimated in the DEIS.

The largest change in Table 3-59 compared with the DEIS is associated with coal production, 

where estimates are up to three times larger. This change is based on revised estimates of 

recoverable coal reserves and its repercussion on mine life. Because the two mines in Gunnison 

County are expected to operate through the 15-year analysis period under alternatives 2, 4 and 

3, annual average production, employment, and labor income is nearly as high as current levels.

Larger impacts associated with coal under alternative 1 are the result of a technical correction 

made in the RDEIS.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—301

Table 3-59. Average Annual Economic Impacts by Alternative for Energy Mineral Activity in the Energy Roadless Model Area, 2010-2024 

(2006 dollars)

Activity/Effects

Value of Production ($ millions) Employment (jobs) Labor Income ($ millions)

Alt 1 Alt 2 & 4 Alt 3 Alt 1 Alt 2 & 4 Alt 3 Alt 1 Alt 2 & 4 Alt 3

Oil & Gas Drilling

Oil & Gas Production

Coal Production

Total Energy Minerals

Totals 732.3 992.6 1,047.7 1,882 2,761 2,871 125.1 189.1 195.5

Direct 103.1 103.1 116.7 152 152 172 12.7 12.7 14.3

Indirect 39.0 39.0 44.1 196 196 221 8.2 8.2 9.2

Induced 14.8 14.8 16.8 141 141 159 4.5 4.5 5.1

Totals 156.9 156.9 177.6 489 489 553 25.3 25.3 28.6

Direct 167.5 167.5 188.9 51 51 57 9.0 9.0 10.2

Indirect 87.4 87.4 98.6 172 172 194 11.2 11.2 12.7

Induced 14.6 14.6 16.4 138 138 155 4.4 4.4 4.9

Totals 269.4 269.4 303.9 360 360 406 24.6 24.6 27.8

Direct 195.9 362.5 362.5 416 770 770 50.8 94.1 94.1

Indirect 53.1 98.2 98.2 185 342 342 10.7 19.9 19.9

Induced 57.0 105.5 105.5 432 799 799 13.6 25.2 25.2

Totals 305.9 566.2 566.2 1,033 1,912 1,912 75.2 139.1 139.1

Direct 466.5 633.1 668.1 619 973 1,000 72.6 115.8 118.6

Indirect 179.5 224.6 240.9 552 710 757 30.1 39.3 41.8

Induced 86.4 134.9 138.7 710 1,078 1,114 22.4 34.0 35.1
Roadless Area Conservation; National Forest System Lands in Colorado DEIS

302—Chapter 3. Affected Environment and Environmental Consequences

Tables 3-60 through 3-62 show the estimated average annual state and local government revenues 

derived from energy mineral activity in roadless areas. Federal mineral lease payments, property 

taxes, and severance taxes have been estimated using production and revenue relationships 

provided by the Colorado Department of Local Affairs, Division of Property Taxation and the 

Colorado Department of Revenue (Anders, 2008; Colby, 2008; Colorado Department of Local 

Affairs, Division of Property Taxation 2007; Colorado Department of Local Affairs, Division of 

Property Taxation 2008). For ease of comparison with the DEIS, models used for estimating local 

government revenues remains unchanged in the Revised DEIS.

Estimates are based on historical, basin-wide averages of well drilling and productivity. The timing 

and magnitude of actual revenues will be dependent upon factors such as market prices, tax laws, 

regulatory constraints, and availability of equipment and personnel. For property taxes, only 

revenue based on production is estimated. Personal and other real property may vary by alternative, 

but estimates for these could not be made.

Alternatives 3, 2 and 4 have the largest State and local government revenue effects, totaling $51.0 

and $48.7 million, respectively. Total revenues under alternative 1 are $33.8 million. Generally, 

property tax revenues account for the largest share of local government revenues. 

Gunnison and Mesa Counties consistently garner the largest shares of local government revenues.

Gunnison County is the largest beneficiary of revenues because of sizable coal and natural gas 

production. Mesa County revenues are solely based on oil and gas production. Distribution among 

counties varies by alternative because of differences in anticipated development and management 

limitations by individual roadless area. Details regarding production by roadless area can be found 

in the oil and gas and in the coal specialist reports.

Property tax revenues vary depending upon the level of oil and gas development, where oil and gas 

development is likely to occur, and whether coal reserves can be mined. Total property tax revenues 

are the highest under alternative 3, but not all counties share equally. Gunnison County shows the 

largest decrease under alternative 1 compared with No Action ($1.6 million); Pitkin shows the 

largest increase under alternative 1 compared with No Action ($0.2 million). Montrose County 

shows property tax revenues only for alternatives 2 and 4. The Horsefly Canyon Roadless Area is 

entirely contained within Montrose County, has oil and gas potential, allows roads, but is only 

available under alternatives 2 and 4. The Montrose County share of total production in alternatives 2 

and 4 is estimated to yield about $111,000 in property taxes per year. 

Impacts on revenues for State and local governments are substantially larger than the DEIS. Reasons 

for the change follow those noted above for economic impacts: a high level of current oil and gas

leasing that was not available under alternative 1 in the DEIS, and longer lives of coal mines under 

alternatives 2, 4 and 3. Larger impacts associated with coal under alternative 1 are the result of a 

technical correction made in the RDEIS.

Historically, decisions on the management of National Forest System lands have affected forest 

revenues and subsequent payments to states and counties. In 2000, the Secure Rural Schools and 

Community Self-Determination Act (SRSCSA) gave counties the opportunity to elect payments that 

would not vary and be independent of National Forest System receipts. All counties in Colorado 

elected to receive the SRSCSA, except Douglas, Gilpin, Jefferson, and San Miguel. Only San Miguel 

could experience a change in forest payments resulting from energy mineral development activities 

in roadless areas. Only fees associated with Forest Service permits for oil, gas, and coal exploration 

and development would affect payments to San Miguel County. Federal mineral lease royalties are 

collected by the Department of Interior and not subject to Forest Service payments. Changes in the 

payment to the county are not expected to be sizeable under any alternative.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—303

Table 3-60. Alternative 1 – Average Annual Federal Mineral Lease Production, Payments, and Related Tax Revenues from Roadless 

Areas, 2010-2024 (thousands of 2007 dollars)

Description

Energy-Affected Counties

All Other 

Counties

State 

Delta Garfield Gunnison Mesa Montrose Pitkin Total

O&G Production Value $5,841 $24,558 $68,123 $34,102 $0 $23,356 $0 $155,980

Coal Production Value $44,625 $0 $167,734 $0 $0 $0 $0 $212,359

Property tax receipts (production only) $413 $644 $2,750 $1,353 $0 $521 $0 $5,680

Severance tax receipts $5,052

Retained by U.S. $23,021

Paid to Colorado $23,021

Public School Fund $11,511

Other State Funds $12,927

To Local Governments $350 $657 $7 $1,256 $40 $0 $1,325 $3,635

Total of Payments and Taxes Received $763 $1,301 $2,757 $2,609 $40 $521 $1,325 $33,753

*Distribution of severance tax and federal mineral lease revenues to counties was revised in 2008 by Colorado statute. Transition distributions were 

implemented in 2009. Estimates above are based on prior distribution formulae for comparison with the DEIS.

Federal Mineral Lease Payments

State Distribution of Severance Tax & Federal Royalties*
Roadless Area Conservation; National Forest System Lands in Colorado DEIS

304—Chapter 3. Affected Environment and Environmental Consequences

Table 3-61. Alternatives 2 and 4 – Average Annual Federal Mineral Lease Production, Payments, and Related Tax Revenues from 

Roadless Areas, 2010-2024 (thousands of 2007 dollars)

Description

Energy-Affected Counties

All Other 

Delta Garfield Gunnison Mesa Montrose Pitkin Counties State Total

O&G Production Value 

$11,46

2 $26,161 $59,293

$32,70

0 $3,158

$23,20

6 $0

$155,98

0

Coal Production Value 

$44,62

5 $0

$348,39

9 $0 $0 $0 $0

$393,02

4

Property tax receipts (production only) $606 $686 $3,794 $1,297 $111 $517 $0 $7,011

Severance tax receipts $7,360

Retained by U.S. $34,313

Paid to Colorado $34,313

Public School Fund $17,156

Other State Funds $19,123

To Local Governments $578 $942 $11 $1,812 $63 $0 $1,987 $5,393

Total of Payments and Taxes Received $1,184 $1,628 $3,805 $3,109 $174 $517 $1,987 $48,683

*Distribution of severance tax and federal mineral lease revenues to counties was revised in 2008 by Colorado statute. Transition distributions were 

implemented in 2009. Estimates above are based on prior distribution formulae for comparison with the DEIS.

Federal Mineral Lease Payments

State Distribution of Severance Tax & Federal Royalties
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—305

Table 3-62. Alternative 3 – Average Annual Federal Mineral Lease Production, Payments, and Related Tax Revenues from Roadless 

Areas, 2010-2024 (thousands of 2007 dollars)

Description

Energy-Affected Counties

All Other 

Delta Garfield Gunnison Mesa Montrose Pitkin Counties State Total

O&G Production Value 

$33,17

1 $17,312 $77,221

$31,80

8 $0

$16,40

5 $0

$175,91

6

Coal Production Value 

$44,62

5 $0

$348,39

9 $0 $0 $0 $0

$393,02

4

Property tax receipts (production only) $1,351 $454 $4,334 $1,262 $0 $366 $0 $7,766

Severance tax receipts $7,659

Retained by U.S. $35,559

Paid to Colorado $35,559

Public School Fund $17,779

Other State Funds $19,845

To Local Governments $589 $983 $11 $1,889 $65 $0 $2,058 $5,594

Total of Payments and Taxes Received $1,939 $1,437 $4,345 $3,151 $65 $366 $2,058 $50,984

*Distribution of severance tax and federal mineral lease revenues to counties was revised in 2008 by Colorado statute. Transition distributions were 

implemented in 2009. Estimates above are based on prior distribution formulae for comparison with the DEIS.

Federal Mineral Lease Payments

State Distribution of Severance Tax & Federal Royalties
Roadless Area Conservation; National Forest System Lands in Colorado DEIS

306—Chapter 3. Affected Environment and Environmental Consequences

Counties with Federal lands also receive Payments in Lieu of Taxes, (PILT) by the Department 

of Interior to help offset the loss of property tax revenues caused by Federal ownership. Using a 

system of formulas, payments are based on county population and acreage in Federal 

ownership less Federal payments from land use in the prior year. Federal mineral lease 

payments are included in prior year deductions. A minimum payment is established so that 

every qualifying county receives some PILT, regardless of prior year payments. Federal mineral 

lease payments estimated for all alternatives could reduce PILT by equal amounts. However, 

PILT payments are subject to Congressional appropriation, and have not been fully funded in 

recent years. Consequently, any reduction in PILT for Colorado counties is likely to be smaller 

than the increase in Federal mineral lease payments. For those counties already receiving the 

minimum PILT payment, no change would occur under any alternative. 

The development and production of energy minerals in roadless areas may impose additional 

demands on services provided by local governments. Higher levels of traffic, greater demands 

for social services, and increased loads on utility infrastructure are examples of additional costs 

that may be incurred by local governments in the Piceance Basin. While these costs are common 

for communities near energy development, the specific timing, magnitude, and location of 

energy development cannot be estimated at this level of analysis. Such impacts on local 

governments are typically addressed at the project level when site-specific development is 

proposed. Because energy markets can be volatile, energy development can begin and end 

quickly, posing significant challenges to local governments in serving residents and visitors 

alike.

Summary of Effects

Provisions for energy mineral development in alternatives 2, 4 and 3 are likely to result in 

sizeable increases of average annual production, employment, and labor income over the next 

15-years for the Energy Roadless model area (Delta, Garfield, Gunnison, Mesa, Montrose, and 

Pitkin counties). Total jobs under alternative 1 are estimated at 2,200 jobs, while for alternatives 

2 and 4 it rises to 3,300 jobs and for alternative 3 are estimated at nearly 3,400 jobs. The 

estimated effects of alternative 1 range from 60 to 70 percent of alternative 3 for output, 

employment and labor income. Effects under alternatives 2 and 4 are about 95 percent of those 

under alternative 3. 

A pattern similar to economic effects emerges for average annual State and local government 

revenues. Compared with $51 million under alternative 3, Federal mineral lease payments and 

tax revenues are estimated to be $49 million for alternatives 2 and 4 and $34 million for 

alternative 1. Gunnison and Mesa Counties are expected to yield the largest revenues under any 

alternative. Other Federal payments to state and local governments, such as those from the 

National Forest Fund and PILT, are expected to either not change or be more than offset by 

revenues from Federal mineral lease payments.

Values at Risk From Wildfire 

Some roadless areas pose a higher wildfire hazard to communities than others. In addition, each 

alternative poses different management restrictions that may influence the ability to treat 

hazardous fuels within roadless areas. The combination of these factors can influence potential 

vulnerabilities of wildfire losses to at-risk communities located nearby. 

For the DEIS, a CWPP-based definition of the wildland urban interface was used to identify at-
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—307

risk communities that could be affected by roadless area management. To approximate a 

CWPP-defined WUI and to provide a consistent analysis area, a 3-mile radius from the 

community center was circumscribed around all communities identified to be at risk. For the 

RDEIS, the analysis area has changed. A Community Protection Zone (CPZ) has been defined 

around all at-risk communities near inventoried or proposed roadless areas. The CPZ extends a 

minimum of 0.5 miles and up to 1.5 miles out from at-risk communities. The CPZ that intersects 

an IRA or CRA is the focus of this analysis. A detailed description of the lands included in this 

analysis area can be found in the Fire and Fuels section in this chapter. 

National forest field personnel in Colorado projected the likelihood of mechanical fuel

treatments in each roadless area under each alternative. The purpose of these treatments would 

be to reduce the risk of losses from wildfire in nearby at-risk communities. The likelihood 

ranged from ―none‖ to ―low‖ to ―high‖. Table 3-63a shows the CPZ land area by county that 

could potentially be treated under each alternative. Some potential is defined as the 

combination of both ―low‖ and ―high‖ likelihoods. High potential is defined as only the ―high‖ 

likelihood projected by forest personnel. Potential does not mean that these acres will be 

treated. Actual treatment depends on funding, overall fuel treatment priorities both in and 

outside of roadless areas, and other factors. However, Table 3-63a provides a cursory indication 

of options and likelihoods for reducing wildfire risks to at-risk communities by county. 

A potential for fuel treatments in either IRAs or CRAs in the CPZ exists in twenty-four counties. 

Across these counties, the greatest acreages of potential treatment occur under alternatives 2 

and 3. The counties with the greatest acreage of high potential treatment include La Plata, Park, 

and Larimer. Those with moderate acreage of high potential include Archuleta, Custer, Chaffee, 

and Douglas. By referencing Table 3-58 above, these seven counties have a minimum of 0.4% to 

8.8% of their total valuation in homes located in the wildland urban interface. While all counties 

with high potential acres could benefit from reduced wildfire risks, these seven counties could 

benefit substantially. 

Under alternative 1, sixteen counties have potential for fuel treatments in the CPZ. The counties 

with the greatest acreage of high potential treatment are La Plata, Larimer, Archuleta and 

Douglas. Under alternative 4, twenty-two counties have potential for treatments in the CPZ. 

The counties with the greatest acreage of high potential treatment are La Plata, Larimer, Park, 

and Douglas. 

Table 3-63b provides a comparison of potential treatment acres between each alternative and 

alternative 3. This table shows more clearly that there are few differences between alternatives 2 

and 3. It also shows clearly a reduction in potential treatment acres under alternatives 1 and 4. 

Thirteen counties would have a lower potential of treatment under alternative 1, while nineteen 

counties would have a lower potential of treatment under alternative 4. Based on Table 3-58, 

Eagle and Summit Counties have a sizeable tax dependence on properties in the urban interface 

and would also have a substantial reduction in potential treatment acres under alternative 1. 

Clear Creek is the only county to have an increase in acreage under alternative 1. Boulder, Clear 

Creek, Dolores, Grand, and Montezuma Counties could have an increase in acreage under 

alternative 4, mostly with lower potential for treatment. Based on estimates in Table 3-58, Clear 

Creek and Grand Counties have a modest, but not insignificant tax dependence on properties in 

the urban interface. 

Tables 3-64a and 3-64b provide another context for understanding potential treatment acres. 

These tables display the share of CPZ acres with treatment potential in IRAs and CRAs 
Roadless Area Conservation; National Forest System Lands in Colorado DEIS

308—Chapter 3. Affected Environment and Environmental Consequences

compared with all National Forest System (NFS) acres that intersect the CPZ by county. A high 

percentage means that IRAs and CRAs could play an important role in overall reduction of 

community vulnerabilities due to wildfire. A low percentage means that treatments in IRAs or 

CRAs may not be critical for this purpose. Table 3-64a shows that fuel treatments under 

alternatives 2 and 3 in IRAs or CRAs may be especially important for La Plata, Custer, Pueblo, 

Huerfano, and Fremont Counties. Acres with a high likelihood of treatment range from about 

16% to 38% of all NFS acres in the CPZ in these counties. Based on Table 3-58, Custer has the 

highest relative vulnerability to losses in the wildland urban interface among these five 

counties. For most other counties, high potential acres are a relatively small share of all NFS 

acres in the CPZ. Under alternative 1, La Plata, Clear Creek, Montezuma, and Larimer Counties 

show a high share of all NFS acres. Under alternative 4, high potential treatment acres are a 

small share of all NFS acres in the CPZ for all counties.

Table 3-64b shows the difference in shares of CPZ acres when comparing each alternative to 

alternative 3. This table clearly shows that there are very small differences between alternative 2 

and 3 when considering the share of all NFS acres available for fuel treatment in the CPZ. 

Alternatives 1 and 4, on the other hand, have clear reductions compared with alternative 3 in 

the proportion of NFS acres available for fuel treatment in the CPZ. Compared with alternative 

3, IRAs and CRAs under these alternatives would have a substantially reduced role on NFS 

lands in attempts to protect communities from wildfire losses.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—309

Table 3-63a. Potential Fuel Treatment1 Acres in the Community Protection Zone within 0.5 and 1.5 miles of At-Risk Communities, Totals by County, 

acres rounded to nearest 100

County

Alternative 1 Alternative 2 Alternative 3 Alternative 4

Some Potential for 

Treatment2

High Potential for 

Treatment3

Some Potential for 

Treatment2

High Potential for 

Treatment3

Some Potential for 

Treatment2

High Potential for 

Treatment3

Some Potential for 

Treatment2

High Potential for 

Treatment3

Within 

0.5 

miles

Within 

1.5 

miles

Within 

0.5 

miles

Within 

1.5 

miles

Within 

0.5 

miles

Within 

1.5 miles

Within 

0.5 

miles

Within 

1.5 miles

Within 

0.5 

miles

Within 

1.5 

miles

Within 

0.5 

miles

Within 

1.5 

miles

Within 

0.5 

miles

Within 

1.5 

miles

Within 

0.5 

miles

Within 

1.5 

miles

- - - -- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -acres, rounded to the nearest 100 acres- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

Archuleta 2,800 18,700 2,800 18,700 2,800 18,700 2,800 18,700 2,800 18,700 2,800 18,700 300 2,400 300 2,400

Boulder - 4,600 - 3,900 - 4,000 - 3,900 - 4,600 - 3,900 1,400 4,500 - 3,900 

Chaffee 900 3,900 900 3,900 3,700 11,900 3,700 11,900 3,700 11,900 3,700 11,900 400 5,700 400 1,600 

Clear Creek 5,600 24,100 - - 4,600 15,700 - - 4,500 13,400 - - 4,800 18,200 - -

Custer - - - - 4,300 13,000 4,300 13,000 4,300 13,000 4,300 13,000 2,100 6,500 - 200 

Dolores 900 1,900 - - 900 1,900 - - 900 1,900 - - 1,300 1,900 - -

Douglas 2,400 10,200 2,400 10,200 2,500 11,800 2,500 11,800 2,500 11,800 2,500 11,800 2,500 11,800 2,500 11,800 

Eagle - - - - 13,300 25,300 2,200 5,000 13,300 25,300 - - 3,500 - - -

El Paso - - - - - 900 - 900 - 900 - 900 - 900 - 900

Fremont - - - - 1,100 3,600 1,100 3,600 1,100 3,600 1,100 3,600 1,100 3,600 - -

Garfield - - - - 500 2,100 - - 500 2,100 - - - - - -

Grand 1,100 11,100 700 6,100 800 5,400 500 3,200 1,100 11,100 700 6,100 2,300 20,600 500 3,900

Gunnison 100 1,200 100 1,200 900 2,600 100 1,200 900 2,600 100 1,200 100 1,200 100 1,200

Huerfano - - - - 1,693 6,550 1,693 6,550 1,693 6,550 1,693 6,550 136 2,560 136 2,560 

Jefferson 500 4,400 500 4,400 500 4,400 500 4,400 500 4,400 500 4,400 500 4,400 500 4,400

La Plata 17,600 69,600 16,700 66,700 17,600 69,600 16,700 66,700 17,600 69,600 16,700 66,700 8,300 20,700 8,300 20,700 

Lake 300 300 300 300 300 300 300 300 300 300 300 300 300 300 300 300

Larimer 22,500 61,700 11,000 29,000 22,500 61,700 11,000 29,000 22,500 61,700 11,000 29,000 8,100 26,200 3,400 8,800 

Mineral - 500 - 500 - 500 - 500 - 500 - 500 - - - -

Montezuma 4,000 22,900 - - 4,000 22,900 - - 4,000 22,900 - - 5,700 22,800 - -

Park 1,100 5,800 1,100 5,800 8,200 29,700 8,200 29,700 8,200 29,700 8,200 29,700 8,200 25,600 4,200 10,000 

Pitkin - - - - 11,318 36,279 - - 9,777 33,739 - - 901 17,618 - -
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

310—Chapter 3. Affected Environment and Environmental Consequences

County

Alternative 1 Alternative 2 Alternative 3 Alternative 4

Some Potential for 

Treatment2

High Potential for 

Treatment3

Some Potential for 

Treatment2

High Potential for 

Treatment3

Some Potential for 

Treatment2

High Potential for 

Treatment3

Some Potential for 

Treatment2

High Potential for 

Treatment3

Within 

0.5 

miles

Within 

1.5 

miles

Within 

0.5 

miles

Within 

1.5 

miles

Within 

0.5 

miles

Within 

1.5 miles

Within 

0.5 

miles

Within 

1.5 miles

Within 

0.5 

miles

Within 

1.5 

miles

Within 

0.5 

miles

Within 

1.5 

miles

Within 

0.5 

miles

Within 

1.5 

miles

Within 

0.5 

miles

Within 

1.5 

miles

- - - -- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -acres, rounded to the nearest 100 acres- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

Pueblo - - - - 2,900 9,400 1,600 5,600 2,900 9,400 2,900 9,400 - 300 - 300

Summit 200 1,400 - - 2,200 9,000 200 1,400 2,200 9,000 200 1,400 1,100 3,100 - -

Total 59,900 242,200 36,400 150,800 106,500 367,200 57,300 217,400 105,200 368,700 56,600 219,100 53,000 200,700 20,600 72,800

Totals may not add due to rounding.

1 Potential means there is some likelihood of tree-cutting for the purpose of fuel treatment.

2 Number of Colorado Roadless Area acres that overlap with Community Protection Zones for at-risk communities where the likelihood of tree-cutting for the purpose of fuel treatment is projected to 

be "low" or "high" by forest units in the most recent roadless area activity projection survey (completed summer, 2010)

3 Number of Colorado Roadless Area acres that overlap with Community Protection Zones for at-risk communities where the likelihood of tree-cutting for the purpose of fuel treatment is projected to 

be "high" by forest units in the most recent roadless area activity projection survey (completed summer, 2010)

Table 3-63b. Potential Fuel Treatment1 Acres in the Community Protection Zone within 0.5 and 1.5 miles of At-Risk Communities Compared with 

Alternative 3, Totals by County, acres rounded to nearest 100 acres.

County

Alternative 1 vs. Alternative 3 Alternative 2 vs. Alternative 3 Alternative 4 vs. Alternative 3

Some Potential for 

Treatment2

High Potential for 

Treatment3

Some Potential for 

Treatment2

High Potential for 

Treatment3

Some Potential for 

Treatment2

High Potential for 

Treatment3

Within

0.5 miles

Within

1.5 miles

Within

0.5 miles

Within

1.5 miles

Within

0.5 miles

Within

1.5 miles

Within

0.5 miles

Within

1.5 miles

Within

0.5 miles

Within

1.5 miles

Within

0.5 miles

Within

1.5 miles

- - - -- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -acres, rounded to the nearest 100 acres- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

Archuleta - - - - - - - - -2,500 -16,400 -2,500 -16,400 

Boulder - - - - - -600 - - 1,400 -200 - -

Chaffee -2,800 -7,900 -2,800 -7,900 - - - - -3,300 -6,200 -3,300 -10,200

Clear Creek 1,100 10,600 - - <50 2,300 - - 200 4,700 - -

Custer -4,300 -13,000 -4,300 -13,000 - - - - -2,200 -6,500 -4,300 -12,800

Dolores - - - - - - - - 500 - - -

Douglas -100 - 1,600 -100 - 1,600 - - - - - - - -

Eagle -13,300 -25,300 - - - - 2,200 5,000 -9,800 -25,300 - -
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—311

County

Alternative 1 vs. Alternative 3 Alternative 2 vs. Alternative 3 Alternative 4 vs. Alternative 3

Some Potential for 

Treatment2

High Potential for 

Treatment3

Some Potential for 

Treatment2

High Potential for 

Treatment3

Some Potential for 

Treatment2

High Potential for 

Treatment3

Within

0.5 miles

Within

1.5 miles

Within

0.5 miles

Within

1.5 miles

Within

0.5 miles

Within

1.5 miles

Within

0.5 miles

Within

1.5 miles

Within

0.5 miles

Within

1.5 miles

Within

0.5 miles

Within

1.5 miles

- - - -- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -acres, rounded to the nearest 100 acres- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

El Paso - -900 - - 900 - - - - - - - -

Fremont -1,100 -3,600 -1,100 -3,600 - - - - - -<50 -1,100 -3,600 

Garfield -500 -2,100 - - - - - - -500 -2,100 - -

Grand - - - - -300 -5,700 -200 -2,900 1,200 9,500 -200 -2,261

Gunnison -900 -1,400 - - - - - - -900 -1,400 - -

Huerfano -1,700 -6,600 -1,700 -6,600 - - - - -1,600 -4,000 -1,600 -4,000 

La Plata - - - - - - - - -9,300 -49,000 -8,412 -46,000 

Larimer - - - - - - - - -14,400 - 35,500 - 7,600 -20,100

Mineral - - - - - - - - - -500 - -500

Montezuma - - - - - - - - 1,700 -<50 - -

Park -7,200 -23,900 -7,200 -23,900 - - - - -<50 -4,100 -4,000 -19,800 

Pitkin -9,800 -33,700 - - 1,500 2,500 - - -8,900 -16,100 - -

Pueblo -2,900 - 9,400 -2,900 - 9,400 - - -1,300 - 3,800 -2,900 - 9,200 -2,900 - 9,200

Summit -2,000 -7,600 -200 -1,400 - - - - -1,000 -6,000 -166 -1,400 

Total -45,300 -126,500 -20,100 -68,300 1,300 -1,500 700 -1,700 -52,200 -168,000 -36,000 -146,000 

Totals may not add due to rounding

1 Potential means there is some likelihood of tree-cutting for the purpose of fuel treatment.

2 Number of Colorado Roadless Area acres that overlap with Community Protection Zones for at-risk communities where the likelihood of tree-cutting for the purpose of fuel treatment is projected to 

be "low" or "high" by forest units in the most recent roadless area activity projection survey (completed summer, 2010)

3 Number of Colorado Roadless Area acres that overlap with Community Protection Zones for at-risk communities where the likelihood of tree-cutting for the purpose of fuel treatment is projected to 

be "high" by forest units in the most recent roadless area activity projection survey (completed summer, 2010)
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

312—Chapter 3. Affected Environment and Environmental Consequences

Table 3-64a. Share of Total NFS Lands in the Community Protection Zone where Potential1Exists for Fuel Treatment by County

County

Alternative 1 Alternative 2 Alternative 3 Alternative 4

Some Potential 

for Treatment2

High Potential 

for Treatment3

Some Potential 

for Treatment2

High Potential 

for Treatment3

Some Potential 

for Treatment2

High Potential 

for Treatment3

Some Potential 

for Treatment2

High Potential 

for Treatment3

Within 

0.5 

miles

Within 

1.5 

miles

Within 

0.5 

miles

Within 

1.5 

miles

Within 

0.5 

miles

Within 

1.5 

miles

Within 

0.5 

miles

Within 

1.5 

miles

Within 

0.5 

miles

Within 

1.5 

miles

Within 

0.5 

miles

Within 

1.5 

miles

Within 

0.5 

miles

Within 

1.5 

miles

Within 

0.5 

miles

Within 

1.5 

miles

Archuleta 5.5% 12.3% 5.5% 12.3% 5.5% 12.3% 5.5% 12.3% 5.5% 12.3% 5.5% 12.3% 0.5% 1.6% 0.5% 1.6%

Boulder - 3.1% - 2.6% - 2.7% - 2.6% - 3.1% - 2.6% 1.4% 3.0% - 2.6%

Chaffee 1.7% 2.1% 1.7% 2.1% 6.8% 6.4% 6.8% 6.4% 6.8% 6.4% 6.8% 6.4% 0.8% 3.1% 0.8% 0.9%

Clear Creek 13.1% 24.1% - - 10.6% 15.8% - - 10.6% 13.5% - - 11.1% 18.2% - -

Custer - - - - 28.1% 23.7% 28.1% 23.7% 28.1% 23.7% 28.1% 23.7% 13.9% 11.9% - 0.3%

Dolores 9.1% 4.8% - - 9.1% 4.8% - - 9.1% 4.8% - - 14.4% 4.8% - -

Douglas 5.4% 9.3% 5.4% 9.3% 5.5% 10.8% 5.5% 10.8% 5.5% 10.8% 5.5% 10.8% 5.5% 10.8% 5.5% 10.8%

Eagle - - - - 13.9% 10.0% 2.3% 2.0% 13.9% 10.0% - - 3.7% - - -

El Paso - - - - - 1.0% - 1.0% - 1.0% - 1.0% - 1.0% - 1.0%

Fremont - - - - 27.6% 18.4% 27.6% 18.4% 27.6% 18.4% 27.6% 18.4% 27.4% 18.1% - -

Garfield - - - - 7.6% 6.4% - - 7.6% 6.4% - - - - - -

Grand 3.3% 9.6% 1.9% 5.3% 2.4% 4.7% 1.5% 2.8% 3.3% 9.6% 1.9% 5.3% 6.9% 17.7% 1.5% 3.3%

Gunnison 0.1% 0.4% 0.1% 0.4% 1.1% 0.9% 0.1% 0.4% 1.1% 0.9% 0.1% 0.4% 0.1% 0.4% 0.1% 0.4%

Huerfano - - - - 17.3% 20.4% 17.3% 20.4% 17.3% 20.4% 17.3% 20.4% 1.4% 8.0% 1.4% 8.0%

Jefferson 1.7% 6.3% 1.7% 6.3% 1.7% 6.3% 1.7% 6.3% 1.7% 6.3% 1.7% 6.3% 1.7% 6.3% 1.7% 6.3%

La Plata 16.3% 29.9% 15.5% 28.7% 16.3% 29.9% 15.5% 28.7% 16.3% 29.9% 15.5% 28.7% 7.7% 8.9% 7.7% 8.9%

Lake 1.5% 0.5% 1.5% 0.5% 1.5% 0.5% 1.5% 0.5% 1.5% 0.5% 1.5% 0.5% 1.5% 0.5% 1.5% 0.5%

Larimer 13.2% 16.1% 6.4% 7.6% 13.2% 16.1% 6.4% 7.6% 13.2% 16.1% 6.4% 7.6% 4.8% 6.9% 2.0% 2.3%

Mineral - 0.4% - 0.4% - 0.4% - 0.4% - 0.4% - 0.4% - - - -

Montezuma 10.2% 22.6% - - 10.2% 22.6% - - 10.2% 22.6% - - 14.5% 22.6% - -

Park 0.7% 1.6% 0.7% 1.6% 5.1% 8.4% 5.1% 8.4% 5.1% 8.4% 5.1% 8.4% 5.1% 7.2% 2.6% 2.8%

Pitkin - - - - 17.3% 20.9% - - 15.0% 19.4% - - 1.4% 10.2% - -

Pueblo - - - - 27.2% 38.4% 15.0% 22.9% 27.2% 38.4% 27.2% 38.4% - 1.1% - 1.1%

Summit 0.1% 0.5% - - 1.7% 3.5% 0.1% 0.5% 1.7% 3.5% 0.1% 0.5% 0.9% 1.2% - -
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—313

County

Alternative 1 Alternative 2 Alternative 3 Alternative 4

Some Potential 

for Treatment2

High Potential 

for Treatment3

Some Potential 

for Treatment2

High Potential 

for Treatment3

Some Potential 

for Treatment2

High Potential 

for Treatment3

Some Potential 

for Treatment2

High Potential 

for Treatment3

Within 

0.5 

miles

Within 

1.5 

miles

Within 

0.5 

miles

Within 

1.5 

miles

Within 

0.5 

miles

Within 

1.5 

miles

Within 

0.5 

miles

Within 

1.5 

miles

Within 

0.5 

miles

Within 

1.5 

miles

Within 

0.5 

miles

Within 

1.5 

miles

Within 

0.5 

miles

Within 

1.5 

miles

Within 

0.5 

miles

Within 

1.5 

miles

Total 3.9% 6.1% 2.3% 3.8% 6.9% 9.2% 3.7% 5.4% 6.8% 9.2% 3.6% 5.5% 3.4% 5.0% 1.3% 1.8%

1 Potential means there is some likelihood of tree-cutting for the purpose of fuel treatment.

2 Number of Colorado Roadless Area acres that overlap with Community Protection Zones for at-risk communities where the likelihood of tree-cutting for the purpose of fuel treatment is projected to 

be "low" or “high" by forest units in the most recent roadless area activity projection survey (completed summer, 2010)

3 Number of Colorado Roadless Area acres that overlap with Community Protection Zones for at-risk communities where the likelihood of tree-cutting for the purpose of fuel treatment is projected to 

be "high" by forest units in the most recent roadless area activity projection survey (completed summer, 2010)

Table 3-64b. Change in Share of Total NFS Lands in the Community Protection Zone where Potential1Exists for Fuel Treatment Compared with 

Alternative 3 by County

County

Alternative 1 vs. Alternative 3 Alternative 2 vs. Alternative 3 Alternative 4 vs. Alternative 3

Some Potential for 

Treatment2

High Potential for 

Treatment3

Some Potential for 

Treatment2

High Potential for 

Treatment3

Some Potential for 

Treatment2

High Potential for 

Treatment3

Within 0.5 

miles

Within 1.5 

miles

Within 0.5 

miles

Within 1.5 

miles

Within 0.5 

miles

Within 1.5 

miles

Within 0.5 

miles

Within 1.5 

miles

Within 0.5 

miles

Within 1.5 

miles

Within 0.5 

miles

Within 1.5 

miles

Archuleta - - - - - - - - -5.0% -10.7% -5.0% -10.7%

Boulder - - - - - -0.4% - - 1.4% -0.1% - -

Chaffee -5.1% -4.3% -5.1% -4.3% - - - - -6.0% -3.3% -6.0% -5.5%

Clear Creek 2.5% 10.7% - - 0.1% 2.3% - - 0.5% 4.8% - -

Custer -28.1% -23.7% -28.1% -23.7% - - - - -14.2% -11.8% -28.1% -23.4%

Dolores - - - - - - - - 5.3% 0.0% - -

Douglas -0.1% -1.5% -0.1% -1.5% - - - - - - - -

Eagle -13.9% -10.0% - - - - 2.3% 2.0% -10.2% -10.0% - -

El Paso - -1.0% - -1.0% - - - - - - - -

Fremont -27.6% -18.4% -27.6% -18.4% - - - - -0.2% -0.2% -27.6% -18.4%

Garfield -7.6% -6.4% - - - - - - -7.6% -6.4% - -

Grand - - - - -0.8% -4.9% -0.4% -2.5% 3.6% 8.1% -0.4% -1.9%
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

314—Chapter 3. Affected Environment and Environmental Consequences

County

Alternative 1 vs. Alternative 3 Alternative 2 vs. Alternative 3 Alternative 4 vs. Alternative 3

Some Potential for 

Treatment2

High Potential for 

Treatment3

Some Potential for 

Treatment2

High Potential for 

Treatment3

Some Potential for 

Treatment2

High Potential for 

Treatment3

Within 0.5 

miles

Within 1.5 

miles

Within 0.5 

miles

Within 1.5 

miles

Within 0.5 

miles

Within 1.5 

miles

Within 0.5 

miles

Within 1.5 

miles

Within 0.5 

miles

Within 1.5 

miles

Within 0.5 

miles

Within 1.5 

miles

Gunnison -1.0% -0.5% - - - - - - -1.0% -0.5% - -

Huerfano -17.3% -20.4% -17.3% -20.4% - - - - -15.9% -12.4% -15.9% -12.4%

La Plata - - - - - - - - -8.6% -21.0% -7.8% -19.8%

Lake - - - - - - - - -8.4% -9.3% -4.4% -5.3%

Larimer - - - - - - - - - -0.4% - -0.4%

Mineral - - - - - - - - -5.0% -10.7% -5.0% -10.7%

Montezuma - - - - - - - - 4.3% 0.0% - -

Park -4.4% -6.7% -4.4% -6.7% - - - - 0.0% -1.2% -2.5% -5.6%

Pitkin -15.0% -19.4% - - 2.4% 1.5% - - -13.6% -9.3% - -

Pueblo -27.2% -38.4% -27.2% -38.4% - - -12.2% -15.4% -27.2% -37.3% -27.2% -37.3%

Summit -1.6% -3.0% -0.1% -0.5% - - - - -0.8% -2.3% -0.1% -0.5%

Total -2.9% -3.2% -1.3% -1.7% 0.1% - - - -3.4% -4.2% -2.3% -3.7%

1 Potential means there is some likelihood of tree-cutting for the purpose of fuel treatment.

2 Number of Colorado Roadless Area acres that overlap with Community Protection Zones for at-risk communities where the likelihood of tree-cutting for the purpose of fuel treatment is projected to 

be "low" or "high" by forest units in the most recent roadless area activity projection survey (completed summer, 2010)

3 Number of Colorado Roadless Area acres that overlap with Community Protection Zones for at-risk communities where the likelihood of tree-cutting for the purpose of fuel treatment is projected to 

be "high" by forest units in the most recent roadless area activity projection survey (completed summer, 2010)
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—315

Benefits and Costs

The final part of economic consequences deals with a national perspective of benefits and costs. 

Unlike the previous section which dealt with regional economic impacts of jobs, income, and 

assets, this part considers benefits and costs realized by citizens across the nation. A discussion 

of benefits and costs, whether expressed in monetary terms or not, is a core function of 

disclosure and critical to decision-making. Table 2-14 in chapter 2 provides a summary of 

environmental consequences by alternatives. A detailed, qualitative discussion of benefits and 

costs based on Table 2-14 may be found in the Regulatory Impact and Cost-Benefit Analysis 

(Miller 2010). What follows is a brief summary of tradeoffs by alternative.

Alternative 1 – 2001 Roadless Rule

Roads and tree removal are highly restricted in this alternative. Projected road construction and 

tree removal in roadless areas are the lowest in this alternative. About 14 miles of road are 

anticipated, 11 of which are associated with energy development. No roads are anticipated for 

hazardous fuels reduction within the IRAs. About 2,300 acres are projected for tree-cutting for 

fuels reduction and forest health purposes. Entry into each roadless area would be prohibited 

except where existing rights allow. The government cost of management would generally be 

low. Emergency access would be expensive when required. Recreation settings would not 

change. Alternative 1 places the highest priority on protection of non-market roadless area 

characteristics. Natural processes and current conditions are recognized to be of very high 

value. This alternative offers the fewest opportunities for hazardous fuel treatments near at-risk 

communities, treatments for forest health, and energy mineral extraction. Alternative 1 retains 

the greatest options for roadless values, but effectively foregoes most options for future use or 

development. While management restrictions for any roadless area could be reversed, the time 

and budgetary costs to do so would be very high.

Alternative 2 – Colorado Roadless Rule (Proposed Action)

Roads and tree removal are allowed under limited conditions in this alternative. Twenty miles 

of road are anticipated, 13 of which are associated with energy development. Five miles of road 

are anticipated for hazardous fuels or forest health treatment. About 6,900 acres are projected 

for tree-cutting for fuels reduction and forest health purposes. The government cost of 

management would generally be modest. Emergency access would be expensive when 

required. Recreation settings would change little from current conditions. Alternative 2 places a 

high priority on protection of non-market roadless area characteristics, especially within the 

upper tier acres. Natural processes and current conditions are recognized to be of high value. 

This alternative offers some opportunities for hazardous fuel treatments near at-risk 

communities, some water conveyances, and coal extraction. Alternative 2 retains most options 

for roadless values, but effectively foregoes many options for future use or development. While 

management restrictions for any roadless area could be reversed, the time and budgetary costs 

to do so would be high.

Alternative 3 – Forest Plans (No Action)

Projected road construction and tree-cutting, sale or removal in roadless areas is the highest in 

this alternative. Nearly 28 miles of road are anticipated, 22 of which are associated with energy 

development or hazardous fuels reduction. About 16,600 acres are projected for tree-cutting for 

fuels reduction and forest health purposes. In addition, 300 acres are projected for entry and 

tree-cutting for public health safety and other purposes. Entry into each roadless area would be 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

316—Chapter 3. Affected Environment and Environmental Consequences

weighed as part of the forest planning process. In most cases, entry would require compliance 

with NEPA and consideration of benefits and costs – market and non-market – for each roadless 

area. The government cost of management would have the greatest range, from low cost for no 

entry and treatment in some roadless areas to high cost for road construction and maintenance, 

law enforcement, permit administration, and other routine activities in other roadless areas. The 

cost of entry also includes administrative costs for NEPA compliance and resource monitoring.

Recreation settings would change, but forest-wide recreation use may not. Roadless area 

characteristics would receive the highest priority and remain unchanged in some areas, but 

could be significantly altered in others, depending on forest plan direction. This alternative 

includes the largest potential change to wildlife habitat along with the greatest opportunities for 

hazard fuel reduction for at-risk communities, forest health treatments, energy mineral

development and production. Roadless area characteristics and non-market benefits would be 

retained. Alternative 3 retains the most options for future use or non-use, and thus limits 

opportunities foregone.

Alternative 4 – Colorado Roadless Rule with Public Proposed Upper Tier Acres

Effects are similar to alternative 2, but with additional upper tier acres, there would be more 

restrictions on road construction and tree-cutting on more acres. This alternative would protect 

most roadless area characteristics on those upper tier acres than the other alternatives, limiting 

all other future uses.

Eighteen miles of road are anticipated, approximately 13 of which are associated with energy 

development. Three miles of road are anticipated for hazardous fuels or forest health 

treatment; 1 mile of the 3 is within the CRAs. Approximately 3,000 acres are projected for tree 

cutting for fuels reduction and forest health purposes; 1,800 acres of which are within the CRAs.

Economics: Cumulative Effects

Values at Risk From Wildfire

Growth of mountain communities, including those near public lands and roadless areas, may be 

the single most important factor in gauging cumulative effects for values at risk of wildfire.

National demographics and income trends are primary drivers in Colorado population 

forecasts. By 2025, the Colorado population is expected to grow by 34 percent. The western 

slope and central mountain areas of the State, where most roadless areas are located, are 

expected to grow by 49 percent and 47 percent, respectively (Colorado Department of Local 

Affairs, State Demography Office 2008). This high growth will likely add to local infrastructure, 

both public and private, making current at-risk communities even more vulnerable to wildfire 

hazards. The ability to treat fuels in roadless areas located in the urban interface could prove to 

be increasingly important to maintaining the quality of life in at-risk communities. Even with 

responsible, proactive actions on the part of local homeowners, the ability to manage wildland 

fuels could be critical. Alternatives 2 and 3 offer more options for reducing the threat of wildfire 

in roadless areas near these communities now and in the future.

Benefits and Costs

With population growth and private land development, the value of non-market roadless area 

characteristics can be expected to increase. This increase places a higher premium on the 

retention of roadless area characteristics, such as natural processes, retention of future options, 

and recreation uses. The same growth, however, also increases the value of wildland protection 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—317

for communities and energy mineral benefits to the nation. The tradeoffs inherent in each of the 

alternatives could easily shift in the future, but it is very difficult to assess the direction and 

magnitude of societal values. 

OTHER EFFECTS DISCLOSURES

Short-Term Uses and Long-Term Productivity

The NEPA requires consideration of ―the relationship between short-term uses of man‘s 

environment and the maintenance and enhancement of long-term productivity‖ (40 CFR 

§1502.16). As declared by Congress, this includes using all practicable means and measures, 

including financial and technical assistance, in a manner calculated to foster and promote the 

general welfare, to create and maintain conditions under which man and nature can exist in 

productive harmony, and fulfill the social, economic, and other requirements of present and 

future generations of Americans (NEPA Section 101). The alternatives all integrate those 

considerations, and ascribe to the principles described in the Forest and Rangeland Renewable 

Resources Planning Act as amended by the National Forest Management Act, as well as the 

Multiple-Use Sustained-Yield Act. The Multiple-Use Sustained Yield Act defines productivity 

as part of multiple-use management. None of the alternatives would deviate from those 

requirements. Consistent with the Multiple-Use Sustained Yield Act, some land will be used for 

less than all of the resources, and the management of various resources would be done without 

impairing the long-term productivity of the land. In addition, consideration is given to the 

relative values of the various resources, and not necessarily the uses that would give the 

greatest dollar return or output. Adopting any of the alternatives would not involve 

implementing any on-the-ground action; therefore, the alternatives do not compel any shortterm uses. 

However, there are differences among alternatives in prohibitions and permissions related to 

road construction or tree-cutting activities in roadless areas. Road construction would be the 

only short-term use that varies by alternative and has the potential to cause a reduction in longterm productivity in the roadless areas. Such roads can cause a loss of long-term soil and 

vegetative productivity and other watershed and wildlife habitat values that last for several 

decades or longer. Tree-cutting activities would not be likely to result in a long-term or 

permanent loss of productivity in the roadless areas.

All Alternatives

Under all alternatives, the use of short-term temporary roads would be more typical in the IRAs 

or CRAs, and those roads would be rehabilitated to restore long-term productivity after their 

use has ended.

Alternative 1 would cause the lowest risk of a short-term use impairing long-term productivity 

because the 2001 Rule is the most restrictive of the alternatives in terms of constructing roads in 

IRAs. 

Alternatives 2 and 4 would cause a relatively low risk of losing long-term productivity in CRAs 

as well, because most roads allowed would be temporary and would eventually be 

decommissioned. However, projections indicate that alternatives 2 and 4 would result in more 

miles of temporary roads being built in CRAs in support of coal operations, so alternatives 2 

and 4 would result in a slightly higher loss of long-term productivity on those road miles (see 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

318—Chapter 3. Affected Environment and Environmental Consequences

projections in Analysis Framework section). For alternatives 1, 2, or 4 the loss of long term 

productivity would be to a relatively limited acreage, especially compared with NFS and other 

lands where road construction is not restricted. 

Alternative 3 would cause a moderate risk of losing long-term productivity in IRAs where 

several forest plans do not restrict construction of permanent roads. See Appendix B and the 

alternative 3 map, which show the forest plan restrictions on roads in roadless areas. Projections 

of temporary roads in support of oil, gas and coal operations are slightly higher under 

alternative 3 compared to alternatives 1, 2 or 4. 

Unavoidable Adverse Effects

The projected amount of road construction, tree-cutting, and oil, gas or coal development 

activities in roadless areas that differ by alternative would result in some potentially 

unavoidable adverse effects in localized portions of some roadless areas. These effects are 

described in more detail in each section of chapter 3 as well as in the Comparison of 

Alternatives section in chapter 2. Site-specific mitigation measures would be expected to be 

identified during project planning and applied during implementation to avoid or minimize 

adverse environmental effects. 

Alternative 1 – 2001 Roadless Rule

Unavoidable adverse effects associated with alternative 1 include less IRA acreage within which 

to reduce wildland fire hazard, provide for utilities or water conveyances, or explore for and 

develop oil, gas or coal resources. 

Alternative 2 – Colorado Roadless Rule (Proposed Action)

Compared to alternative 1, unavoidable adverse effects associated with alternative 2 include a 

slight reduction in semi-primitive recreation settings and existing scenic quality; increases in 

invasive plant populations that can indirectly adversely affect threatened, endangered or 

sensitive plants and other resources; and an increased risk to aquatic and terrestrial animal 

species and habitat in some CRAs.

Alternative – Forest Plans (No Action)

Compared to alternatives 1, 2, and 4 unavoidable adverse effects associated with alternative 3 

include greater reductions in IRA acreage providing semi-primitive recreation settings and high 

scenic integrity; greater increases in roadless areas with invasive plant populations that can 

indirectly adversely affect threatened, endangered or sensitive plants and other resources; and 

an increased risk to aquatic and terrestrial animal species and habitat in some areas.

Alternative 1 – Colorado Roadless Rule with Public Proposed Upper Tier

This alternative is similar to alternative 2. There would be a lesser degree of unavoidable 

adverse effects than alternative 2. 

Irreversible and Irretrievable Commitments of Resources

Irreversible commitments of resources are those that cannot be regained, such as the extinction 

of a species or the removal of mined ore. Irretrievable commitments are those that are lost for a 

period of time, such as the temporary loss of vegetative or soil productivity in forested areas 

that are cleared for use of those lands for roads, powerline rights-of-way, or other constructed 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 3. Affected Environment and Environmental Consequences—319

facilities. 

The roadless area management alternatives that are subject to this analysis do not include any 

site-specific actions to be implemented. Therefore, there can be no actual irreversible or 

irretrievable commitments of resources associated with any of these alternatives. Commitments 

of resources would take place when projects or activities are proposed and after the preparation 

and consideration of appropriate NEPA analysis and documentation.

However, based on projections of potential activities that differ by alternative, differences in the 

potential for irreversible and irretrievable commitments of resources could be estimated. 

Constructing new roads and other facilities would result in commitments of resources, as 

would extraction of non-renewable energy mineral resources such as oil, gas and coal. No 

irreversible or irretrievable commitments of resources would be likely to result from 

permissible tree-cutting activities under any alternative.

Alternative 1 – 2001 Roadless Rule

The amount of irreversible or irretrievable commitments of resources expected under this 

alternative would be negligible, due to the general prohibition on road construction and treecutting except under very limited exceptional circumstances. However, there would be 

approximately 11 miles of road construction or reconstruction per year in IRAs and 3 miles of 

road construction or reconstruction in the remainder of the analysis area. Some of the roads 

would entail longer term road use for oil, gas or coal operations. Wells, well pads, and other 

ground disturbing activities projected to occur in roadless areas under this alternative would be 

considered an irretrievable commitment of resources in those localized sites. That commitment 

would be reversed and vegetative productivity reclaimed on those constructed roads and 

facilities sites after the use of those roads or facilities has ended. Additionally, the amount of oil, 

natural gas, and coal that could be extracted from roadless areas would be an irreversible 

commitment of resources (see the Leasable Minerals section for details and quantities).

Alternative 2 – Colorado Roadless Rule (Proposed Action)

There would be a minimal amount of irreversible or irretrievable commitments of resources 

expected under this alternative due to the general prohibition on road construction and treecutting except under certain exceptional circumstances. However, there would be 

approximately 16 miles of road construction or reconstruction per year in CRAs with 4 miles of 

road construction or reconstruction per year in the remainder of the analysis area. Some of the 

roads would entail longer term road use for oil, gas or coal operations. Wells, well pads, and 

other ground disturbing activities projected to occur in roadless areas under this alternative 

would be considered an irretrievable commitment of resources in those localized sites. That 

commitment would be reversed and vegetative productivity reclaimed on those constructed 

roads and facilities sites after the use of those roads or facilities has ended. Additionally, the 

amount of oil, natural gas, and coal that could be extracted from roadless areas would be an 

irreversible commitment of resources (see the Leasable Minerals section for details and 

quantities). 

Alternative 3 – Forest Plans (No Action)

The commitments of resources would be similar to alternative 2, but there would be more 

roadless area acres where there is an irretrievable commitment of resources anticipated, based 

on projections displayed in the Analysis Framework section. Approximately 28 miles of roads 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

320—Chapter 3. Affected Environment and Environmental Consequences

would be built in the analysis area each year, with the majority of those roads being for oil, gas 

or coal resource operations; some of the roads would entail longer term road use. Wells, well 

pads, and other ground-disturbing activities projected to occur would add to the total 

irretrievable commitment of resources in those localized sites. Additionally, the amount of oil, 

natural gas, and coal that could be extracted from roadless areas would be an irreversible 

commitment of resources (see the Leasable Minerals section for details and quantities).

Alternative 4 – Colorado Roadless Rule with Public Proposed Upper Tier

Similar to alternative 2, there would be a minimal amount of irreversible or irretrievable 

commitments of resources expected under this alternative due to the general prohibition on 

road construction and tree-cutting except under certain exceptional circumstances. However, 

there would be approximately 14 miles of road construction or reconstruction per year in CRAs 

with 4 miles of road construction or reconstruction per year in the remainder of the analysis 

area. Some of the roads would entail longer term road use for oil, gas or coal operations. Wells, 

well pads, and other ground disturbing activities projected to occur in roadless areas under this 

alternative would be considered an irretrievable commitment of resources in those localized 

sites. That commitment would be reversed and vegetative productivity reclaimed on those 

constructed roads and facilities sites after the use of those roads or facilities has ended. 

Additionally, the amount of oil, natural gas, and coal that could be extracted from roadless 

areas would be an irreversible commitment of resources (see the Leasable Minerals section for 

details and quantities). 

Other Required Disclosures

The NEPA implementing regulations direct agencies to prepare draft environmental impact 

statements concurrently with and integrated with other environmental review laws and 

executive orders (40 CFR 1502.25a). Consultation and coordination with the US Fish and 

Wildlife Service is ongoing during preparation of the EIS for this rulemaking proposal, and 

included completion of a biological assessment, in accordance with the Endangered Species Act

requirements (more information is in the Terrestrial Species and Habitat section and EIS 

record). None of the alternatives would require consultation under the Fish and Wildlife 

Coordination Act because they do not require water to be impounded or diverted, or with the 

National Historic Preservation Act because there would be no ground-disturbing actions.

The US Department of Agriculture rulemaking procedural requirements are being followed for 

this proposed rulemaking action, including associated requirements of the Unfunded Mandates 

Reform Act, Executive Order 12988, and the Civil Justice Reform Act, as is discussed in the 

preamble for the proposed rule (published in the Federal Register). There are no anticipated 

effects on any State or county laws because of the permissions for existing rights. Effects of each 

alternative in relation to the Clean Air Act, Clean Water Act, Migratory Bird Treaty Act, 

Wilderness Act, and other federal environmental laws, regulations, and executive orders are 

disclosed in each section of chapter 3 where an effect is anticipated.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 4. Preparers and EIS Distribution—321

CHAPTER 4. PREPARERS AND EIS DISTRIBUTION

LIST OF PREPARERS

This section provides a list of the people who were primarily responsible for preparing this 

environmental impact statement (EIS), in accordance with regulations at 36 CFR 1502.17. It is 

organized alphabetically by last name, and includes the individual‘s work group and 

organization, contribution to the EIS, and their educational qualifications and years of relevant 

work experience. A second list is also provided to acknowledge the other specialists and 

managers who provided oversight, guidance, reviews and other information in support of this 

document. In addition to those listed, other Forest Service personnel provided invaluable 

administrative and technical support during the development of this document.

Primary Contributors to the EIS

Name Organization EIS Contribution Education

Years of Relevant 

Experience

Bruin, Susan Environmental 

coordination, FSTEAMS, Washington 

Office

Process 

management and 

documentation

M.S., Natural Resource 

Policy and Administration

B.S., Natural Resource 

Management

27

Carlson, Joan Water resources 

program, Rocky 

Mountain Regional 

Office

Water resources M.S., Forest Engineering

B.S., Forest Science

M.B.A.

21

Dean, Cindy Recreation special 

uses, Rocky Mountain 

Regional Office

Process 

documentation

B.S., Forest Management 25

Dunn, Michael Minerals and geology 

program, Rocky 

Mountain Regional 

Office, Retired

Locatable and 

saleable minerals,

geological and 

paleontological

resources, and 

abandoned mines

M.S., Geology

B.S., Geology

32

Gee, Angela Fire and fuels

program, Rocky 

Mountain Regional 

Office

Fuels and fire 

ecology

B.S., Forestry 6

Holm, Melody Minerals and geology 

centralized national 

operations

Leasable minerals, 

oil and gas

resources 

M.A., Geology

B.A., Geology

33
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

322—Chapter 4. Preparers and EIS Distribution

Name Organization EIS Contribution Education

Years of Relevant 

Experience

John, Tommy Soil resources 

program, Rocky 

Mountain Regional 

Office

Soil resources M.S., Forest Soil

B.S., Forestry

33

Kowynia, Ken Winter sports program, 

Rocky Mountain 

Regional Office

Developed ski areas B.A., Pre-Medicine, 

Psychology

M.F., Forest Management

36

Kratz, Andrew Botany program, 

Rocky Mountain 

Regional Office

Threatened, 

endangered, and 

sensitive plants

M.S., Biology (plant 

synecology)

B.A., Biology

29

Kurtz, Kathy Strategic planning, 

Rocky Mountain 

Regional Office

Process 

management

B.S., Forest Biology 29

Langowski, Paul Fire and fuels 

program, Rocky 

Mountain Regional 

Office

Fuels & Fire 

Ecology

B.S., Resource 

Management

32

Liestman, Terri Heritage program

Rocky Mountain 

Regional Office

Cultural Resources M.A. Anthropology

B.A. Anthropology

30

Mattson, Liane Leaseable minerals 

program, Grand Mesa, 

Uncompahgre, and 

Gunnison NFs

Leaseable minerals 

and coal mining

B.S., Geological 

Engineering

15

McClure, Tom Invasive species 

program, Rocky 

Mountain Regional 

Office

Invasive plants B.S., Range and Forest 

Ecology

29

Milligan, Joshua NEPA, Chugach 

National Forest

Writer/editor Juris Doctor

M.S., Environmental Law

B.S., Business 

Administration in Finance

9

Moll, Jeffry Engineering, Rocky 

Mountain Regional 

Office

Roads Registered Professional 

Engineer

M.S., Civil Engineering

B.S., Civil Engineering

32

O’Connell, 

Michele 

Lands and special 

uses program, Rocky 

Mountain Regional 

Office

Land special use 

authorizations

B.S., Resource 

Management/ Forestry

28
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 4. Preparers and EIS Distribution—323

Name Organization EIS Contribution Education

Years of Relevant 

Experience

Quimby, 

Charles 

Rangelands and 

grazing program, 

Rocky Mountain 

Regional Office, 

Retired

Rangeland health 

and livestock

grazing 

M.S., Watershed 

Management

B.S., Range Management

39

Retzlaff, Mike Economic Insights of 

Colorado, LLC

Economics M.S., Economics

B.S., Hydrology

35

Schaefers, Julie Strategic planning, 

Rocky Mountain 

Regional Office

Social Report, GIS 

Analysis, and EIS

M.S., Natural Resource 

Economics

B.S., Forestry 

Management

18

Schillie, Trey Strategic planning,

Rocky Mountain 

Regional Office

Climate Change M.S. Environmental 

Management

B.S. Geography

11

Skeels, Pamela Strategic planning,

Rocky Mountain 

Regional Office

Roadless Rule and 

EIS writing-editing, 

and roadless areas 

information

M.S., Forest and Range 

Management

B.S., Forest Resource 

Management

36

Sorkin, Jeff Air program, Rocky 

Mountain Regional 

Office

Air Resource M.S., Environmental 

Science

M.S., Public Affairs

B.S., Zoology

11

Sporl, Chris Recreation, Rocky 

Mountain Regional 

Office

Dispersed 

recreation and 

scenic resources 

M.L.A., Masters of 

Landscape Architecture

B.S., Horticulture

16

Swain, Ralph Wilderness program, 

Rocky Mountain 

Regional Office 

Wilderness and 

other 

congressionally 

designated areas

M.S., Natural Resource 

Management

B.A., Marketing

28

Thinnes, Jim Silviculture, Rocky 

Mountain Regional 

Office

Forest vegetation 

and health 

Post- bac., Forest 

Engineering and 

Silviculture

B.S., Natural Resource 

Management

30

Tu, Ken Strategic planning,

Rocky Mountain 

Regional Office

Process 

management

B.S. Forest Management 26

Warren, Nancy Regional threatened, 

endangered and 

sensitive species 

program, Rocky 

Mountain Regional 

Office

Terrestrial habitat

and species, 

including federallylisted species

M.S., Wildlife 

Management

B.S., Wildlife Biology

30
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

324—Chapter 4. Preparers and EIS Distribution

Name Organization EIS Contribution Education

Years of Relevant 

Experience

Wehrli, 

Christopher

Strategic planning,

Rocky Mountain 

Regional Office

NEPA Review B.A. Political Science 13

Winters, David Aquatic ecology and 

fisheries program, 

Rocky Mountain 

Regional Office

Aquatic habitat and 

species, and 

reference 

landscapes

M.S., Zoology with an 

emphasis in Aquatic 

Biology

B.S., Fishery Biology

A.A.S., Fish and Wildlife 

Technology

22

Wilson, Janice 

E.

Geographic 

Information, Rocky 

Mountain Regional 

Office

GIS analysis and 

maps

B.A., Geography 26

Other Contributors to the EIS

The following people contributed to the EIS by providing oversight, guidance, document 

reviews, or other information to this Revised DEIS or the DEIS. This list includes their name, 

current office, and primary contribution or area of expertise. They are Forest Service employees 

except where otherwise noted. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 4. Preparers and EIS Distribution—325

Name Primary Contribution Office

Abing, Tim Oil, gas and geothermal review Rocky Mountain Regional Office

Bowden, Philip Vegetation review Pacific Southwest Regional Office

Briggs, Shane Terrestrial wildlife review Colorado Division of Wildlife

Burmark, Brad Economic review Pacific Southwest Regional Office

Carlson, Ann Aquatic wildlife review Northern Regional Office

Cawrse, David Vegetation review Washington Office

Ciapusci, Teresa Ann EIS writing-editing Coronado National Forest

Clark, David Tribal consultation Southwestern Regional Office

Cook, Richard Process oversight/guidance Washington Office

Cossette, Steve Process oversight/guidance Washington Office

Cox, Brian Biological evaluations Bureau of Land Management

DeBord, Karen Vegetation review Bureau of Indian Affairs

DeWitte, Vince Legal compliance Office of General Council-Washington 

Office

Dillon, Madelyn Writing-editing/publishing Publishing Arts-Washington Office

Duda, Joe Vegetation review Colorado Department of Forestry

Ernst-Ulrich, Gwen Public involvement Independent Resources, Washington 

Office

Friedman, Sharon Process oversight/guidance Rocky Mountain Regional Office

Garner, Elizabeth Economic review State of Colorado, Department of Local 

Affairs

Graham, Russell Vegetation review Rocky Mountain Research Station

Granger, Geneen EIS writing-editing, comment processing 

and analysis Southwest Regional Office

Houghton, Bonnie Livestock management review Rocky Mountain Regional Office

ICF- Jones and Stokes, Inc. Public comment processing and analysis ICF- Jones & Stokes, Salt Lake City, UT 

office

Jain, Terrie Vegetation review Rocky Mountain Research Station

Janik, Anne Roadless area profile editing GMUG National Forest

Johnson, Susan Tribal consultation Rocky Mountain Regional Office

Karkula, Ken Process oversight/guidance Washington Office

Karsteadt, Randy Process oversight/guidance Rocky Mountain Regional Office

Kurth, Jay Vegetation review Black Hills National Forest

LaPerriere, Monique Copy-editing Publishing Arts-Washington Office

Larkin-McKim, Kelly Aquatic wildlife review & aquatics data Arapaho-Roosevelt NF

LoSapio, Carol Document formatting Publishing Arts-Washington Office 

Lui, Karen Economic regulatory impact analysis Washington Office 

Martin, Thomas Vegetation review Intermountain Regional Office

McDonald, Peter TES wildlife, ESA consultations Rocky Mountain Regional Office

Miller, Chris Economic regulatory impact analysis Washington Office
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

326—Chapter 4. Preparers and EIS Distribution

Name Primary Contribution Office

Misztal, Adam Aquatic and terrestrial wildlife review US Fish and Wildlife Service

Mitchell, Veronica Roads Rocky Mountain Regional Office

Morgan, Edward Vegetation review Bureau of Indian Affairs

Nesler, Tom Aquatic wildlife review Colorado Division of Wildlife

Ogden, Cay Terrestrial wildlife review National Park Service

Overturf, Jeff Cultural resources Rocky Mountain Regional Office

Parker, Tracy Saleable and locatable review Washington Office

Page, Dennis Vegetation review Pike-San Isabel National Forest

Palmer, Kelly Air resource San Juan National Forest

Regan, Claudia Ecology Rocky Mountain Regional Office

Riffe, Mark Copy-editing Publishing Arts-Washington Office

Rinella, Steve Lands Rocky Mountain Regional Office

Rolofson, Bud Air quality Retired Forest Service

Rumbold, Ed Aquatic wildlife review Bureau of Land Management

Rupe, John Forest planning and analysis Rocky Mountain Regional Office

Skorkowsky, Robert Migratory birds Medicine Bow-Routt National Forest

Smith, Janelle Public involvement Rocky Mountain Regional Office

Stockmann, Keith Economic review Intermountain Regional Office

Supulski, Bill Process oversight/guidance Washington Office

Sutton, Jody Comment analysis and responses Washington Office

Wilson, Josh Economic review Forest Service, T.E.A.Ms

Witcosky, Jeff Vegetation review Rocky Mountain Regional Office

Woolever, Melanie Terrestrial animal habitat and species Rocky Mountain Regional Office

National Forest Coordinators

The following Forest Service employees were the primary contacts between the regional office 

planning team and the national forests in Colorado. They coordinated the data gathering and 

document reviews with appropriate national forest resource specialists and managers. The GIS 

staffs and other specialists on each forest contributed data throughout the planning process.

Name National Forest Office

Dyer, Harold Rio Grande National Forest 

Gayton, Dyce Arapaho-Roosevelt National Forest

Haskins, Wendy White River National Forest

Howe, Carol Grand Mesa, Uncompahgre, and Gunnison National Forests

Jewkes, Pamela Manti-La Sal National Forest 

Johnson, Mike San Juan National Forest

Romero, Frank Routt National Forest

Thibedeau, Ron Pike-San Isabel National Forest
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 4. Preparers and EIS Distribution—327

DISTRIBUTION OF THE DRAFT ENVIRONMENTAL IMPACT STATEMENT

This section provides a list of the agencies and organizations that were sent copies of the EIS or 

notified of its availability on the Web. This list includes federal, state, and local governmental 

organizations, elected officials, and federally recognized tribes who submitted comments or 

requested to be on the mailing list for this EIS. It does not include the thousands of individuals 

on the mailing list who were also sent copies of the EIS or notified of its availability on the Web, 

depending on the preference they expressed in response to a Forest Service inquiry. 

Government Agencies and Tribal Governments

Agencies

Access Board, U.S.

Advisory Council on Historic Preservation

Agriculture, U.S. Department of

Animal and Plant Health Inspection Service (APHIS)

Forest Service, Washington Office 

Forest Service, Rocky Mountain Regional Office

Forest Service, Intermountain Regional Office

Forest Service, Arapaho and Roosevelt National Forest

Forest Service, Grand Mesa, Uncompahgre, and 

Gunnison National Forests 

Forest Service, Manti-La Sal National Forest

Forest Service, Medicine Bow-Routt National Forest 

Forest Service, Pike and San Isabel National Forests 

Forest Service, Rio Grande National Forest 

Forest Service, San Juan National Forest 

Forest Service, White River National Forest 

National Agricultural Library

Natural Resources Conservation Service

Office of Civil Rights

USDA/BLM Gunnison Resource Area

Air Force, U.S. 

Air Force Civil Engineer

Army Corps of Engineers, U.S.

Washington Office

Northwestern Division

Defense, U.S. Department of

Environmental Protection Agency, U.S.

Office of Federal Activities

EPA- Region 8

Federal Energy Regulatory Commission

Interior, U.S. Department of the

Bureau of Land Management 

Gunnison Resource Area

Fish and Wildlife Service

National Park Service

Black Canyon National Park

Uncompahgre Field Office

Office of Environmental Policy and Compliance

Army Engineer Division, U.S.

Colorado, State of

Department of Public Health and the Environment

Air Quality Commission

Water Quality Commission

Department of Natural Resources

Division of Wildlife

Division of Forestry

Federal Lands Coordination

Oil and Gas Conservation Commission

State Land Board

Department of Transportation

Historical Office

Office of Archaeology and Historic Preservation

Northwest Colorado Council of Governors

Colorado Congressional Delegations, U.S.

City Governments

U.S. Conference of Mayors

County Governments

The 41 counties in Colorado with roadless area lands 

(listed in chapter 3-Social)

Energy, U.S. Department of

Western Area Power Administration

National Oceanic and Atmospheric Administration

Navy, U.S.

Chief of Naval Operations

Utah, State of

Department of Natural Resources
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

328—Chapter 4. Preparers and EIS Distribution

Federally Recognized Tribes

Arapaho of Ft. Washakie WY Cheyenne and Arapaho Tribes of OK

Hopi Tribe Jicarilla Apache Nation

Navajo Nation Northern Cheyenne Tribe

Ohkay Owingeh Pueblo of Jemez

Pueblo of Nambé Pueblo of Picuris

Pueblo of Pojoaque Pueblo of San Ildefonso

Pueblo of Santa Clara Pueblo of Taos

Pueblo of Tesuque Pueblo of Zuni

Shoshone of Ft. Washakie, WY So. Ute Indian Tribe of Ignacio, CO

Ute Mountain Tribe of Towaoc, CO

Organizations

American Camping Association American Farm Bureau Federation

American Counsel of Snowmobile Associations American Forests

American Fisheries American Hiking Society

American Geological Society American Loggers Council

American Lands Alliance American Mountain Guide Association

American Motorcyclist Association American Rivers

American Petroleum Institute American Society of Landscape Architects

American Sheep Industry Association American Sportfishing Association

American Society of Travel Agents Appalachian Mountain Club

American Water Works Association Audubon Society, Grand Valley

Association of Partners for Public Lands Backcountry Hunters & Anglers

Audubon Society, Arvada Valley Blue Mesa 4 Wheelers

Backcountry Horsemen of America Boy Scouts of America

Backcountry Snowsports Alliance Californians for Western Wilderness

Boone and Crocket Club Center for Biological Diversity

Buckmasters Center for Plant Conservation

Camp Fire Club of America Central Colorado Wilderness Coalition

Center for Native Ecosystems Colorado Mining Association

Center for Water Advocacy Colorado Oil and Gas Association

Colorado Environmental Coalition Colorado Snowmobile Association

Colorado Mountain Club Colorado Trout Unlimited

Colorado Ski Country USA Colorado Wildlife Federation

Colorado Timber Industry Association Conservation Force

Colorado Wild Creepers Jeepers

Conservation Congress Crested Butte Mountain Resort

Continental Divide Trail Alliance Defenders of Wildlife
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 4. Preparers and EIS Distribution—329

Crested Butte Mountain Bike Association Ducks Unlimited

Cross Country Ski Areas Association Earthjustice

Domestic Petroleum Council Elk Mountains Hikers Club

Earthjustice Legal Defense Fund Environmental Coalition

Ecological Society of America Environmental Law Institute

Environmental Alliance for Senior Involvement Evergreen Audubon Society

Environmental Defense Forest Guild

Environmental Working Group Forest Products Society

Forest Conservation Council Forest Service Employees for Environmental Ethics

Forest Landowners Association Fort Lewis College Environmental Center

Forest Resources Association Four Corners Backcountry Horsemen

Forest World Friends of the Earth

Foundation for North American Wild Sheep Girl Scouts of America

Four Corners Trail Club Grand Mesa Nordic Council

Geological Society of America Greater Yellowstone Coalition

Gold Prospectors Association Gunnison Energy Corp

Great Old Broads for Wilderness Heritage Conservation Program

Greenpeace High Country Motorsports, Inc.

Gunnison Trails NPO Independent Petroleum Association of America

High Country Citizen’s Alliance Indian Peaks Wilderness Alliance

High Rocky Riders OHV Club Intermountain Forest Association

Indian Land Tenure Foundation International Mountain Biking Association

Institute for Culture and Ecology International Snowmobile Manufacturers Association

International City and County Management Association Izaak Walton League

International Rights Of Way Association Kokopelli Bike Club

Intertribal Timber Council Maricopa Audubon Society

Jews of the Earth Maryland Ornithological Society

Leave No Trace Mineral Policy Center

Marina Operators Association of America Mountain Coal Company

Methow Valley Backcountry Horsemen Mule Deer Foundation

Montana Wilderness Association National Audubon Society

Mountain Studies Institute National Alliance of Gateway Communities

National 4-H Council National Association of State Park Directors

National Association of Conservation Districts National Cattlemen’s Beef Association

National Association of State Trail Administration National Council for Science and the Environment

National Coal Council National Environmental Trust

National Council of American Indians National Governors Association

National Forest Foundation National Mining Association

National Hardwood Lumber Association National Parks Conservation Association
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

330—Chapter 4. Preparers and EIS Distribution

National Off-Highway Vehicle Conservation Council National Recreation and Parks Association

National Petroleum Council National Rifle Association

National Religious Partnership for the Environment National Ski Area Association

National Shooting Sports Foundation National Sporting Goods Association

National Speleological Society National Tribal Environmental Council

National Stone, Sand, and Gravel Association National Wild Turkey Association

National Trust for Historic Preservation National Wildlife Refuge System

National Wildlife Federation Natural Resources Defense Council

Native American Rights Fund North American Grouse Partnership

Nature Serve Northern Colorado Trail Riders Association

North American Pronghorn Foundation Northwest Mining Association

Northwest Forestry Association Outdoor Industry Association

Ouray Trail Group Oxbow Mining LLC

Outward Bound Partnership for the National Trails System

Pacific Rivers Council Plains Exploration and Production Company

Pinchot Institute for Conservation Public Land Partnership

Powderhorn Resort Resources for the Future

Quiet Use Coalition Rocky Mountain Land Use Institute

Rocky Mountain Elk Foundation Safari Club International

Rocky Mountain Mineral Law Foundation San Juan Citizens Alliance

Salida Mountain Trails San Juan Wise Use Alliance

San Juan Trail Riders Sheep Mountain Alliance

San Luis Valley Ecosystem Council Sierra Club, Colorado Chapter

Sierra Club Silver Institute

Sierra Club, Rocky Mountain Chapter, Pikes Peak Group Society for Conservation Biology

Snowsports Industries America Society for Historical Archaeology

Society for Ecological Restoration International Society of Mining, Metallurgy, and Exploration

Society of American Foresters Southern Environmental Law Center

Society of Range Management Stewards of the Sequoia

Southern Rockies Ecosystem Project The American Alpine Club

The Access Fund The Conservation Fund

The American Land Conservancy The Nature Conservancy

The Lands Council The Nature Conservancy, Utah

The Nature Conservancy, Colorado Theodore Roosevelt Conservation Partnership

The Ocean Conservancy the Wild Foundation Trail Users Partnership

Three Lakes Watershed Association Tread Lightly

Travel Industry Association of America Trout Unlimited

Tri-State Generation & Transmission Association, Inc. Uncompahgre Valley Trail Riders

Trust for Public Land University of Wyoming- Department of Geology and 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Chapter 4. Preparers and EIS Distribution—331

Recreation

United Four Wheel Drive Association, Inc. Vail Resorts, Inc.

Upper Arkansas Motorized Recreation Coalition Western Environmental Law

Western Colorado Congress Western Governors Association

Western Fire Ecology Center Western Lands Project

Western Land Group Western Organization of Resource Councils

Western Native Trout Wild Connects Upper Arkansas, South Platte Project

Western States Tourism Council Wild Wilderness

Wild Earth Guardians Wilderness Land Trust

Wildlands Center for Preventing Roads Wilderness Society, Central Rockies Region

Wilderness Society Wildlands CPR

Wilderness Workshop Wildlife Habitat Council

Wildlaw Willsource Enterptise, LLC

Wildlife Management Institute World Resources Institute

Winter Wildlands Alliance
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

332—Chapter 4. Preparers and EIS Distribution
Roadless Area Conservation; National Forest System Lands in Colorado RDEIS

Index—333

CHAPTER 5. REFERENCES CITED

Albini, F.A. 1983. Potential spotting distances from 

wind-driven surface fires. Res. Pap. INT-309. 

Ogden, UT: U.S. Department of Agriculture, 

Forest Service, Intermountain Forest and 

Range Experiment Station. 27 p. 

Allan, J.D. 1995. Stream ecology: structure and 

function of running waters. New York, NY: 

Chapman and Hall. 388 p. 

Amman, G.D.; McGregor, M.D.; Cahill, D.B.; Klein, 

W.H. 1977. Guidelines for reducing losses of 

lodgepole pine to mountain pine beetles in 

unmanaged stands in the Rocky Mountains. 

Gen. Tech. Rep. INT-36. Ogden, UT: U.S. 

Department of Agriculture, Forest Service, 

Intermountain Forest and Range Experiment 

Station. 19 p. 

Anders, N. Personal communication with Nancy 

Anders. April 22, 2008. 

Andrews, K.M; Gibbons, J.W. 2005. How do 

highways influence snake movement? 

Behavioral responses to roads and vehicles. 

Copeia. 4: 772-782. 

www.uga.edu/srel/reprint/2906.htm (April 

2008). 

Andrews, P.L. 1996. Fire behavior. In: Pyne, S.J.; 

Andrews, P.L.; Laven, R.D. Introduction to 

wildland fire. 2nd ed. New York, NY: John 

Wiley and Sons: Chapter 2. 

Anthony, R.G; Isaacs, F.B. 1989. Characteristics of 

bald eagle nest sites in Oregon. Journal of 

Wildlife Management. 53: 148–159. 

www.jstor.org/view/ (April 2008). 

Ash, A.N. 1997. Disappearance and return of 

plethodontid salamanders to clearcut plots in 

the southern Blue Ridge Mountains. 

Conservation Biology. 11: 983–989. 

www.blackwell-synergy.com/doi/ (April 

2008). 

Backlund, P.; Janetos, A.; Schimel, D.S.; Hatfield, J.; 

Ryan, M.; Archer, S.; Lettenmaier, D. 2008. 

Executive Summary. In: The effects of climate 

change on agriculture, land resources, water 

resources, and biodiversity. Washington, DC: 

U.S. Climate Change Science Program and the 

Subcommittee on Global Change Research. 362 

p. 

Baker, H.G. 1986. Patterns of plant invasion in 

North America. In: Mooney, H.A.; Drake, J.A., 

eds. Ecology of biological invasions of North 

America and Hawaii. Berlin, Germany: 

Springer-Verlag: 44–57. 

Baker, M.D.; Lacki, M.J. 1997. Short-term changes 

in bird communities in response to silvicultural 

prescriptions. Forest Ecology and 

Management. 96: 27–36. 

www.sciencedirect.com (April 2008). 

Baker, W.L.; Veblen, T.T.; Sherriff, R.L. 2007. Fire, 

fuels, and restoration of ponderosa pineDouglas-fir forests in the Rocky Mountains, 

USA. Journal of Biogeography. 34: 251–269. 

Barton, D.R.; Taylor, W.D.; Biette, R.M. 1985. 

Dimensions of riparian buffer strips required 

to maintain trout habitats in southern Ontario 

streams. North American Journal of Fisheries 

Management. 5: 364–378. 

Batzer, D. P.; Jackson, C.R.; Mosner, M. 2000. 

Influences of riparian logging on plants and 

invertebrates in small, depressional wetlands 

of Georgia, U.S.A. Hydrobiologia 441: 123–132. 

Baur, A.; Baur, B. 1990. Are roads barriers to 

dispersal of the land snail Arianta arbustorum? 

Canadian Journal of Zoology. 68: 613–617. 

Behnke, R.J. 2002. Trout and salmon of North 

America. New York, NY: The Free Press. 384 p. 

Bentz, J., ed. 2009. Bark beetle outbreaks in Western 

North America: causes and consequences. 

University of Utah Press. 42 p. 

Birdsey, R.; Pregitzer, K.; Lucier, A. 2006. Forest 

carbon management in the United States: 1600-

2100. Journal of Environmental Quality. 35: 

1461-1469. 
Roadless Area Conservation; National Forest System Lands in Colorado RDEIS

334—Chapter 5. References Cited

Bisson, P.A.; Quinn, T.P.; Reeves, G.H.; Gregory, 

S.V. 1992. Best management practices, 

cumulative effects, and long-term trends in fish 

abundance in Pacific Northwest river systems. 

In: Naiman, R.B., ed. Watershed management: 

balancing sustainability and environmental 

change. New York, NY: Springer-Verlag: 189–

232. 

Bormann, B.T.; Martin, J.R.; Wagner, F.H.; Wood, 

G.W.; Alegeria, J.; Cunningham, P.G.; Brookes, 

M.H.; Friesema, P.; Berg, J.; Henshaw, J.R. 1999. 

Adaptive management. In: Johnson, N.C.; 

Malk, A.J.; Szaro, R.C.; Sexton, W.C., eds. Vol. 

3, Ecological stewardship: a common reference 

for ecosystem management. Oxford, UK: 

Elsevier Science. 761 p. 

Brown, G.; Reed, P. 2000. Validation of a forest 

values typology for use in national forest 

planning. Forest Science. 46(2): 240–247. 

Brown, J.K.; Smith, J.K., eds. 2000. Wildland fire in 

ecosystems: effects of fire on flora. Gen. Tech. 

Rep. RMRS- 42, Vol. 2. Ogden, UT: U.S. 

Department of Agriculture, Forest Service, 

Rocky Mountain Research Station. 257 p.

Brown, T.C.; Hobbins, M.T.; Ramirez, J.A. 2005. 

The source of water supply in the United 

States. Discussion paper RMRS-RWU-4851. 

Fort Collins, CO: U.S. Department of 

Agriculture, Forest Service, Rocky Mountain 

Research Station. 57 p. 

Cain, R. 2008. Personal communication with Robert 

Cain. April, 2008.

Cappa, J.A.; Young, G.; Burnell, J.R.; Carroll, C.J.; 

Widmann, B. 2007. Colorado mineral and 

energy industry activities, 2006. Denver, CO: 

Colorado Department of Natural Resources, 

Geological Survey. 64 p. 

Carroll, C.J. 2005. Coal production, distribution, 

and electric generation map of Colorado. 

Information Series 71, Map 1. Denver, CO: 

Colorado Department of Natural Resources, 

Geological Survey. geosurvey.state.co.us/

(April 2008). 

Causey, J.D. 2007. Mining claim activity on federal 

land in the United States. U.S. Geological 

Survey Data Series 290, v. 1.1. Denver, CO: U.S. 

Department of the Interior, Geological Survey. 

pubs.usgs.gov/ds/2007/290/ (April 2008). 

Chamberlin, T.W.; Harr, R.D.; Everest, F.H. 1991. 

Timber harvesting, silviculture, and watershed 

processes. In: Meehan, W.R., ed. Influences of 

forest and rangeland management on 

salmonid fishes and their habitats. Special 

Publication 19. Bethesda, MD: American 

Fisheries Society: 181–205. 

Chavez, D.J. 2000. Invite, include, and involve: 

racial groups, ethnic groups, and leisure. In: 

Allison, M.T.; Schneider, I.E., eds. Diversity 

and the recreation profession: organizational 

perspectives. State College, PA: Venture 

Publishing: 179–191.

Chavez, D.J. 2005. Latinos and public lands in 

California. California Parks and Recreation. 

Spring 2005: 32–35.

Chen, J.; Franklin, J.F.; Lowe, J.S. 1996. Comparison 

of abiotic and structurally defined patch 

patterns in a hypothetical forest landscape. 

Conservation Biology. 10(3): 854–862. 

Chen, J.; Franklin J.F.; Spies, T.A. 1993. Contrasting 

microclimates among clearcut, edge, and 

interior of old growth Douglas-fir forest. 

Agricultural and Forest Methodology. 63: 219–

237. 

Chen, J.; Franklin, J.F.; Spies, T.A. 1995. Growingseason microclimatic gradients from clearcut 

edges into old growth Douglas-fir forest. 

Ecological Applications. 5(1): 74–86. 

www.jstor.org/view/ (April 2008). 

Cohen, J.D. 1995. Structure ignition assessment 

model (SIAM). In: Weise, David R.; Martin, 

Robert E., tech. coords. Proceedings of the 

Biswell symposium: fire issues and solutions in 

urban interface and wildland ecosystems, 1994 

February 15-17; Walnut Creek, CA. Gen. Tech. 

Rep. PSW- 158. Albany, CA: U.S. Department 

of Agriculture, Forest Service, Pacific 

Southwest Forest Experiment Station : 85–92. 

Colby, S. 2008. Personal communication with 

Stephen Colby. April 22, 2008. 

Cole, E.K.; Pope, M.D.; Anthony, R.G. 1997. Effects 

of roads management on movement and 

survival of Roosevelt elk. Journal of Wildlife 

Management. 61(4): 1115–1126. 
Roadless Area Conservation; National Forest System Lands in Colorado RDEIS

Chapter 5. References Cited—335

Cole, E.K.; Pope, M.D.; Anthony, R.G. 2004. 

Influence of road management on diurnal 

habitat use of Roosevelt elk. Northwest 

Science. 78(4): 313–321. www.jstor.org/view/

(April 2008). 

Colorado Department of Agriculture. 2001. 

Colorado‘s strategic plan to stop the spread of 

noxious weeds: a framework for state-wide 

coordinated and cost- effective action to protect 

agriculture and the environment. Lakewood, 

CO: Colorado Department of Agriculture. 23 p. 

Colorado Department of Local Affairs [DOLA], 

Division of Local Governments. 2009. Federal 

mineral lease and severance tax direct 

distribution report. Denver, CO: Financial 

Assistance Programs, Energy/Mineral Impact 

Fund. 

Colorado Department of Local Affairs [DOLA], 

Division of Property Taxation. 2007. Annual 

report, 2006. Denver, CO. 763 p. 

Colorado Department of Local Affairs [DOLA], 

Division of Property Taxation. 2008. Annual 

report, 2007. Denver, CO. 773 p. 

Colorado Department of Local Affairs [DOLA], 

Division of Property Taxation. 2009. Annual 

report, 2008. Denver, CO. 803 p. 

Colorado Department of Local Affairs [DOLA], 

Division of Property Taxation. 2010. Annual 

report, 2009. Denver, CO. 807 p. 

Colorado Department of Local Affairs [DOLA], 

Division of Property. 2008. Colorado assessed 

values manual, 1994–2007. Denver, CO. 

www.dola.state.co.us/dpt/publications (April 

2008).

Colorado Department of Local Affairs [DOLA], 

State Demography Office. 2006. Economic and 

population estimates and forecasts. Denver, 

CO. www.dlg.oem2.state.co.us/demog/

(April 2008)

Colorado Department of Local Affairs [DOLA], 

State Demography Office. 2007. Annual 2007 

demography meeting, Colorado population 

forecast update. Denver, CO. 

www.dola.colorado.gov/dlg/demog/ (March 

2008).

Colorado Department of Local Affairs [DOLA], 

State Demography Office. 2008. Economic and 

population estimates and forecasts. Denver, 

CO. www.dola.colorado.gov/dlg/demog/

(November 2009).

Colorado Department of Local Affairs [DOLA], 

State Demography Office. 2010. Colorado 

demographic trends, January 2010. Denver, 

CO. 

www.dola.colorado.gov/dlg/demog/prese

ntations.html (September 2010). 

Colorado Department of Natural Resources [DNR], 

Geological Survey. 2007. Colorado coal fact 

sheet, 2006. Denver, CO. 

http://geosurvey.state.co.us/portals/0/2007

%20Coal%20fact%20sheet.pdf (April 2008).

Colorado Department of Natural Resources [DNR], 

Division of Wildlife. 2006. Colorado‘s 

comprehensive wildlife conservation strategy 

and wildlife action plans. Denver, CO. 339 p. 

Colorado Department of Natural Resources [DNR], 

Oil and Gas Conservation Commission. 2009. 

Monthly production and sales by county, gas 

and oil sold, CY 2008 prices. Denver, CO. 

www.cogcc.state.co.us database inquiry

(December 2009). 

Colorado Department of Public Health and 

Environment [CDPHE], Water Quality Control 

Division. 2004. Source water assessment 

methodology for surface water sources and 

ground water sources under the direct 

influence of surface water. Denver, CO. 27 p.

Colorado Department of Public Health and 

Environment [CDPHE], Water Quality Control 

Division. 2006. Regulation #93 (5 CCR 1002-93) 

section 303(d) list water quality limited 

segments requiring TMDLs. Denver, CO.

Colorado Department of Public Health and 

Environment [CDPHE], Water Quality Control 

Division. 2005. 2005 supplement to the 2000 

Colorado nonpoint source management 

program. Denver, CO. 80 p. 

www.cdphe.state.co.us/wq/nps/index.html

(April 2008).

Colorado Department of Public Health and 

Environment [CDPHE], Water Quality 

Control Division. 2008a. Status of Water 

Quality in Colorado – 2008 update to the 

2002, 2004 and 2006 305(b) Reports. Denver, 

CO: Colorado Department of Public Health 
Roadless Area Conservation; National Forest System Lands in Colorado RDEIS

336—Chapter 5. References Cited

and Environment, Water Quality Control 

Division. 142 pp.

Colorado Department of Public Health and 

Environment [CDPHE], Water Quality 

Control Division. 2008b. Regulation #93 (5 

CCR 1002-93) Section 303(d) list water 

quality limited segments requiring TMDLs. 

Denver, CO: Colorado Department of Public 

Health and Environment, Water Quality 

Control Commission 20p.

Colorado Department of Public Health and 

Environment [CDPHE], Water Quality 

Control Division. 2010. Regulation #93 (5 

CCR 1002-93) Section 303(d) list water 

quality limited segments requiring TMDLs. 

Denver, CO: Colorado Department of Public 

Health and Environment, Water Quality 

Control Commission 61 p.

Colorado Division of Reclamation, Mining and 

Safety. 2008 and 2009. Monthly Coal Detail 

Report, February 26, 2008, and February 24, 

2010. mining.state.co.us/Reports/Coal

(April 2008 and June 2010). 

Colorado Office of the Governor. 2007. State 

petition for roadless rulemaking. 

www.fs.fed.us/emc/roadless. (April 2008).

Cordell, H.K.; Tarrant, M.A.; McDonald, B.L.; 

Bergstrom, J.C. 1999a. How the public views 

wilderness: more results from the USA survey 

on recreation and the environment. 

International Journal of Wilderness. 4(3): 28–31. 

www.srs.fs.usda.gov/pubs/ja/ja_cordell001.p

df (October 2010). 

Cordell, H.K.; McDonald, B.L.; Teasley, R.J.; 

Bergstrom, J.C.; Martin, J.; Bason, J.; 

Leeworthy, V.R. 1999b. Outdoor recreation in 

American life: a national assessment of 

demand and supply trend. Champaign, IL: 

Sagamore Press: 219–322. 

www.treesearch.fs.fed.us/pubs/20814

(October 2010). 

Cordell, K.H.; Bergstrom, J.C.; Betz, C.J.; Green, 

G.T. 2004. Dominant socioeconomic forces 

shaping the future of the United States. In: 

Manfredo, M.J.; Vaske, J.J.; Bruyere, B.L.; Field, 

D.R.; Brown, P.J., eds. Society and natural 

resources, a summary of knowledge. 

University Park, PA: International Association 

for Society and Natural Resources: 349–361. 

Cordell, K.H.; Overdevest, C. 2001. Footprints on 

the land: an assessment of demographic trends 

and the future of natural lands in the United 

States. Champaign, IL: Sagamore Publishing. 

309 p. 

Council on Environmental Quality [CEQ]. 1997. 

Environmental justice, guidance under the 

National Environmental Policy Act. 

Washington, DC. 

www.whitehouse.gov/CEQ/ (March 2008).

Covington, W.W.; Moore, M.M. 1994. 

Southwestern ponderosa pine forest structure 

changes since Euro-American settlement. 

Journal of Forestry. 9: 39–47. 

Dahl, T.E. 1990. Wetland losses in the United States 

1780s to 1980s. Washington, DC: U.S. 

Department of the Interior (USDI), Fish and 

Wildlife Service. 22 p.

Dahl, T.E; Johnson, C.E; Frayer, W.E. 1991. Status 

and trends of wetlands in the conterminus 

United States, mid-1970s to mid-1980s. 

Washington, DC: U.S. Department of the 

Interior (USDI), Fish and Wildlife Service. 22 p.

Davies, P.E.; Nelson, M. 1994. Relationships 

between riparian buffer widths and the effects 

of logging on stream habitat, invertebrate 

community composition and fish abundance. 

Australian Journal of Marine and Freshwater 

Research. 45: 1289–1305.

DeMaynadier, P.G.; Hunter, M.L., Jr. 1998. Effects 

of silvicultural edges on the distribution and 

abundance of amphibians in Maine. 

Conservation Biology. 12: 340-352. 

www.blackwellsynergy.com/doi/pdf/ (April 

2008).

DeMaynadier, P.G.; Hunter, M.L., Jr. 1999. Forest 

canopy closure and juvenile emigration by 

pool-breeding amphibians in Maine. Journal of 

Wildlife Management. 63: 441–450. 

Driver, B.L.; Brown, P.J.; Peterson, G.L. 1991. 

Benefits of leisure. State College, PA: Venture 

Publishing. 483 p.

Dube, S.; Plamondon, A.P.; Rothwell, R.L. 1995. 

Watering up after clear-cutting on forested

wetlands on the St. Lawrence lowland. Water 

Resources Research. 31: 1741–1750.
Roadless Area Conservation; National Forest System Lands in Colorado RDEIS

Chapter 5. References Cited—337

Elliot, W.J. 2000. Roads and other corridors. In: 

Dissmeyer, G.E., ed. Drinking water from 

forests and grasslands: a synthesis of the 

scientific literature. Gen. Tech. Rep. SRS-039. 

Asheville, NC: U.S. Department of Agriculture, 

Forest Service, Southern Research Station. 246 

p.

Elliot, W.J.; Foltz, R.B.; Luce, C.H.; Koler, T.E. 1996. 

Computer-aided risk analysis in road 

decommissioning. In: McDonald, J.J.; Stribling, 

J.B.; Neville, L.R.; Leopold, D.J., eds. 

Proceedings of the AWRA annual symposium 

on watershed restoration management: 

physical, chemical, and biological 

considerations; Syracuse, NY. Herndon, VA: 

American Water Resources Association: 341–

350. 

Elliot, W.J.; Hall, D.E. 1997. Water erosion 

prediction project (WEPP) forest applications. 

Gen. Tech. Rep. INT-365. Ogden, UT: U.S. 

Department of Agriculture, Forest Service, 

Intermountain Region. 11 p.

Fernandez, C. 1993. The choice of nesting cliffs by 

golden eagles (Aquila chrysaestos): the influence 

of accessibility and disturbance by humans. 

Alauda. 61: 105–110.

Findlay, C.S.; Bourdages, J. 2000. Response time of 

wetland biodiversity to road construction on 

adjacent lands. Conservation Biology. 14(1): 

86–94. 

Finney, M.A.; Cohen, J.D. 2003. Expectation and 

evaluation of fuel management objectives. 

Proceedings RMRS-P-29 2003. Fort Collins, 

CO: U.S. Department of Agriculture, Forest 

Service, Rocky Mountain Research Station. 475 

p. 

Flather, C.H.; Brady, S.J.; Knowles, M.S. 1999. 

Wildlife resource trends in the United States: a 

technical document supporting the 2000 

United States Department of Agriculture 

Forest Service RPA assessment. Gen. Tech. 

Rep. RMRS- 33. Fort Collins, CO: U.S. 

Department of Agriculture, Forest Service, 

Rocky Mountain Research Station. 79 p. 

www.fs.fed.us/rm/pubs/rmrs_gtr033.pdf

(October 2007).

Forman, F.T.T.; Sperling, D.; Bissonette, J.A.; 

Clevenger, A.P.; Cutshall, C.D.; Dale, V.H.; 

Fahrig, L.; France, R.; Goldman, C.R.; Heanue, 

K.; Jones, J.A.; Swanson, F.J.; Turrentine, T.; 

Winter, T.C. 2003. Road ecology: science and 

solutions. Washington, DC: Island Press: 113–

134.

Franklin, B. 2008. Telephone call between Andrew 

Kratz (R2 Regional Office) and Ben Franklin 

(Utah Natural Heritage Program, Salt Lake 

City, UT) on March 25, 2008. 

Freddy, D.J. 1986. Responses of adult mule deer to 

human harassment during winter. In: Comer, 

R.D.; Baumann, T.G.; Davis, P.; Monarch, J.W.; 

Todd, J.; VanGytenbeek, S.; Wills, D.; 

Woodling, J., eds. Proceedings II: Issues and 

technology in the management of impacted 

western wildlife. Boulder, CO: Thorne 

Ecological Institute: 286.

Freddy, D.J.; Bronaugh, W.M.; Fowler, M.C. 1986. 

Responses of mule deer to disturbance by 

persons afoot and snowmobiles. Wildlife 

Society Bulletin. 14(1): 63–68.

Fulé, P.Z.; Covington, W.W.; Moore, M.M. 1997. 

Determining reference conditions for 

ecosystem management of southwestern 

ponderosa pine forests. Ecological 

Applications. 7: 895–908. 

Furniss, R.L.; Carolin, V.M. 1977. Western forest 

insects. Misc. Publication No. 1339. 

Washington, DC: U.S. Department of 

Agriculture, Forest Service: 353–361.

Furniss, M.J.; Roeloffs, T.D.; Yee, C.S. 1991. Road 

construction and maintenance. In: Meehan, 

W.R., ed. Influences of forest and rangeland 

management on salmonid fishes and their 

habitats. Special Publication 19. Bethesda, MD: 

American Fisheries Society: 297–323.

Gaines, W.L.; Lyons, A.L.; Lehmkuhl, J.F.; Raedeke, 

K.J. 2005. Landscape evaluation of female black 

bear habitat effectiveness and capability in the 

Northern Cascades, Washington. Biological 

Conservation. 125(4): 411–425. 

www.fs.fed.us/pnw/pubs/journals/pnw_200

5_gaines001.pdf (October 2007).

Garman, G.C.; Moring, J.R. 1994. Diet and annual 

production of two boreal river fishes following 

clear-cut logging. Environmental Biology of 

Fishes. 36: 301–311.
Roadless Area Conservation; National Forest System Lands in Colorado RDEIS

338—Chapter 5. References Cited

Gibbs, J.P. 1998. Amphibian movements in 

response to forest edges, roads, and 

streambeds in southern New England. Journal 

of Wildlife Management. 62: 584–589. 

www.jstor.org/view/ (October 2007).

Graham, R.T.; Jain, T.B.; Loseke, M. 2009. Fuel 

treatments, fire suppression, and their 

interaction with wildfire and its impacts: the 

Warm Lake experience during the Cascade 

Complex of wildfires in central Idaho, 2007. 

Gen. Tech. Rep. RMRS- 229. Fort Collins, CO: 

U.S. Department of Agriculture, Forest Service, 

Rocky Mountain Research Station. 36 p. 

Gucinski, H.; Furniss, R.R.; Ziemer, M.J.; Brookes, 

M.H., eds. 2000. Forest roads –a synthesis of 

scientific information. Washington, DC: U.S. 

Department of Agriculture, Forest Service. 

117p. 

Hansen, A.; Neilson, R.; Dale, V.; Flather, C.; 

Iverson, L.; Currie, D.; Shafer, S.; Cook, R.; 

Bartlein, P. 2001. Global changes in forests: 

responses of species, communities, and 

biomes. Bioscience. 51(9): 765–779.

Harris, L.F.; Johnson, S. 2004. The consequences of 

habitat fragmentation for plant–pollinator 

mutualisms. International Journal of Tropical 

Insect Science. 24: 29–43.

Hartman, G.F., Scrivener, J.C.; Miles, M.J. 1996. 

Impacts of logging in Carnation Creek, a highenergy coastal stream in British Columbia, and 

their implications for restoring fish habitat. 

Canadian Journal of Fisheries and Aquatic 

Sciences. 53 (Supplement 1): 237–251.

Hayes, S.G.; Leptich, D.J.; Zager, P. 2002. Proximate 

factors affecting male elk hunting mortality in 

northern Idaho. Journal of Wildlife 

Management. 66(2): 491–499.

Hayes, J.P.; Weikel, J.M.; Huso, M.M.P. 2003. 

Response of birds to thinning young Douglasfir forests. Ecological Applications. 13: 1222-

1232.

Helms, J.A. 1998. The dictionary of forestry. 

Bethesda, MD: Society of American Foresters. 

210 p.

Hiebert, R.D.; Stubbendieck, J. 1993. Handbook for 

ranking exotic plants for management and 

control. Natural Resources Report 

NPS/NRMWRO/NRR-93/08. Denver, CO: 

U.S. Department of Interior, National Park 

Service, Natural Resources Publication Office. 

Holm, M. 2009. Leasable energy minerals – natural 

gas, oil, and geothermal resources. Preliminary 

final unpublished manuscript on file at the U.S. 

Department of Agriculture, Forest Service, 

Rocky Mountain Region (Golden, Colorado).

Holtby, L.B. 1988. Effects of logging on stream 

temperatures in Carnation Creek, British 

Columbia, and associated impacts on the coho 

salmon (Oncorhynchus kisutch). Canadian 

Journal of Fisheries and Aquatic Sciences. 45: 

502–515.

Hubbard, M. 2008. Telephone call between 

Andrew Kratz (R2 Regional Office) and Mike 

Hubbard (Manti-La Sal NF, Supervisor‘s 

Office, Price, UT) on March 26, 2008. 

Huckaby, L.S. 2009. Personal communication. 

November, 2009.

Hutto, R.L.; Gallo, S.M. 2006. The effects of postfire 

salvage logging on cavity-nesting birds. 

Condor. 108: 817–831. 

www.dbs.umt.edu/research_labs/huttolab/

(April 2008).

Ingelfinger, F.; Anderson, S. 2004. Passerine 

response to roads associated with natural gas 

extraction in a sagebrush steppe habitat. 

Western North American Naturalist. 64(3): 

385–395.

Inouye, D. 2008. Effects of climate change on 

phenology, frost damage, and floral 

abundance of montane wildflowers. Ecology. 

89(2): 353–362.

Intergovernmental Panel on Climate Change 

[IPCC]. 2007. Climate change 2007: Summary 

for policymakers in: impacts, adaptation and 

vulnerability. Cambridge, UK 7-22.

Jimerson, T.M.; D.W. Jones. 2000. Ecological and 

watershed implications of the Megram fire. 

Fire Conference 2000: The First Congress on 

Fire Ecology, Prevention and Management. 

www.fs.fed.us/fire/fireuse/success/R5/meag

ramfire.pdf (January 22, 2010). 
Roadless Area Conservation; National Forest System Lands in Colorado RDEIS

Chapter 5. References Cited—339

Joslin, G., and h.Youmans, coordinators. 1999. 

Effects of recreation on Rocky Mountain 

wildlife: A review for Montana. Committee on 

effects of recreation on wildlife, Montana 

Chapter of the Wildlife Society. 307pp.

Karlen, D.L.; Mausbach, M.J.; Doran, J.W.; Cline, 

R.G.; Harris, R.F.; Schuman, G.E. 1997. Soil 

quality: a concept, definition, and framework 

for evaluation. Soil Science Society of America 

Journal. 61: 4–10.

Kaufman, M.R.; Fornwalt, P.J.; Huckaby, L.S.; 

Stoker, J.M. 2001. Cheesman Lake – a historical 

ponderosa pine landscape guiding restoration 

in the South Platte watershed of the Colorado 

Front Range. In: Vance, R.K.; Edminster, C.B.; 

Covington, W.W.; Blake, J.A., eds. Ponderosa 

pine ecosystems restoration and conservation: 

steps toward stewardship. Proc. RMRS-P-22. 

Fort Collins, CO: U.S. Department of 

Agriculture, Forest Service, Rocky Mountain 

Research Station. 188 p.

Kaufman, M.R.; Regan, C.M.; Brown, P.M. 2000. 

Heterogeneity in ponderosa pine/Douglas-fir 

forests: age and size structure in unlogged and 

logged landscapes of central Colorado. 

Canadian Journal of Forest Research. 30: 698–

711.

Kedzierski, W.M.; Smock, L.A. 2001. Effects of 

logging on macroinvertebrate production in a 

sand-bottomed, low-gradient stream. 

Freshwater Biology. 46: 821–833.

Keeley, J.E.; Aplet, G.H.; Christensen, N.L.; Conard, 

S.C.; Johnson, E.A.; Omi, P.N.; Peterson, D.L.; 

Swetnam, T.W. 2009. Ecological foundations 

for fire management in North American forest 

and shrubland ecosystems. Gen. Tech. Rep. 

PNW- 779. Portland, OR: U.S. Department of 

Agriculture, Forest Service, Pacific Northwest 

Research Station. 92 p. 

Kleindorfer, P.R.; Kunreuther, H.C.; Schoemaker, 

P.J.H. 1993. Decisions sciences: an interactive 

perspective. New York, NY: Cambridge 

University Press. 470 p.

Lacey, J.R.; Marlow, C.B.; Lane, J.R. 1989. Influence 

of spotted knapweed on surface runoff and 

sediment yield. Weed Technology. 3(4): 627–

631.

Landres, P.; Boutcher, S.; Meriglian, L.; Barns, C.; 

Davis, D.; Hall, T.; Henry, S.; Hunter, B.; Janiga, 

P.; Laker, M.; McPherson, A.; Powell, D.S.; 

Rowan, M.; Sater, S. 2005. Monitoring selected 

conditions related to wilderness character: a 

national framework. Gen. Tech. Rep. RMRS151. Fort Collins, CO: U.S. Department of 

Agriculture, Forest Service, Rocky Mountain 

Research Station. 38 p.

Langowski, P.G. 2009. Hazardous fuel treatments 

and the draft Colorado roadless rule. 

Unpublished manuscript on file at the U.S. 

Department of Agriculture, Forest Service, 

Rocky Mountain Region. (Golden, Colorado)

Lee, D.C.; Sedell, J.R.; Rieman, B.R.; Thurow, 

R.F.; Williams, J.E.; [and others]. 1997. In: 

Quigley, T.M.; Arbelbide, S.J., tech. eds. An 

assessment of ecosystem components in the 

interior Columbia basin and portions of the 

Klamath and Great Basins: vol. 3, ch. 4. Gen. 

Tech. Rep. PNW- 405. Portland, OR: U.S. 

Department of Agriculture, Forest Service, 

Pacific Northwest Research Station: 1058–

1496. 

LeMaster, D.C.; Shao, G.; Donnay, J. 2007. 

Protecting front range forest watersheds from 

high-severity wildfires. 

www.frftp.org/docs/FINAL_Protecting_Front

_Range_Watersheds_081407.pdf (January 22, 

2010).

Leukering, T.; Carter, M.F.; Panjabi, A.; Faulkner, 

D.; Levad, R. 2000. Monitoring Colorado‘s 

birds: the plan for count-based monitoring. 

Brighton, CO: Rocky Mountain Bird 

Observatory.

Lienert, J. 2004. Habitat fragmentation effects on 

fitness of plant populations – a review. Journal 

for Nature Conservation. 12: 53–72.

Lloyd Levy Consulting. 2004. Job generation in the 

Colorado mountain resort economy. 

Silverthorne, CO: prepared for the Northwest 

Colorado Council of Governments. 

Loeb, S.C.; Waldrop, T.A.; Leput, D.W. 2002. Effects 

of forest thinning and prescribed burning on 

bat activity in the Piedmont of South Carolina. 

Bat Research News. 43(4): 164. 
Roadless Area Conservation; National Forest System Lands in Colorado RDEIS

340—Chapter 5. References Cited

Loeffler, C., ed. 2001. Conservation plan and 

agreement for the management and recovery 

of the southern Rocky Mountain population of 

the boreal toad (Bufo boreas boreas). Denver, CO: 

Boreal Toad Recovery Team for the Colorado 

Division of Wildlife. 76 p. + appendices. 

Lyon, A.G.; Anderson, S.H. 2003. Potential gas 

development impacts on sage grouse nest 

initiation and movement. Wildlife Society 

Bulletin. 31(2): 486–491.

Lyon, L.J. 1979. Influences of logging and weather 

on elk distribution in western Montana. 

Research Paper INT- 236. Ogden, UT: U.S. 

Forest Service, Intermountain Forest and 

Range Experiment Station. 11pp. 

Lyon, L.J. 1983. Road density models describing 

habitat effectiveness of elk. Journal of Forestry 

81: 592-595.

Lyon, L.J.; Brown, J.K.; Huff, M.H. 2008. Fire 

regimes. In: The Forest Encyclopedia Network.

Encyclopedia Identification: p. 150. 

www.forestencyclopedia.net (April 2008). 

Marsh, D.M.; Beckman, N.G. 2004. Effects of forest 

roads on the abundance and activity of 

terrestrial salamanders. Ecological 

Applications. 14(6): 1882–1891.

Marsh, D.M.; Milam, G.S.; Gorham, N.P.; Beckman, 

N.G. 2005. Forest roads as partial barriers to 

terrestrial salamander movement. 

Conservation Biology. 19(6): 2004-2008. 

Marshal, J.P.; Bleich, V.C.; Krausman, P.R.; Reed, 

M.L.; Andrew, N.G.; Bueich, V.C. 2006. Factors 

affecting habitat use and distribution of desert 

mule deer in an arid environment. Wildlife 

Society Bulletin. 34(3): 609–619. 

www.bioone.org/archive/ (April 2008).

Mazerolle, M.J.; Huot, M.; Gravel, M. 2005. 

Behavior of amphibians on the road in 

response to car traffic. Herpetologica. 61(4): 

380-388. 

MacDonald L.H.; Stednick J.D. 2003. Forests and 

water: a state-of-the-art review for Colorado. 

Fort Collins, CO: Colorado Water Resources 

Research Institute, Colorado State University. 

65 p. 

McDonald, L.A.; Bender, H.W.; Hurley, E.; 

Donnelly, S.; Taylor, D. 2007. Oil and gas 

economic impact analysis. Golden, CO: 

prepared by B.A. Hamilton for the Colorado 

Energy Research Institute. 95 p. 

cerimines.org/CERIOil&Gas.pdf (October 

2010).

McGregor, M.D.; Amman, G.D; Schmitz, R.F.; 

Oakes, R.D. 1987. Partial cutting lodgepole 

pine stands to reduce losses to the mountain 

pine beetle. Canadian Journal of Forest 

Research. 17: 1234–1239. 

McIntosh, B.A., Sedell, J.R.; Smith, J.E.; Wissmar, 

R.C.; Clarke, S.E.; Reeves, G.H.; Brown, L.A. 

1994. Historical changes in fish habitat for 

select river basins of eastern Oregon and 

Washington. Northwest Science. 68: 36–53.

Millar, C.; Stephenson, N.; Stephens, S. 2007. 

Climate change and forests of the future: 

managing in the face of uncertainty. Ecological 

Applications. 17(8): 2145–2151.

Miller, C. 2010. Regulatory impact analysis and 

cost-benefit analysis. Unpublished manuscript 

on file at the U.S. Department of Agriculture, 

Forest Service, Rocky Mountain Region, 

(Golden, Colorado). 

Minnesota IMPLAN Group, Inc. [MIG]. 2008. 

Social accounting and impact analysis 

software, version 2. Stillwater, MN.

Mitchell, M.S.; Powell, R.A. 2003. Response of black 

bears to forest management in the southern 

Appalachian Mountains. Journal of Wildlife 

Management. 67(4): 692-705. 

www.jstor.org/view/ (October 2007).

Morrison, G.M., Revitt, D.M.; Ellis, J.B. 1995a. The 

gully pot as a biochemical reactor. Water 

Science and Technology. 31: 229–236.

Morrison, J.R.; de Vergie, W.J.; Alldredge, A.W.; 

Byrne, A.E.; Andree, W.W. 1995b. The effects 

of ski area expansion on elk. Wildlife Society 

Bulletin. 23(3): 481–489.

Mowat, G. 2006. Winter habitat associations of 

American martens (Martes americana) in 

interior wet belt forests. Wildlife Biology. 12(1): 

51–61.

National Mining Association. 2009. U.S. coal 

production by state, region, and method of 

mining - 2008. Washington, DC. 

www.nma.org/pdf/c_production_method.pd

f (May 2010). 
Roadless Area Conservation; National Forest System Lands in Colorado RDEIS

Chapter 5. References Cited—341

National Ski Areas Association. 2009. Comments 

on the Colorado Roadless Rulemaking Notice 

of Intent. Unpublished report. Available in 

NOI comment database. Letter #2362. 3 p.

National Wildfire Coordinating Group (NWCG). 

2005. Glossary of Wildland Fire Terminology. 

www.nwcg.gov (January 2010).

Negron, J.F.; Popp, J.B. 2004. Probability of 

ponderosa pine infestation by mountain pine 

beetle in the Colorado Front Range. Forest 

Ecology and Management. 191: 17–27.

Norling, B.S.; Anderson, S.H.; Hubert, W.A. 1992. 

Roost sites used by sandhill crane staging 

along the Platte River, Nebraska. Great Basin 

Naturalist. 52: 253–261.

Noss, R.F.; Cooperrider, A.Y. 1994. Saving nature‘s 

legacy: protecting and restoring biodiversity. 

Washington, DC: Island Press. 416 p.

Olson, B.E. 1997. Impacts of noxious weeds on 

ecologic and economic systems. In: Sheley, 

R.L.; Petroff, J.K., eds. Biology and 

management of noxious rangeland weeds. 

Corvallis, OR: Oregon State University Press: 

4–18.

Ortega, Y.K.; Capen, D.E. 2002. Roads as edges: 

Effects on birds in forested landscapes. Forest 

Science. 48(2): 381–390.

Oxley, D.J.; Fenton, M.B.; Carmody, G.R. 1974. The 

effects of roads on populations of small 

mammals. Journal of Applied Ecology. 25: 

1073–1087.

Parendes, L.A; Jones, J.A. 2000. Role of light and 

availability and dispersal in exotic plant 

invasion along roads and streams in the H.J. 

Andrews Experimental Forest, Oregon. 

Conservation Biology. 14(1): 64–75.

Partners in Flight. 2007. Physiographic areas plans. 

www.blm.gov/widlife/pifplans.htm (April 

2008).

Patriquin, K.J.; Barclay, R.M.R. 2003. Foraging by 

bats in cleared, thinned and unharvested 

boreal forest. Journal of Applied Ecology. 40(4): 

646–657. 

Perison, D.; Phelps,J.; Pavel, C.; Kellison, R. 1997. 

The effects of timber harvest in a South 

Carolina blackwater bottomland. Forest 

Ecology and Management. 90: 171–185.

Peterson, G.L.; Driver, B.L.; Gregory, R. 1988. 

Amenity resource valuation: integrating 

economics with other disciplines. State College, 

PA: Venture Publishing, Inc. 260 p. 

Petranka, J.W.; Eldridge, M.E.; Haley, K.E. 1993. 

Effects of timber harvesting on southern 

Appalachian salamanders. Conservation 

Biology. 7: 363–370.

Rahel, F.J. 2000. Homogenization of fish faunas 

across the United States. Science. 288: 854–856.

Reed, R.A.; Johnson-Barnard, J.; Baker, W.L. 1996. 

Contribution of roads to forest fragmentation 

in the Rocky Mountains. Conservation Biology. 

10(4): 1098–1106.

Reh, W.; Seitz, A. 1990. The influence of land use on 

the genetic structure of populations of the 

common frog (Rana temporaria). Biological 

Conservation. 54: 239–249. 

Reynolds, R.T.; Graham, R.T.; Reiser, M.H. 1992. 

Management recommendations for the 

northern goshawk in the southwestern United 

States. Gen. Tech. Rep. RM-217. Fort Collins, 

CO: U.S. Department of Agriculture, Forest 

Service, Rocky Mountain Forest and Range 

Experiment Station. 90 p. 

www.fs.fed.us/rm/pubs_rm/rm_gtr217.pdf

(April 2008).

Rice, R.M; Lewis, J. 1991. Estimating erosion risks 

associated with logging and forest roads in 

northwestern California. Journal of the 

American Water Resources Association. 27(5): 

809–818.

Rico, A; Kindlmann, P.; Sedlacek, F. 2007. Road 

crossing in bank voles and yellow-necked 

mice. Acta Theriologica. 52(1): 85–94.

Robinson, S.K; Thompson, F.R., III; Donavan, T.M.; 

Whitehead, D.R.; Faaborg, J. 1995. Regional 

forest fragmentation and the nesting success of 

migratory birds. Science. 267: 1987-1990. 

www.ncrs.fs.fed.us/pubs/jrnl/1995/ (April 

2008).

Robitaille, J.F.; Aubry, K. 2000. Occurrence and 

activity of American martens (Martes 

americana) in relation to roads and other routes. 

Acta Theriologica. 45(1): 137–143.
Roadless Area Conservation; National Forest System Lands in Colorado RDEIS

342—Chapter 5. References Cited

Romero, J.; Seesholtz, D.; Schaefers, J.; Shon, F.; 

Vasievich, M.; Woodward, A. 2001. Identifying 

potentially underserved communities, 

southern San Luis Valley pilot project. U.S. 

Department of Agriculture, Forest Service, 

Civil Rights Department. 

Rosenberg, K.V.; Lowe, J.D.; Dhondt, A.A. 1999. 

Effects of forest fragmentation on breeding 

tanagers: a continental perspective. 

Conservation Biology. 13: 568–583. 

www.blackwell-synergy.com/doi/pdf/ (April 

2008).

Rowland, M.M; Wisdom, M.J.; Johnson, B.K.; 

Penninger, M.A. 2004. Effects of roads on elk: 

Implications for management in forested 

ecosystems. In: Wisdom, M. J., tech. ed. 

Transactions of the North American wildlife 

and natural resources conference. Lawrence, 

KS: Alliance Communications Group: 491-508. 

RRC Associates. 2006. Kottke national estimate of 

ski season 2005 – 2006, final report. Boulder, 

CO. 72 p.

Ruediger, B.; Claar, J.; Gniadek, S.; Holt, B.; Lewis, 

L.; Mighton, S.; Nancy, B.; Patton, G.; Rinaldi, 

T.; Trick, J.; Vandehey, A.; Wahl, F.; Warren, 

N.; Wenger, D.; Williamson, A. 2000. Canada 

lynx conservation assessment and strategy 

(LCAS). Publication R1-00-53. Missoula, MT: 

U.S. Department of Agriculture, Forest Service; 

US Department of the Interior (USDI) Fish and 

Wildlife Service, Bureau of Land Management, 

and National Park Service. 142 p. 

www.fs.fed.us/r1/planning/lynx/reports/lca

s/pdf. (April 2008).

Ruggiero, L.F.; Aubry, K.B.; Buskirk, S.W.; Lyon, 

J.L.; Zielinski, W.J., eds. 1994. The scientific 

basis for conserving forest carnivores: 

American marten, fisher, lynx, and wolverine 

in the western United States. Gen. Tech. Rep. 

RM-254. Fort Collins, CO: U.S. Department of 

Agriculture, Forest Service, Rocky Mountain 

Research Station. 17 p

Schmid, J.M.; Frye, R.H. 1977. Spruce beetle in the 

Rockies. General Technical Report RM-49. Fort 

Collins, CO: U.S. Department of Agriculture, 

Forest Service, Rocky Mountain Forest and 

Range Experiment Station. 38 p. 

Schmid, J.M.; Mata, S.A. 1992. Stand density and 

mountain pine beetle caused tree mortality in 

ponderosa pine stands. Research Note RM-515. 

Fort Collins, CO: U.S. Department of 

Agriculture, Forest Service, Rocky Mountain 

Forest and Range Experiment Station. 4 p. 

Scrivener, J.C.; Brownlee, M.J. 1989. Effects of forest 

harvesting on spawning gravel and incubation 

survival of chum (Oncorhynchus keta) and coho 

salmon (O. kisutch) in Carnation Creek, British 

Columbia. Canadian Journal of Fisheries and 

Aquatic Sciences. 46: 681–696. 

Sheley, R.; Manoukian, K.; Marks, G. 1995. 

Preventing noxious weed invasions. Montana 

State University Technical Bulletin T199517 AG 

8/2002. Bozeman, MT: Montana State 

University Extension Service. 3 p.

Sheley, R.; Petroff, J. 1999. Biology and 

management of noxious rangeland weeds. 

Corvallis, OR: Oregon State University Press: 1, 

5, 69–71. 

Shine, R; Lemaster, M.; Wall, M.; Langkilde, T.; 

Mason, R. 2004. Why did the snake cross the 

road? Effects of roads on movement and 

location of mates by garter snakes. 

Conservation Ecology. 9(1): 1-13. 

www.ecologyandsociety.org/ (April 2008).

Smith , B. 2008. Telephone call between Andrew 

Kratz (R2 Regional Office) and Barbara Smith 

(Manti-La Sal NF, Moab Ranger District, Moab, 

UT) on March 26, 2008. 

Smith , J.K., ed. 2000. Wildland fire in ecosystems: 

effects of fire on fauna. Gen. Tech. Rep. RMRS42, vol.1. Ogden, UT: U.S. Department of 

Agriculture, Forest Service, Rocky Mountain 

Research Station. 83 p. 

www.fs.fed.us/rm/pubs/ (April 2008).

Spackman, S.; Jennings, B.; Coles, J.; Dawson, C.; 

Minton, M.; Kratz, A.; Spurrier, C. 1997. 

Colorado rare plant field guide. Fort Collins, 

CO: prepared for the Bureau of Land 

Management, the U.S. Forest Service, and the 

U.S. Fish and Wildlife Service by the Colorado 

Natural Heritage Program. 

www.cnhp.colostate.edu/rareplants/ (April 

2008). 
Roadless Area Conservation; National Forest System Lands in Colorado RDEIS

Chapter 5. References Cited—343

Stednick, J.D. 2000. Timber management. In: 

Dissmeyer, G.E., ed. Drinking water from 

forests and grasslands: A synthesis of the 

scientific literature. Gen. Tech. Rep. SRS-39. 

Asheville, NC: U.S. Department of Agriculture, 

Forest Service, Southern Research Station: 103–

119. 

Stein, B.A.; Kutner, L.A.; Adams, J.S. 2000. Precious 

heritage: the status of biodiversity in the 

United States. A joint project of The Nature 

Conservancy and the Association for 

Biodiversity Information. New York, NY: 

Oxford University Press. 399 p.

Stein, S.M; Alig, R .J.; White, E.M.; Comas, S.J.; 

Carr, M.; Eley, M.; Elverum, K.; O‘Donnell, M.; 

Theobald, D.M.; Cordell, K.; Haber, J.; 

Beauvais, T.W. 2007. National forests on the 

edge: development pressures on America‘s 

national forests and grasslands. Gen. Tech. 

Rep. PNW-728. Portland, OR: U.S. Department 

of Agriculture, Forest Service, Pacific 

Northwest Research Station. 26 p. 

Stephens, S.L.; Moghaddas, J.J.; Edminster, C.; 

Fiedler, C.E.; Haase, S.; Harrington, M.; Keeley, 

J.E.; Knapp, E.E.; McIver, J.D.; Metlen, K.; 

Skinner, C.N.; Youngblood, A. 2009. Fire 

treatment effects on vegetation structure, fuels, 

and potential fire severity in western U.S. 

forests. Ecological Applications. 19(2): 305-320. 

Sublette, J.E.; Hatch, M.D.; Sublette, M. 1990. The 

fishes of New Mexico. Albuquerque, NM: 

University of New Mexico Press. 393 p. 

Swihart, R.K.; Slade, N.A. 1984. Road crossing in 

Sigmodon hispidus and Microtus ochrogaster. 

Journal of Mammalogy. 65(2): 357–360.

Theobald, D.M; Romme, W.H. 2007. Expansion of 

the U.S. wildland-urban interface. Landscape 

Urban Planning. 83: 340–354.

Thomas, J.W.; Black, H., Jr.; Scherzinger, R.J.; 

Pederson, R.T. 1979. Deer and elk. In: Thomas, 

J.W., ed. Wildlife habitats in managed forests –

the Blue Mountains of Oregon and 

Washington. Forest Service Agricultural 

Handbook Number 553. Washington, DC: U.S. 

Department of Agriculture, Forest Service: 

104–127.

Trombulak S.C.; Frissell, C.A. 2000. Review of 

ecological effects of roads on terrestrial and 

aquatic communities. Conservation Biology. 

14(1): 18-30. www.blackwellsynergy.com/doi/pdf/ (April 2008).

U.S. Department of Agriculture [USDA], Forest 

Service. 1974. National forest landscape 

management, vol. 2, chapter 1, the visual 

management system: recreation, heritage, and 

wilderness resources. Agricultural Handbook 

number 462. Washington, DC. 45 p.

U.S. Department of Agriculture [USDA], Forest 

Service. 1995a. Challenges facing resource 

management and research. No. 2. Seattle, WA: 

Pacific Northwest Research Station, People and 

Natural Resource RD&A Program, Seattle 

Forestry Sciences Lab. 1 p.

U.S. Department of Agriculture [USDA], Forest 

Service. 1995b. Landscape aesthetics, a 

handbook for scenery management. 

Agricultural Handbook number 701. 

Washington, DC. 47 p.

U.S. Department of Agriculture [USDA], Forest 

Service. 1999. Heritage – it‘s about time? A 

national strategy. Washington, DC: Recreation, 

Heritage and Wilderness Resource 

Management. 

www.fs.fed.us/recreation/programs/heritage

/heritage_strategy (April 2008).

U.S. Department of Agriculture [USDA], Forest 

Service. 2000a. Roadless area conservation final 

environmental impact statement, volume 1, 

FEIS, volume 2, maps; and volume 3, agency 

responses to public comments. 

U.S. Department of Agriculture [USDA], Forest 

Service. 2000b. Biological evaluation specialist 

report for Forest Service roadless area 

conservation FEIS, November 2000 (revised). 

Unpublished report. 90 p. 

www.roadless.fs.fed.us/documents/feis/spec

rep/Final_biological_evaluation.pdf (April 

2008).

U.S. Department of Agriculture [USDA], Forest 

Service. 2003a. Backcountry road maintenance 

and weed management. 7100 Engineering, July 

2003. 0371-2811-MTDC. Washington, DC. 26 p.
Roadless Area Conservation; National Forest System Lands in Colorado RDEIS

344—Chapter 5. References Cited

U.S. Department of Agriculture [USDA], Forest 

Service. 2003b. Kruger, L.E., tech. ed. 

Understanding community-forest relations. 

Gen. Tech. Rep. PNW- 566. Seattle, WA: Pacific 

Northwest Research Station. 162 p.

U.S. Department of Agriculture [USDA], Forest 

Service. 2004a. National Strategy and 

implementation plan for invasive species 

management. Washington, D.C. 24 p. 

www.invasivespecies.gov (April 2009)

U.S. Department of Agriculture [USDA], Forest 

Service. 2004b. National forest visitor use 

monitoring program national project results 

January 2000 through September 2003. 

Washington, DC: Washington Office. 10 p. 

www.fs.fed.us/recreation/programs/nvum/

national_report_final_draft.pdf (March 2010).

U.S. Department of Agriculture [USDA], Forest 

Service. 2007. An assessment of fuel treatment 

effects on fire behavior, suppression 

effectiveness, and structure ignition on the 

Angora fire, R5-TP-025. Manuscript on file at 

the Pacific Southwest Regional Office. Valejo, 

CA. 

U.S. Department of Agriculture [USDA], Forest 

Service. 2010. A Profile of Development and 

the Wildland-Urban Interface (WUI). Draft 

report in Economic Profile System-Human 

Dimensions Toolkit (EPS-HDT). 2010. 

Washington, DC. 5 p. 

U.S. Department of Agriculture [USDA]. 2008. Fuel 

treatment effectiveness report. Gunbarrel

wildland fire use. Manuscript on file at the 

Shoshone National Forest, Cody, WY.

U.S. Department of Agriculture [USDA], Grand 

Mesa-Uncompahgre-Gunnison National 

Forests. 2006. Coal Resource and 

Development Potential. Internal analysis 

report prepared for forest plan revision for 

the Grand Mesa-Uncompahgre-Gunnison 

National Forests. Available at National 

Forest Supervisor‘s Office, Grand Junction, 

CO.

U.S. Department of Agriculture [USDA], Global 

Change Program Office. 2001. Forests: the 

potential consequences of climate variability 

and change. A report to the national forest 

assessment group for the U.S. Global Change 

Research Program. Washington, DC. 8 p. 

www.usgcrp.gov/usgcrp/library/nationalass

essment/forests/ (April 2008).

U.S. Department of Agriculture [USDA], Roadless 

Area Conservation National Advisory 

Committee [RACNAC]. 2007a. Advice of the 

RACNAC on Colorado‘s petition per the 

Administrative Procedures Act to amend the 

Forest Service Roadless Area Conservation 

Rule of 2001. www.fs.fed.us/emc/roadless

(April 2008).

U.S. Department of Agriculture [USDA], Roadless 

Area Conservation National Advisory 

Committee [RACNAC]. 2007b. Acceptance 

letter for Colorado‘s petition, from 

Undersecretary Mark Rey, Office of the 

Secretary, to Governor Bill Ritter, Jr. 

Washington, DC. 

www.fs.fed.us/emc/roadless (April 2008).

U.S. Department of Agriculture [USDA], Office of 

Inspector General, Southeast Region. 1996. 

Forest Service management of hazardous 

material at active and abandoned mines. Audit 

report No. 08601-1-A. Washington, DC. 46 p.

U.S. Department of Agriculture [USDA], Forest 

Service; University of California. 2006. What is 

genetic erosion and how can it be managed? 

In: Rogers, D., ed. Why we care about genetics, 

vol. 11. Davis, CA: Forest Service National 

Forest Genetics Laboratory and University of 

California Genetics Resources Conservation 

Program. 

www.grcp.ucdavis.edu/projects/geneticfactsh

eets/ (April 2008). 

U.S. Department of Agriculture [USDA]; U.S. 

Department of the Interior [USDI]. 2001. 

National fire plan: managing the impacts of 

wildfires on communities and the 

environment. Misc pub MP-1584. 2002.
Roadless Area Conservation; National Forest System Lands in Colorado RDEIS

Chapter 5. References Cited—345

U.S. Department of Agriculture [USDA]; U.S. 

Department of the Interior [USDI]. 2006. A 

collaborative approach for reducing wildfire 

risks to communities and the environment: 10-

year comprehensive strategy implementation 

plan (revision of the 2002 report). 

www.forestsandrangelands.gov/plan (April 

2008).

U.S. Department of Agriculture [USDA]; U.S. 

Department of the Interior [USDI]; 2007. An 

assessment of fuel treatments on three large 

2007 Pacific Northwest fires. Manuscript on file 

at the Pacific Northwest Regional Office, 

Portland, OR. 

U.S. Department of Commerce [USDOC], Census 

Bureau. 2000. 2000 census of population, social 

and economic characteristics of Colorado. 

Washington, DC. www.census.gov (March 

2008). 

U.S. Department of Energy [USDOE], Geothermal 

Technology Program. 2007a. GeoPowering the 

West. Washington, DC. 

www.nrel.gov/docs/fy07osti/41082.pdf 

(February 2007). 

U.S. Department of Energy [USDOE], Energy 

Information Administration. 2007b. Annual 

energy outlook 2007. Washington, DC. 

www.eia.doe.gov/oiaf/ (April 2008).

U.S. Department of Energy [USDOE], Energy 

Information Administration. 2008. Annual 

energy outlook 2008 (revised early release). 

Washington, DC. www.eia.doe.gov/oiaf/aeo/

(March 2008).

U.S. Department of Energy [USDOE], Energy 

Information Administration. 2009. Annual 

energy outlook 2009. Washington, DC. 

http://www.eia.doe.gov/ (November 2009). 

U.S. Department of the Interior [USDI], Bureau of 

Land Management. 2005. Letter responding to 

GMUG National Forest coal resource and 

development potential report. In: 

Administrative record. Montrose, CO: 

Uncompahgre Field Office.

U.S. Department of Interior [USDI], Bureau of Land 

Management; U.S. Department of Agriculture 

[USDA], Forest Service. 2008. Final 

programmatic Environmental Impact 

Statement for geothermal leasing in the 

western United States. FES 08-44.

U.S. Department of Interior [USDI], Bureau of Land 

Management. 2009. Personal communication 

between D. Dyer, mining engineer, and L. 

Mattson, Grand Mesa-UncompahgreGunnison National Forests. November, 2009.

U.S. Department of the Interior [USDI], Bureau of 

Mines. 1984. Minerals yearbook area reports, 

volume 3. Washington D.C. 

digicoll.library.wisc.edu/cgi-bin/EcoNatRes

(April 2008).

U.S. Department of the Interior [USDI], Fish and 

Wildlife Service. 1993. Endangered and 

threatened wildlife and plants: the plant 

Eutrema penlandii (Penland alpine fen mustard) 

determined to be a threatened species. Federal 

Register. 58(143): 40539–40547.

U.S. Department of Interior [USDI], Fish and 

Wildlife Service. 1998. Greenback cutthroat 

trout recovery plan. Denver, CO. 69 p.

www.ecos.fws.gov/docs/recovery_plans/199

8 (April 2008).

U.S. Department of the Interior [USDI], Fish and 

Wildlife Service. 2010. Endangered and 

threatened wildlife and plants: Listing 

Ipomopsis polyantha (Pagosa skyrocket) as 

endangered throughout its range, and listing 

Penstemon debilis (parachute beardtongue) and 

Phacelia submutica (DeBeque Phacelia) as 

threatened throughout their range. Federal 

Register. 75(120): 35721–35745.

U.S. Department of Interior [USDI], Fish and 

Wildlife Service, and U.S. Department of 

Commerce [USDOC], U.S. Census Bureau. 

2008. 2006 national survey of fishing, hunting, 

and wildlife-associated recreation: Colorado. 

FHW-06-CO. 91 p.

U.S. Department of Interior [USDI], Geological 

Survey. 2007. The national map LANDFIRE: 

LANDFIRE national fire regime group layer. 

gisdata.usgs.net/website/landfire/ (October 

2009).

U.S. Department of the Interior [USDI], U.S. 

Geological Survey. 2001. Eastern Energy Team; 

John Tully, comp. Coal fields of the United 

States: national atlas of the United States. 

Reston, VsA.
Roadless Area Conservation; National Forest System Lands in Colorado RDEIS

346—Chapter 5. References Cited

Veblen, T.T.; Kitzberger, T.; Donnegan, J. 2000. 

Climatic and human influences on fire regimes 

in ponderosa pine forests in the Colorado 

Front Range. Ecological Applications. 10: 1178–

1195.

Vestjens, W.J.M. 1973. Wildlife mortality on a road 

in New South Wales. Emu. 73: 107-112.

Vincent, R. E.; Miller, W.H. 1969. Altitudinal 

distribution of brown trout and other fishes in 

a head water tributary of the South Platte 

River, Colorado. Ecology. 50(3): 464–466.

Waters, T.F. 1995. Sediment in streams: sources, 

biological effects, and control. Sources of 

sediment, monograph number 7. Bethesda, 

MD: American Fisheries Society. 251 p.

Wesolowski, T.; Czeszczewik, D.; Rowinski, P. 

2005. Effects of forest management on the 

three-toed woodpecker (Picoides tridactylus) 

distribution in the Bialowieza Forest (NE 

Portland): conservation implications. Acta 

Ornithologica. 40(1): 53–60. 

Wiens, J.D.; Noon, B.R.; Reynolds, R.T. 2006. Postfledgling survival of northern goshawks: the 

importance of prey abundance, weather, and 

dispersal. Ecological Applications. 16(1): 406-

418. www.fs.fed.us/rm/pubs_other/ (April 

2008).

Windell, J.T.; Williard, B.E.; Cooper, D.J.; Foster, 

S.Q.; Knud-Hansen, C.F.; Rink, L.P.; Kiladis, 

G.N. 1986. An ecological characterization of 

Rocky Mountain montane and subalpine 

wetlands. U.S. Fish and Wildlife Service 

Biological Report 86(11). National ecology 

center, Division of wildlife and contaminant 

research, Fish and Wildlife Service USDI. 298 

p.

Winters, D.S.; Bohn, B.; Cooper, D.; Eaglin, G.; 

Hammerlinck, J.; Hirsch, C.; Poff, N.L.; 

Quimby, C.; Rahel, F.; Rau, P.; Scaife, D.; 

Staley, D.; Wohl, E. 2004. Conceptual 

framework and protocols for conducting 

multiple scale aquatic, riparian and wetland 

ecological assessments. Fort Collins, CO: U.S.

Department of Agriculture, Forest Service, 

Rocky Mountain Region. 134 p.

Winters, D.S.; Staley, D.M. 2008. Aquatic, riparian 

and wetland ecosystem assessment, 

anthropogenic influence analysis results: White 

River National Forest. Internal document. 

Denver, CO: U.S. Department of Agriculture, 

Forest Service, Rocky Mountain Region. 42 p.

Wisdom, M.J.; Holthausen, R.S.; Wales, B.K.; 

Hargis, C.D.; Saab, V.A.; Lee, D.C.; Hann, W.J.; 

Rich, T.D.; Rowland, M.M.; Murphy, W.J.; 

Eames, M.R. 2000. Source habitats for

terrestrial vertebrates of focus in the interior 

Columbia basin: broad scale trends and 

management implications. Gen. Tech. Rep. 

PNW- 485. 3 vols. Portland, OR: U.S. 

Department of Agriculture, Forest Service, 

Pacific Northwest Research Station. 

www.fs.fed.us/pnw/pubs/gtr485/ (April 

2008).

Wohl, E.E. 2001. Virtual rivers. Lessons from the 

mountain rivers of the Colorado Front Range. 

New Haven, CT: Yale University Press. 210 p.

Worrall, J.J.; Egeland, L.; Eager, T.; Mask, R.A.; 

Johnson, E.W.; Kemp, P.A.; Shepperd, W.D. 

2008. Forest Ecology and Management. 255: 

686-69.
Roadless Area Conservation; National Forest System Lands in Colorado RDEIS

Index—347

INDEX

abandoned mines, 269, 270, 321

access (road access), 4, 10, 12, 14, 16, 30, 34, 39, 

43, 45, 54, 56, 59, 66, 70, 82, 84, 85, 88, 89, 95, 

96, 99, 111, 114, 117, 118, 120, 123, 124, 125, 

129, 130, 131, 132, 134, 147, 163, 175, 183, 200, 

201, 202, 204, 205, 208, 226, 228, 229, 230, 246, 

256, 258, 260, 261, 263, 264, 265, 267, 269, 276, 

277, 279, 280, 281, 282, 283, 284, 285, 286, 315

administratively designated areas, 26, 77, 245, 

250

air resource, 2, 25, 29, 57, 77, 92, 115, 148, 158, 

159, 160, 161, 203, 251, 278, 289

all terrain vehicle (ATV), 231

American Indians, 43, 45, 275, 329

aquatic, 21, 30, 73, 152, 153, 175, 177, 178, 179, 

180, 181, 182, 183, 184, 185, 186, 187, 188, 190, 

204, 207, 217, 318

Arapaho and Roosevelt National Forest, 5, 36, 

45, 49, 58, 152, 188, 197, 221, 232, 234, 235, 246, 

248, 249, 325, 326, 327

at-risk communities, 14, 15, 32, 53, 55, 64, 70, 81, 

95, 96, 105, 106, 108, 112, 113, 114, 116, 150, 

157, 223, 225, 228, 229, 282, 284, 306, 307, 310, 

311, 313, 314, 315, 316

best management practices, 99, 148, 154, 179, 

181, 183, 185, 186, 187, 188

biological diversity, 30, 98, 177, 190, 218, 219, 

246, 267, 277, 299

candidate species, 2, 30, 164, 166, 176, 177, 251

catchment, 15, 16, 33, 66, 70

Clean Water Act, 45, 50, 153, 154, 156, 269, 270, 

320

climate change, 64, 91, 94, 97, 155, 164, 173, 174, 

176, 190

coal, 4, 10, 16, 33, 34, 39, 44, 51, 55, 69, 84, 85, 86, 

100, 101, 117, 120, 121, 122, 123, 124, 125, 129, 

130, 131, 132, 133, 134, 135, 136, 147, 150, 154, 

157, 160, 161, 165, 169, 171, 173, 185, 186, 187, 

188, 189, 199, 204, 205, 207, 208, 209, 211, 212, 

215, 218, 219, 222, 223, 224, 227, 228, 239, 247, 

249, 252, 254, 268, 278, 279, 280, 282, 284, 285, 

286, 288, 290, 291, 292, 295, 300, 302, 315, 317, 

318, 319, 320, 322

Colorado Governor‘s roadless areas taskforce, 3, 

28, 29

Colorado roadless areas petition, 3, 5, 7, 8, 11, 28, 

29, 31, 34, 36, 37, 41, 51

common variety minerals, 117

Community Protection Zone (CPZ), 20, 32, 53, 

64, 70, 73, 95, 96, 106, 107, 108, 109, 111, 112, 

113, 114, 115, 150, 210, 223, 225, 227, 229, 239, 

244, 282, 283, 284, 285, 286, 307, 308, 309, 310, 

311, 312, 313, 314

community wildfire protection plans (CWPP), 

15, 53, 64, 279, 284, 306

Comprehensive Environmental Response, 

Compensation, and Liability Act (CERCLA), 

13, 45, 50, 67, 85, 269, 270

condition class, 32, 53, 64, 105, 108

congressionally designated areas, 2, 4, 5, 13, 26, 

28, 35, 45, 51, 62, 77, 79, 244, 255, 323

consultations, 8, 9, 37, 38, 165, 176, 256, 257, 258, 

320, 325

Continental Divide National Scenic Trail, 245

costs, 99, 114, 115, 118, 125, 204, 287, 291, 315, 

316

Council on Environmental Quality, 274

critical habitats, 176, 191, 206, 210, 214

cumulative, 97, 101, 146, 147, 160, 161, 173, 174, 

181, 188, 189, 216, 217, 218, 219, 240, 250, 255, 

265, 269, 279, 316

demographic, 201, 274, 276, 280, 286

developed recreation, 226, 228, 229, 230, 231, 236

dispersed recreation, 30, 46, 153, 226, 227, 228, 

229, 230, 251, 299

drinking water, 2, 3, 30, 34, 153, 251

ecological, 90, 93, 177, 178, 179, 181, 184, 205, 

221, 237, 246, 254, 255, 279

economic, 1, 27, 79, 90, 94, 95, 97, 111, 124, 131, 

133, 176, 178, 224, 228, 262, 265, 270, 273, 274, 

276, 280, 282, 285, 287, 288, 290, 291, 292, 293, 

294, 296, 299, 302, 306, 315, 317

ecosystem, 14, 15, 16, 20, 30, 32, 49, 53, 55, 64, 70, 

73, 81, 82, 94, 95, 96, 98, 100, 105, 106, 107, 111, 

112, 113, 114, 115, 148, 170, 203, 239, 252, 254, 

255, 267, 287, 299

electrical power line, 4, 16, 24, 33, 34, 44, 50, 55, 

71, 76, 81, 251, 252, 262, 263

emergency, 44, 56, 132, 156, 186, 246, 260, 261, 

269, 296

Endangered Species Act, 30, 164, 165, 166, 168, 

176, 191, 196, 320, 325

energy resources, 117, 126, 147, 286, 295, 299, 

302, 306, 315, 316, 317, 319
Roadless Area Conservation; National Forest System Lands in Colorado RDEIS

348—Index

environmental justice, 270, 274, 280

Environmental Protection Agency, 27, 57, 81, 

153, 158, 159, 327

federal highway projects, 13

fire hazard, 53, 58, 64, 70, 93, 97, 110, 157, 171, 

172, 181, 212, 279, 283, 286, 318

fire occurrence, 53, 64

fire regimes, 89, 90, 102, 105, 106, 107, 209, 216

fish, 3, 10, 29, 34, 39, 97, 164, 175, 176, 177, 178, 

180, 181, 182, 184, 186, 188, 189, 193, 227, 228, 

229, 267, 278, 288

fishing, 13, 30, 31, 46, 176, 181, 182, 183, 198, 226, 

227, 228, 229, 231, 258, 259

forest health, 20, 73, 90, 91, 93, 94, 95, 96, 97, 168, 

209, 216, 236, 315

forest plan, 1, 4, 5, 6, 7, 12, 13, 14, 16, 17, 18, 24, 

28, 31, 35, 36, 42, 43, 45, 48, 49, 50, 51, 52, 53, 

56, 57, 58, 59, 60, 62, 63, 64, 65, 66, 67, 68, 69, 

70, 71, 76, 79, 80, 86, 88, 95, 101, 112, 113, 114, 

115, 121, 122, 123, 125, 130, 131, 132, 133, 134, 

136, 138, 140, 142, 143, 146, 147, 150, 156, 158, 

170, 171, 172, 178, 185, 186, 187, 195, 202, 205, 

206, 208, 209, 210, 211, 212, 213, 214, 215, 216, 

219, 221, 223, 224, 225, 228, 229, 230, 231, 233, 

234, 235, 237, 239, 240, 241, 242, 244, 245, 246, 

247, 248, 249, 250, 251, 252, 253, 255, 260, 262, 

263, 264, 265, 266, 280, 281, 282, 283, 284, 285, 

286, 316, 318

forest plan amendments, 17, 45, 57, 128, 242

forest plan revisions, 3, 14, 17, 18, 29, 42, 45, 49, 

52, 57, 58, 62, 121, 221, 253

fragmentation, 115, 173, 176, 177, 179, 199, 200, 

201, 202, 203, 204, 206, 211, 212, 214, 215, 217

fuels, 15, 18, 20, 22, 32, 53, 59, 64, 73, 75, 82, 91, 

94, 95, 96, 101, 102, 103, 104, 106, 107, 108, 110, 

111, 112, 113, 114, 115, 156, 157, 158, 168, 182, 

183, 188, 212, 227, 228, 229, 236, 243, 249, 268, 

279, 280, 283, 291, 307, 308, 310, 311, 313, 314, 

315, 316

geological resources, 30, 162, 237, 247, 321

geothermal, 117, 118, 127, 146, 147, 204, 259, 264, 

325

Grand Mesa, Uncompahgre, and Gunnison 

National Forests, 5, 36, 45, 49, 51, 52, 58, 180, 

186, 187, 188, 197, 214, 221, 232, 234, 235, 266, 

322, 326, 327

habitat, 2, 3, 10, 14, 15, 16, 18, 23, 30, 32, 33, 34, 

39, 49, 53, 56, 58, 59, 64, 66, 70, 75, 90, 93, 94, 

97, 98, 99, 102, 115, 123, 134, 164, 165, 166, 167, 

168, 169, 170, 173, 175, 176, 177, 178, 179, 180, 

181, 182, 183, 184, 185, 186, 187, 188, 190, 191, 

192, 193, 194, 195, 196, 197, 198, 199, 200, 

201, 202, 203, 204, 205, 206, 207, 208, 209, 210, 

211, 212, 213, 214, 215, 216, 217, 218, 219, 227, 

228, 229, 247, 249, 267, 279, 316, 317, 318, 323, 

324, 326

harvest, 1, 4, 5, 14, 28, 35, 49, 50, 51, 63, 90, 99, 

102, 160, 183, 184, 280, 282

hunting, 9, 13, 30, 31, 38, 46, 200, 201, 202, 226, 

227, 231, 256, 257, 258, 259, 276

income, 22, 23, 74, 75, 274, 275, 276, 279, 287, 288, 

291, 292, 294, 295, 296, 299, 300, 306, 315, 316

insects and diseases, 20, 33, 64, 73, 82, 91, 93, 94, 

95, 96, 105, 107, 160, 243, 249

invasive species, 30, 97, 98, 99, 100, 101, 115, 177, 

185, 186, 199, 202, 203, 204, 209, 211, 212, 214, 

215, 217, 218

issues, 277

jobs, 288, 291, 292, 295, 296, 300, 306

land use authorizations, 12, 13, 44, 45, 232

leaseable minerals, 14

linear construction zone (LCZ), 4, 5, 16, 24, 25, 

33, 34, 35, 36, 41, 44, 54, 55, 56, 60, 70, 71, 76, 

77, 81, 88, 97, 100, 101, 148, 149, 150, 154, 155, 

156, 157, 158, 165, 169, 171, 172, 173, 176, 180, 

185, 186, 187, 204, 205, 212, 215, 251, 252, 261, 

262, 263, 264, 265

linear facility, 33, 99

livestock, 10, 39, 97, 99, 123, 149, 153, 154, 160, 

173, 181, 266, 267, 268, 269, 287, 323

locatable minerals, 43, 45, 67, 117, 119, 120, 129, 

146

management indicator species (MIS), 175, 178, 

179, 180, 185, 186, 187, 188, 189, 190, 195, 196, 

197, 199, 205, 208, 211, 215, 216

Manti-La Sal National Forest, 5, 36, 45, 49, 51, 52, 

58, 61, 137, 138, 139, 141, 142, 152, 177, 179, 

180, 189, 197, 214, 221, 241, 246, 247, 266, 326, 

327

migratory birds, 190, 198, 199, 205, 208, 212, 215, 

216

mining, 33, 43, 51, 55, 69, 82, 117, 119, 121, 122, 

123, 124, 125, 129, 130, 131, 132, 133, 134, 135, 

147, 149, 150, 153, 154, 157, 158, 175, 181, 188, 

204, 209, 221, 227, 229, 247, 249, 279, 282, 284, 

285, 288, 289, 291, 292, 295, 322

mitigation, 21, 22, 23, 25, 73, 74, 75, 77, 100, 105, 

148, 149, 155, 156, 157, 161, 168, 179, 181, 183, 

185, 186, 187, 188, 265, 269, 318

motorized, 2, 13, 16, 30, 33, 44, 46, 56, 66, 70, 99, 

134, 183, 186, 212, 226, 227, 230, 231, 232, 236, 

237, 243, 244, 245, 246, 249, 251, 255, 265, 267, 

268, 279, 281, 282, 283, 284, 285, 286

municipal water supply system, 4, 14, 15, 20, 32, 

34, 53, 55, 64, 73, 81, 112, 116, 223, 225, 283
Roadless Area Conservation; National Forest System Lands in Colorado RDEIS

Index—349

municipal watersheds, 102, 261, 282

National Environmental Policy Act (NEPA), 1, 5, 

9, 12, 18, 27, 35, 38, 42, 43, 45, 57, 58, 62, 66, 71, 

81, 120, 121, 130, 138, 140, 143, 155, 160, 210, 

233, 234, 265, 277, 316, 317, 319, 320, 322, 324

National Forest Management Act (NFMA), 12, 

43, 57, 62, 178, 317

National Forest System (NFS) lands, 1, 2, 3, 4, 5, 

8, 11, 12, 13, 14, 18, 28, 29, 31, 34, 35, 37, 41, 42, 

43, 44, 45, 49, 50, 51, 52, 54, 55, 59, 62, 63, 69, 

71, 79, 83, 85, 89, 97, 101, 116, 117, 118, 120, 

121, 127, 129, 140, 147, 151, 153, 154, 155, 162, 

166, 176, 177, 178, 181, 192, 202, 204, 205, 212, 

218, 220, 226, 230, 231, 232, 233, 235, 240, 256, 

257, 258, 259, 260, 261, 263, 264, 265, 267, 269, 

271, 278, 280, 281, 284, 286, 308, 312, 313, 318

native cutthroat trout, 15, 16, 33, 56, 66, 70, 177, 

186

North Fork coal mining area, 10, 16, 33, 39, 51, 

55, 69, 85, 100, 101, 131, 132, 133, 147, 150, 157, 

223, 224, 225

Notice of Intent, 278

off highway vehicle (OHV), 56, 154, 186, 200, 

221, 226

oil and gas, 10, 11, 16, 18, 24, 33, 39, 40, 50, 52, 55, 

57, 60, 68, 71, 76, 81, 84, 86, 87, 100, 119, 120, 

125, 126, 128, 131, 136, 137, 138, 139, 140, 141, 

142, 143, 144, 146, 147, 148, 154, 156, 159, 160, 

168, 181, 187, 188, 189, 204, 205, 206, 207, 208, 

210, 211, 212, 214, 222, 223, 224, 227, 240, 

249, 251, 252, 254, 259, 260, 261, 262, 272, 279, 

282, 285, 291, 295, 299, 300, 302, 321

outfitters and guides, 231, 299

paleontological resources, 162, 163, 247, 321

Pike and San Isabel National Forests, 5, 36, 45, 

49, 58, 152, 176, 188, 195, 197, 221, 232, 235, 

247, 326, 327

pollutant, 153, 159

pollution, 115, 154, 158, 159, 160

pre-existing water court decree, 15, 16, 33, 54, 55, 

69, 71, 157, 264

prescribed burning, 46, 93, 99, 102, 105, 111, 112, 

114, 159, 160, 181, 190, 202, 206, 210, 268

primitive, 2, 3, 11, 24, 30, 34, 40, 76, 99, 231, 232, 

236, 237, 239, 245, 251, 252, 279

public health and safety, 13, 15, 50, 54, 55, 67, 82, 

85, 202

public involvement, 8, 37, 45, 48, 52, 287

public meetings, 8, 28, 37, 277

purpose of and need for action, 9, 19, 38, 41, 42, 

43, 58, 260

rangelands, 102, 267

reasonably foreseeable, 160, 173, 174, 212, 216

Recreation Opportunity Spectrum, 230, 249

reference landscapes, 2, 254, 255, 324

research natural areas (RNA), 245, 246

reserved and outstanding rights, 12, 13, 15, 17, 

31, 43, 45, 50, 54, 58, 59, 67, 247, 249, 250

right-of-way, 55, 56, 57, 69, 318

Rio Grande National Forest, 5, 36, 45, 48, 49, 51, 

52, 58, 61, 144, 151, 152, 153, 177, 179, 180, 189, 

195, 196, 197, 213, 221, 232, 241, 246, 248, 249, 

266, 272, 274, 275, 292, 298, 326, 327

riparian, 134, 178, 181, 182, 183, 184, 185, 186, 

187, 188, 189, 192, 193, 194, 197, 206, 210, 213, 

266, 267

road decommissioning, 56, 66, 99, 123, 132, 134

road density, 17, 59, 155, 196, 227

roaded natural, 230, 236

roadless area boundaries, 1, 4, 5, 13, 17, 29, 34, 

62, 119, 219, 230

roadless area characteristics, 3, 4, 9, 10, 14, 17, 19, 

25, 29, 32, 34, 35, 38, 39, 41, 42, 47, 49, 50, 51, 

53, 56, 58, 63, 64, 77, 80, 81, 148, 186, 222, 223, 

224, 225, 227, 232, 251, 252, 253, 265, 281, 282, 

283, 284, 285, 286, 287, 315, 316

Roadless Area Conservation National Advisory 

Committee, 3, 29

Routt National Forests, 5, 36, 45, 48, 49, 51, 52, 

58, 61, 121, 122, 123, 124, 131, 133, 145, 152, 

177, 179, 180, 189, 193, 194, 195, 196, 197, 221, 

232, 234, 235, 241, 246, 248, 249, 266, 272, 275, 

291, 292, 298, 326, 327

rulemaking, 3, 5, 10, 13, 19, 23, 24, 27, 28, 29, 31, 

35, 39, 45, 48, 50, 61, 75, 76, 135, 148, 165, 174, 

176, 227, 258, 276, 277, 320

sacred sites, 3, 30, 251, 256, 258, 259

saleable minerals, 117, 127, 128, 146, 321

San Juan National Forest, 5, 9, 36, 38, 44, 45, 48, 

49, 51, 52, 58, 61, 119, 121, 122, 123, 124, 126, 

131, 133, 137, 138, 139, 140, 141, 142, 143, 146, 

151, 152, 153, 163, 177, 179, 180, 188, 195, 196, 

197, 213, 214, 221, 232, 235, 238, 241, 243, 246, 

248, 249, 266, 272, 276, 292, 298, 299, 326, 327, 

330

scenic resources, 2, 11, 23, 30, 40, 75, 97, 98, 189, 

220, 221, 222, 223, 224, 225, 230, 237, 239, 244, 

245, 247, 251, 281, 289, 318, 323

scoping, 9, 18, 38, 42

Secretary of Agriculture, 1, 3, 7, 8, 9, 13, 28, 29, 

36, 37, 38, 45, 50, 51, 245

sediment, 105, 148, 152, 153, 154, 155, 157, 182, 

183, 184, 207

semi-primitive, 2, 3, 11, 24, 30, 34, 40, 76, 227, 

228, 230, 232, 236, 245, 249, 251, 318
Roadless Area Conservation; National Forest System Lands in Colorado RDEIS

350—Index

sensitive species, 2, 14, 15, 30, 49, 53, 64, 94, 164, 

165, 166, 167, 168, 170, 171, 172, 173, 174, 175, 

176, 177, 178, 179, 180, 185, 186, 187, 188, 190, 

191, 192, 199, 205, 207, 211, 212, 214, 215, 216, 

219, 247, 251

ski areas, 4, 5, 23, 34, 35, 51, 52, 62, 66, 75, 80, 85, 

128, 149, 181, 188, 205, 208, 209, 210, 211, 212, 

221, 222, 223, 224, 225, 227, 230, 231, 232, 233, 

234, 235, 236, 254, 283, 285, 299, 322

social, 1, 23, 27, 30, 75, 79, 265, 270, 274, 276, 280, 

282, 283, 284, 288, 290, 294, 306, 317

soil resource, 2, 11, 22, 29, 40, 75, 97, 98, 99, 104, 

109, 148, 149, 150, 151, 154, 155, 156, 160, 161, 

164, 168, 170, 183, 203, 251, 267, 278, 317, 318

special interest areas (SIA), 162, 245, 247, 249

special use authorizations, 24, 76, 231, 260, 264, 

322

streams, 11, 40, 98, 151, 152, 153, 154, 155, 157, 

175, 176, 177, 179, 180, 181, 182, 183, 184, 185, 

188, 207, 211, 214

substantially altered areas, 4, 5, 14, 18, 24, 29, 35, 

47, 50, 51, 52, 60, 62, 63, 66, 76, 80, 83, 94, 95, 

96, 100, 104, 112, 113, 115, 128, 130, 131, 132, 

133, 149, 150, 156, 157, 186, 205, 208, 219, 222, 

223, 224, 225, 227, 228, 229, 251, 252, 254, 255, 

258, 259, 269, 280, 281, 282, 283, 285

sustainability, 177, 203, 267

temporary roads, 15, 17, 32, 33, 44, 50, 51, 52, 54, 

55, 56, 57, 59, 66, 67, 68, 69, 70, 82, 84, 85, 86, 

87, 95, 96, 110, 113, 115, 125, 128, 130, 132, 134, 

150, 154, 155, 168, 183, 200, 206, 209, 210, 212, 

216, 222, 223, 224, 228, 229, 252, 253, 261, 270, 

283, 285, 317, 318

terrestrial species (or habitat), 23, 30, 75, 98, 109, 

190, 191, 195, 199, 200, 202, 203, 205, 212, 217, 

219, 318, 326

threatened and endangered (T&E) species, 102, 

164, 165, 169, 170, 173, 174, 175, 176, 177, 180, 

183, 185, 186, 187, 188, 190, 191, 192, 196, 197, 

199, 205, 206, 212, 214, 219

timber, 1, 4, 5, 14, 18, 19, 28, 31, 35, 42, 49, 50, 51, 

59, 63, 89, 90, 94, 97, 99, 102, 111, 117, 160, 161, 

175, 197, 202, 215, 221, 243, 249, 278, 279, 280, 

282, 284, 287, 288, 299

tourism, 22, 75, 231, 256, 258, 259, 278, 281, 287, 

288, 293

traditional cultural properties, 3, 30, 256, 257, 

258, 259

trails, 63, 82, 99, 226, 230, 236, 243, 245, 281, 284

travel management, 10, 19, 39, 42, 226, 281, 282, 

283, 284, 285

unavoidable adverse effects, 318

unroaded areas, 4, 35, 58, 149, 150, 156, 271

upper tier, 4, 5, 6, 7, 11, 12, 14, 15, 18, 19, 20, 23, 

25, 31, 32, 34, 36, 41, 42, 43, 52, 53, 54, 55, 60, 

61, 62, 63, 64, 67, 68, 69, 70, 73, 75, 76, 77, 80, 

82, 95, 96, 100, 101, 112, 113, 114, 115, 134, 143, 

150, 151, 157, 158, 171, 172, 186, 188, 208, 215, 

216, 219, 223, 225, 228, 229, 230, 234, 236, 

240, 242, 252, 253, 254, 255, 259, 261, 262, 263, 

264, 281, 282, 283, 285, 286, 315, 316

water influence zone, 15, 16, 33, 56, 66, 70

water quality, 11, 40, 98, 148, 151, 153, 154, 155, 

156, 157, 158, 161, 178, 181, 183, 184

water supply, 10, 32, 39, 53, 55, 64, 70, 73, 105, 

153, 156, 157, 158, 288

water yield, 153, 154, 155, 161, 184, 287

watershed, 15, 16, 33, 66, 70, 98, 103, 104, 114, 

148, 150, 151, 154, 155, 161, 180, 185, 261, 317

wetlands, 30, 181, 182, 183, 184, 185, 187, 188, 

193, 197, 207, 211, 214

White River National Forest, 5, 36, 45, 48, 49, 51, 

52, 58, 61, 83, 86, 91, 108, 119, 121, 122, 123, 

124, 126, 131, 133, 137, 138, 139, 140, 141, 142, 

143, 145, 152, 163, 177, 179, 180, 188, 195, 197, 

198, 207, 209, 211, 213, 214, 215, 221, 232, 234, 

235, 241, 246, 248, 249, 266, 299, 326, 327

Wild and Scenic Rivers, 2

wilderness, 2, 4, 5, 10, 13, 17, 26, 28, 30, 31, 35, 39, 

41, 48, 49, 58, 62, 78, 79, 97, 144, 151, 153, 158, 

177, 198, 200, 201, 215, 218, 224, 226, 237, 238, 

239, 240, 241, 242, 243, 244, 253, 255, 267, 279, 

281, 283, 284, 285, 320, 323, 328, 329, 331

wildfire, 4, 10, 14, 15, 32, 34, 39, 53, 55, 64, 70, 91, 

93, 94, 95, 96, 97, 102, 103, 104, 105, 108, 111, 

112, 113, 115, 116, 149, 150, 151, 168, 172, 184, 

190, 202, 204, 205, 212, 223, 225, 280, 282, 284, 

287, 296, 306, 307, 308, 316

wildfire hazards, 14, 15, 32, 53, 55, 70, 94, 95, 96, 

112, 172, 205, 223, 225, 306, 316

wildland-urban interface (WUI), 32, 102, 104, 

106, 108, 109, 110, 111, 115, 255, 279, 282, 283, 

284, 286, 307

wildlife, 3, 10, 11, 18, 29, 30, 32, 34, 39, 40, 58, 59, 

90, 98, 99, 115, 123, 134, 153, 162, 164, 173, 190, 

192, 198, 199, 200, 201, 202, 203, 204, 205, 206, 

208, 209, 213, 215, 217, 218, 219, 224, 226, 227, 

228, 229, 249, 267, 268, 278, 279, 299, 316, 317, 

325, 326

wildlife habitat linkages, 209