Roadless Area Conservation; National Forest System Lands in Idaho DEIS Proposed Action (Idaho Roadless Rule) 

Summary 1 

SUMMARY

Proposed Action (Idaho Roadless Rule) 

The Forest Service is proposing to promulgate a State-specific rule in response to the 

Idaho State Petition presented by Governor James Risch on November 29 and 30, 

2006, to the Roadless Area Conservation National Advisory Committee (RACNAC). 

The proposed Idaho Roadless Rule would designate a system of lands called Idaho 

Roadless Areas and establish five management area themes for individual roadless 

areas: Wild Land Recreation; Primitive; Special Areas of Historic and Tribal 

Significance; Backcountry/Restoration; and General Forest, Rangeland, and 

Grassland. The proposed themes span a continuum (fig. S-1) that includes at one end 

a restrictive approach emphasizing passive management and natural restoration 

approaches, and on the other end, active management designed to sustain forest, 

rangeland, and grassland management. This continuum accounts for stewardship of 

the uniqueness of each individual roadless area’s landscape and the quality of 

roadless characteristics in that area. 

Figure S-1. Idaho Roadless Rule continuum 
Proposed Action (Idaho Roadless Rule) Roadless Area Conservation; National Forest System Lands in Idaho DEIS 

2 Summary 

Allocation to a specific theme is not intended to mandate or direct the Forest Service to 

propose or implement any action; rather, the themes provide an array of permitted and 

prohibited activities regarding: 

• Timber cutting, sale, or removal; 

• Road construction and reconstruction; 

• Mineral activities. 

The Proposed Action also provides for the ability to accommodate necessary corrections 

and modifications in the future. A full description of the Proposed Action may be found 

in the alternatives section. 
Roadless Area Conservation; National Forest System Lands in Idaho DEIS Purpose of and Need for Action 

Summary 3 

Purpose of and Need for Action 

The purpose of the proposed Idaho Roadless Rule is to respond to the State’s petition to 

provide State-specific direction for the conservation and management of inventoried 

roadless areas within the State of Idaho. The proposed Idaho Roadless Rule integrates 

local management concerns with the national objectives for protecting roadless area 

values and characteristics. 

The management direction is based on individual roadless characteristics for lands (1) 

containing outstanding or unique features, where there is minimal or no evidence of 

human use; (2) containing culturally significant areas; (3) containing general roadless 

characteristics, where human uses may or may not be more apparent; and (4) 

displaying high levels of human use, while: 

• Protecting communities, homes, and property from the risk of severe wildfire or 

other risks existing on adjacent Federal lands; 

• Protecting forests from the negative effects of severe wildfire and insect and disease 

outbreaks; or 

• Protecting access to property, by ensuring that States, Tribes, and citizens owning 

property within roadless areas have access to that property as required by existing 

laws. 

The Secretary, aware of the long, unresolved debates over the management of 

inventoried roadless areas in the absence of wilderness legislation for the State of Idaho, 

considered the State’s Petition, the advice and recommendations of the RACNAC, and 

associated public comments; the Secretary determined that there is a need to consider 

regulatory direction for roadless area management specific to the State of Idaho. 
Public Involvement Roadless Area Conservation; National Forest System Lands in Idaho DEIS 

4 Summary 

Public Involvement 

A notice of intent to prepare an EIS on “Roadless Area Conservation; National Forest 

System Lands in Idaho” was published in the Federal Register, April 10, 2007 (68, FR 

17816). About 38,000 comments were received, of which 32,000 were form letters1, while 

the remaining letters consisted of original responses or form letters with additional 

original text. These comments were evaluated and summarized in a report called 

Summary of Public Comments, which is provided in the Scoping section of the project 

record. The summary analyzes the public’s responses specific to the Proposed Action, 

identifying significant concerns and issues. 

 

1 Form letters are five or more letters that contain identical text but are submitted by different people. 
Roadless Area Conservation; National Forest System Lands in Idaho DEIS Issues 

Summary 5 

Issues 

The Forest Service identified as significant issues those resources that could directly or 

indirectly be affected as a result of implementation of the Proposed Action. The Forest 

Service identified the following significant issues during scoping. These issues 

represent possible effects of implementing the proposed Idaho Roadless Rule: 

• Changes to roadless characteristics; 

• Ability to address forest health and fire ecology; 

• Ability to utilize minerals and energy resources; 

• Social factors; and 

• Economic factors. 
Alternatives Roadless Area Conservation; National Forest System Lands in Idaho DEIS 

6 Summary 

Alternatives 

This draft environmental impact statement (draft EIS) examines three alternatives 

establishing regulatory direction: 

1. Direction based on the 2001 Roadless Rule (2001 Roadless Rule); 

2. Direction based on existing forest plans (Existing Plans); 

3. Direction based on the Petition, as presented to the RACNAC (Idaho Roadless 

Rule). 

The Idaho Roadless Rule recommends Idaho Roadless Areas be managed within a 

spectrum of five management themes: Wild Land Recreation; Primitive; Special Areas 

of Historic and Tribal Significance; Backcountry/Restoration; and General Forest, 

Rangeland and Grassland. To aid in analyzing effects and to better compare 

alternatives, the management prescriptions in the 2001 Roadless Rule and Existing 

Plans were placed in a management theme that would be the closest equivalent. Table 

S-1 describes each theme’s management emphasis and the number of acres represented 

by that theme, by alternative. To account for all acreage identified as a roadless area, the 

table lists other forest plan special areas, which are not affected by this proposed rule. 

Table S-1. Number of acres represented by Idaho Roadless Rule themes and equivalent themes for the 2001 

Roadless Rule and Existing Plans 

Theme 

2001 

Roadless Rule Existing Plans 

Idaho Roadless 

Rule 

Wild Land Recreation. These lands would show little 

evidence of human-caused disturbance and natural 

conditions and processes would be predominant 

0 1,320,800 1,378,600 

Primitive. These lands would remain relatively 

undisturbed by human management activities while 

allowing for limited forest health activities including 

preserving biological strongholds for a variety of species 

and protecting ecological integrity. 

0 2,131,400 1,656,300 

Special Areas of Historic and Tribal Significance. 

These areas would remain relatively undisturbed by 

human management activities in order to maintain their 

unique Tribal or historic characteristics 

0 0 68,600 

Backcountry/Restoration. These areas would retain their 

undeveloped character, while providing a variety of 

recreation opportunities, and allowing for limited forest 

health activities, including preserving biological 

strongholds for a variety of species, and maintaining or 

restoring the characteristics of ecosystem and structure. 

9,304,200 4,244,500 5,246,100 

General Forest, Rangeland, and Grassland. These areas 

would provide a variety of goods and services as well as 

a broad range of recreational opportunities, and 

conservation of natural resources. 

0 1,262,400 609,500 

Other lands* 

Forest plan special areas ( appendix H, table H-9) 0 345,100 345,100 

Totals 9,304,200 9,304,200 9,304,200 

* The Idaho Roadless Rule would not apply to these other special areas. 
Roadless Area Conservation; National Forest System Lands in Idaho DEIS Alternatives 

Summary 7 

Each alternative addresses only management actions associated with timber cutting, 

road construction/reconstruction, or future discretionary mineral-related actions for 

saleable or leasable minerals, because these particular activities have been identified as 

having the greatest likelihood of altering roadless area values and characteristics. Road 

construction/reconstruction or timber cutting under any alternative would be designed 

based on applicable forest plan standards and guidelines (for example, protection of 

riparian areas or habitat needs for species). 

The following subsections generally describe each alternative. In-depth discussion on 

management direction can be found in chapter 2 of the draft EIS. 

ALTERNATIVE 1. THE 2001 ROADLESS RULE (NO ACTION)

2

This alternative presents a roadless area management regime based on the approach set 

out in the 2001 Roadless Rule (see 36 CFR, 294, subpart B [2004]; 66 Fed. Reg. 3244 [Jan. 

12, 2001]). The purpose of the 2001 Roadless Rule was to ensure that inventoried 

roadless areas sustain their values for this generation and for future generations. By 

sustaining these values, a continuous flow of benefits associated with healthy 

watersheds and ecosystems was expected. 

Timber cutting activities and road construction/reconstruction were identified as 

having the greatest likelihood of altering and fragmenting landscapes, and the greatest 

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

characteristics; therefore, these activities were prohibited, with certain exceptions in 

each roadless area. 

The rule allows for road construction or reconstruction in the case of reserved or 

outstanding rights, or as provided for by statute or treaty. This would include roads 

associated with locatable mineral activities pursuant to the General Mining Law of 1872. 

The 2001 Roadless Rule was the product of a national process and established 

management direction at the national level with limited focus on State or local issues. 

ALTERNATIVE 2. EXISTING PLANS

Management direction in this alternative represents a roadless area management 

regime based on each forest’s land and resource management plan (forest plan). Each 

forest’s plan is unique to its planning area; collectively the forest plans provide a broad 

range of management from wilderness to intensive management. Overall, as national 

forests have revised their forest plans, the trend has been to move more roadless areas 

into management prescriptions that conserve roadless characteristics. When developing 

or revising their forest plans, each forest or group of forests collaborates with the public 

 

2 As of the printing of this draft EIS, the 2001 Roadless Rule is in operation by court order and represents 

the legal status quo and operating management direction for these lands. In the absence of the 2001 

Roadless Rule, management would be governed by each forest’s land management plan. 
Alternatives Roadless Area Conservation; National Forest System Lands in Idaho DEIS 

8 Summary 

and interested parties to develop management direction for their roadless areas. 

Generally, forest plans allow or limit an array of activities in roadless areas. 

ALTERNATIVE 3. IDAHO ROADLESS RULE3 (PROPOSED ACTION) 

The Proposed Action represents a strategy for the conservation and management of 

Idaho Roadless Areas that takes into account State and local situations and unique 

resource management challenges, while it recognizes and integrates the national 

interest in maintaining roadless characteristics. 

Building from each forest’s existing or proposed forest plan4, the proposed Idaho 

Roadless Rule assigned individual roadless areas within five broad management 

themes: Wild Land Recreation; Special Areas of Historic or Tribal Significance; 

Primitive; Backcountry/Restoration; and General Forest, Rangeland, and Grassland. 

These themes span a continuum (fig. S-1) that includes at one end, a restrictive 

approach emphasizing passive management and natural restoration approaches, and 

on the other end, active management designed to accomplish sustainable protection of 

roadless characteristics. The continuum accounts for stewardship of the uniqueness of 

each individual roadless area’s landscape and the quality of roadless characteristics in 

that area. 

The proposed Idaho Roadless Rule would not apply to other special areas (referred to 

as “forest plan special areas” such as research natural areas; wild and scenic rivers 

(designated, eligible, and suitable); special interest areas; visual corridors; and the like 

(table S-1). These areas would be managed according to applicable current and future 

forest plan direction. These lands are included in the discussion for sake of 

completeness; however, the Proposed Action does not recommend management 

direction for these 345,100 acres. 

Allocation to a specific theme is not intended to mandate or direct the Forest Service to 

propose or implement any action; rather, the themes provide an array of permitted and 

prohibited activities related to timber cutting, sale, and removal; road 

construction/reconstruction; and discretionary mineral activities. 

As in the 2001 Roadless Rule, timber cutting and road construction/reconstruction are 

identified as the management activities having the greatest potential for altering 

landscapes and causing immediate changes to roadless values and characteristics; 

therefore, a continuum of prohibitions and permissions was proposed for each roadless 

area. 

 

3 The Idaho Roadless Rule includes clarifications made by Governor Risch at the November 29 and 30, 

2007, RACNAC meeting. 

4 Existing plans referred to here include the Boise, Caribou, Challis, Payette, Salmon, Sawtooth, Caribou, 

Wallow-Whitman. Proposed plans referred to here are the Clearwater, Idaho Panhandle, Kootenai, Nez 

Perce. 
Roadless Area Conservation; National Forest System Lands in Idaho DEIS Alternatives 

Summary 9 

The Proposed Action also establishes prohibitions and permissions for discretionary 

mineral activities because of potential effects on roadless characteristics. Further, the 

Proposed Action, like the 2001 Roadless Rule, allows for road 

construction/reconstruction in the case of reserved or outstanding rights, or as 

provided for by statute or treaty. This would include roads associated with locatable 

mineral activities pursuant to the General Mining Law of 1872. Finally, the Proposed 

Action provides additional direction regarding common variety minerals, which are the 

sole discretion of the Secretary of Agriculture (Secretary) to manage. 

Again, like the 2001 Roadless Rule, the Proposed Action does not seek to restrict 

retroactively any existing mineral authorizations5. However, the Proposed Action 

would establish limitations on the future exercise of discretion available to Forest 

Service line officers. It does not seek to impose restrictions on decision-making that 

Congress has assigned to the Department of the Interior. The Proposed Action also does 

not effect or seek a withdrawal of the mineral estate; such matters are subject to a 

separate statutory process established in the Federal Land Policy and Management Act 

(FLPMA). Instead, the Proposed Action would be applied only where Forest Service 

line officers have discretionary authority to influence whether and how the activity may 

occur. 

The Proposed Action does not address grazing, travel management, or wildland fire 

use. Management direction related to those activities would be regulated by other 

existing regulatory and analytical processes (for example, travel planning). 

 

5 Mineral authorizations include those for saleable, leasable, and locatable minerals. 
Comparison of Alternatives Roadless Area Conservation; National Forest System Lands in Idaho DEIS 

10 Summary 

Comparison of Alternatives 

2001 Roadless Rule Existing Plans Idaho Roadless Rule 

Idaho Roadless Rule and equivalent themes for the 2001 Roadless Rule and Existing Plans (Acres) 

Wild Land Recreation 0 1,320,800 1,378,600 

Primitive 0 2,131,400 1,656,300 

SAHTS 0 0 68,600 

Backcountry 9,304,200 4,244,500 5,246,100 

GFRG 0 1,262,400 609,500 

Other lands (Acres) 

Forest Plan Special Areas 0 354,100 354,100 

Total Idaho Roadless Area 

Acres 9,304,200 9,304,200 9,304,200 

Projected timber cutting 

Timber harvest yearly 

average (MMBF) 0.5 14 4 

Timber harvest yearly 

average (CCF) 1,137 26,900 7,237 

Timber harvest yearly 

average (acres) 100 2,800 800 

% of average yearly volume 

harvested on all NFS lands in 

Idaho 

.5% 11.5% 3% 

% of average yearly acreage 

harvested on all NFS lands in 

Idaho 

1% 28% 8% 

Projected miles of road construction/reconstruction activities; yearly average 

Permanent – other 0.8 0.8 0.8 

Temporary – other 0.2 0.2 0.2 

Reconstruction – other 0.0 0.0 0.0 

Total 1.0 1.0 1.0 

Permanent – timber 0.0 4.0 0.0 

Temporary – timber 0.0 2.0 1.5 

Reconstruction – timber 0.0 5.0 1.5 

Total 0.0 11.0 3.0 

Grand Total 1.0 12.0 4.0 

Decommissioning 1.0 4.0 3.0 

Net Change 0.0 8.0 1.0 

Percent of Idaho Roadless Areas that permit or prohibit construction/ reconstruction 

Prohibited 0 39 34 

Permitted, under limited 

exceptions 100 0 59 

Permitted, under variable 0 47 0 

Permitted without exceptions 0 14 7 
Roadless Area Conservation; National Forest System Lands in Idaho DEIS Comparison of Alternatives 

Summary 11 

2001 Roadless Rule Existing Plans Idaho Roadless Rule 

Forest health 

Insect and disease 

Most of the 1.4 million 

acres currently at risk of 

25% mortality or 

significant growth loss 

would remain untreated. 

190,000 of high risk 

forests in GFRG. 730,000 

in Backcountry 

Opportunities for 

treatment. 

Projected treatments on 

42,000 acres likely to be 

effective over 15 years. 

26,000 acres of high risk 

forests in GFRG. 940,000 

acres in Backcountry. 

Opportunities to treat 

GFRG. Opportunity for 

treatment in Backcountry 

if done for forest health or 

to reduce hazardous fuels 

Projected treatments on 

12,000 acres likely to be 

effective over 15 years. 

Noxious weeds – Potential for 

Noxious weed spread 

Spreading is unlikely 

given limited potential for 

soil disturbance. 28,000 

acres of weeds currently 

found in Idaho Roadless 

Areas. 

Some potential for 

spreading based on 

acreage assigned to 

GFRG (1.262 million); the 

limited degree of 

projected road 

construction, timber 

cutting, and mineral 

activity would minimize 

the potential for 

spreading. 8,300 acres of 

weeds currently found in 

GFRG. 

Some potential for 

spreading based on 

acreage assigned to 

GFRG (609,500 acres); 

the limited degree of 

projected construction, 

harvest and mineral 

activity would minimize 

the potential for 

spreading. 2,600 acres of 

noxious weeds currently 

found in GFRG. 

Climate change 

The magnitude and rapidity of climate change is uncertain, particularly at the finer 

scales such as Idaho Roadless Areas. Variable impacts across alternatives are 

therefore not quantified. 
Comparison of Alternatives Roadless Area Conservation; National Forest System Lands in Idaho DEIS 

12 Summary 

2001 Roadless Rule Existing Plans Idaho Roadless Rule 

Fuel management 

Road construction not 

permitted in conjunction 

with treatments on 100% 

of the WUI. 

Treatments more 

expensive; insignificant 

acreage treated relative to 

acres at risk. Limited 

capacity to treat high 

priority condition class 2 

and 3 areas. 

Does not directly permit 

timber cutting to reduce 

risk of unwanted wildland 

fire. 

Road construction 

permitted in conjunction 

with treatments on 69% of 

the Wildland Urban 

Interface (WUI). 

Mechanical treatments, 

without road construction 

may be permitted on 22% 

of the WUI. 

Mechanical treatments 

not permitted on 9%6

 of 

the WUI. 

Projected harvests could 

treat 10% of high priority 

areas (Fire Regimes I, II 

and III, Condition Class 2 

and 3) within WUIs or 1% 

of high priority areas 

overall. 

May permit timber cutting 

to reduce risk of 

unwanted wildland fires 

Road construction 

permitted in conjunction 

with treatments on 71% of 

the Wildland Urban 

Interface (WUI). 

Mechanical treatments, 

without road construction 

may be permitted on19% 

of the WUI. 

Mechanical treatments 

not permitted on 9% of 

the WUI. 

Projected harvests could 

treat 3% of high priority 

areas (Fire Regimes I, II 

and III, Condition Class 2 

and 3) within WUIs or less 

than half a percent of high 

priority areas overall. 

Directly permits timber 

cutting to reduce risk of 

unwanted wildland fires in 

the Primitive, 

Backcountry, and GFRG 

themes. 

Potential for increase in 

human-caused fire starts No increase Potential for increase No measurable increase 

Locatable minerals 

Gold, silver, lead, Etc. 

None of the alternatives affect rights of reasonable access to prospect and explore 

lands open to mineral entry and develop valid claims under the General Mining Act 

of 1872. 

Rights to reasonable access 

for locatable minerals Yes Yes Yes 

 

6

 Includes lands in Forest Plan Special Areas 
Roadless Area Conservation; National Forest System Lands in Idaho DEIS Comparison of Alternatives 

Summary 13 

2001 Roadless Rule Existing Plans Idaho Roadless Rule 

Leasable minerals 

Oil, gas, and coal Differences in activity and revenue associated with oil, gas, and coal development is 

expected to be minimal based on existing trends and inventories. 

Geothermal – acres of high 

geothermal potential within 

the GFRG theme 

0 387,300 351,600 

Geothermal – acres of 

medium geothermal potential 

within the GFRG theme 

0 796,600 236,500 

Geothermal – acres of high 

geothermal potential within 

the GFRG theme, less than 

40% slope 

0 249,500 233,600 

Geothermal – acres of 

medium geothermal potential 

within the GFRG theme, less 

than 40% slope 

0 457,700 140,800 

Geothermal development Negligible opportunities 

for development. 

No opportunities on 40% 

of acreage; 

Limited opportunities on 

46% of acreage; 

Open or unrestricted 

opportunities on 14% of 

acreage. 

No opportunities on 93% 

of acreage; 

Open or unrestricted 

opportunities on 7% of 

acreage. 

Leasable resources: 

phosphate (short term within 

15 yrs) 

Projected output is equal across all alternatives because (i) none of the alternatives 

prohibit road construction and reconstruction associated with existing leases and (ii) 

existing leases are expected to meet demand in reasonably foreseeable future. 

Phosphate – acres 

reasonable foreseeable road 

construction and mining 

disturbance proposed in Sage 

Creek and Meade Peak 

Roadless areas 

1,100 1,100 1,100 

Phosphate – Projected 

phosphate acres currently 

under lease 

8,000 8,000 8,000 

Phosphate (Long term – 

leasing of unleased 

phosphate deposits) 

Opportunities to recover 

phosphate from Idaho 

Roadless Areas are 

negligible. 

Estimated 603 million 

tons of phosphate 

deposits from 13,400 

unleased acres available 

for development. 

Estimated 545 million 

tons of phosphate 

deposits from 12,100 

unleased acres available 

for development (road 

construction prohibited on 

primitive theme acres). 
Comparison of Alternatives Roadless Area Conservation; National Forest System Lands in Idaho DEIS 

14 Summary 

2001 Roadless Rule Existing Plans Idaho Roadless Rule 

Saleable minerals 

Acres associated with 

potential developing new 

mineral material sites within 

Idaho Roadless Areas 

(GFRG) 

0 1,262,400 609,500 

Potential for development of 

new mineral material sites 

within Idaho Roadless Areas 

Rare Circumstance Minimal Minimal 

Saleable minerals (sand, 

stone, gravel, pumice, etc.) 

Differences in production of saleable minerals are projected to be minimal across 

alternatives due to the relative inefficiencies of providing saleable minerals from 

Idaho Roadless Areas. 

Abandoned and inactive mines 

Road Construction allowed for 

CERCLA Violations Yes Yes Yes 

Energy corridors 

Energy corridors 

None of the proposed corridors designated for oil, gas, and/or electricity under 

Section 368 of the Energy Policy Act are within Idaho Roadless Areas. Opportunities 

for non-Section 368 corridors within Idaho Roadless Areas are a function of the 

themes assigned to the areas proposed for corridor development; differences in 

opportunities across alternatives cannot be discerned. 

Physical resources 

Acres of high sensitive soils 

by theme 

 Wild Land Recreation 0 221,900 270,200 

 Primitive 0 817,200 610,800 

 SAHTS 0 0 24,100 

 Backcountry 3,094,200 1,503,400 1,842,500 

 GFRG 0 440,300 235,200 

 Forest Plan Special Areas 111,400 111,400 

Acres of high sensitivity 

soils where road construction/ 

reconstruction is permitted 

without restrictions – GFRG 

0 440,300 235,200 

Acres of highly sensitive soils 

where road construction/ 

reconstruction is prohibited 

3,094,200 1,1150,500 1,016,500 

Effect of road building on high 

hazard soils for timber cutting No effect Negligible effect Negligible effect 

Effect of road building on high 

hazard soils for mining Limited risk Likely effect Likely effect 

Miles of 303(d) listed streams 

Wild Land Recreation 0 15 29 

Primitive 0 62 47 

SAHTS 0 0 4 

Backcountry 445 159 210 

GFRG 0 84 31 

Forest Plan Special Areas 0 125 125 
Roadless Area Conservation; National Forest System Lands in Idaho DEIS Comparison of Alternatives 

Summary 15 

2001 Roadless Rule Existing Plans Idaho Roadless Rule 

Acres of watersheds with 

surface drinking water 

 Wild Land Recreation 0 26,800 29,500 

 Primitive 0 165,000 119,900 

 SAHTS 0 0 0 

 Backcountry 409,100 151,600 230,900 

 GFRG 0 61,500 24,600 

 Forest Plan Special Areas 0 4,200 4,200 

Effect of road construction, 

reconstruction, and timber 

harvest on listed streams and 

drinking water 

Negligible effect Minimal effect Negligible effect 

Effect of mining on listed 

streams and drinking water 

Possible effect to 303(d) 

streams from selenium – 

mitigation required at time 

of analysis 

Possible effect to 303(d) 

streams from selenium – 

mitigation required at time 

of analysis 

Possible effect to 303(d) 

streams from selenium – 

mitigation required at time 

of analysis 

Acres within 50 miles of a 

Class I air quality protection 

area 

 

 Wild Land Recreation 0 832,400 879,600 

 Primitive 0 1,712,300 1,406,300 

 SAHTS 0 0 46,500 

 Backcountry 5,542,800 2,370,600 2,871,100 

 GFRG 395,200 107,000 

 Forest Plan Special Areas 232,300 232,300 

Effect to air quality from fuel 

reduction projects Negligible Negligible Negligible 

Botanical resources 

Number of occurrences of 

known sensitive plant 

populations 

 

 Wild Land Recreation 0 127 141 

 Primitive 0 166 147 

 SAHTS 0 0 1 

 Backcountry 1,165 523 601 

 GFRG 0 84 10 

 Forest Plan Special Areas 0 265 265 

Effects on biodiversity Beneficial 

Beneficial in Wild Land 

Recreation, Primitive, or 

SAHTS 

Aquatic 

Effects to aquatic species or 

habitat Beneficial 

Beneficial in Wild Land 

Recreation, Primitive, or 

SAHTS; Some potential 

risk of adverse effects in 

management 

prescriptions similar to 

Backcountry and GFRG 

Beneficial in Wild Land 

Recreation, Primitive, or 

SAHTS; Limited potential 

risk of adverse effects in 

Backcountry; some 

potential risk in GFRG 
Comparison of Alternatives Roadless Area Conservation; National Forest System Lands in Idaho DEIS 

16 Summary 

2001 Roadless Rule Existing Plans Idaho Roadless Rule 

Wildlife 

Effects to terrestrial animal 

species or habitat Beneficial 

Beneficial in Wild Land 

Recreation, Primitive, or 

SAHTS; Some potential 

risk of adverse effects in 

management 

prescriptions similar to 

Backcountry and GFRG 

Beneficial in Wild Land 

Recreation, Primitive, or 

SAHTS; Limited potential 

risk of adverse effects in 

Backcountry; some 

potential risk in GFRG 

Recreation 

Dispersed Recreation – 

No measurable change to 

dispersed recreation 

opportunities. Feeling of 

remoteness or solitude 

may change if timber 

cutting or road 

construction/ 

reconstruction occurs 

(projected 1,500 acres 

timber cutting and 15 

miles of road 

construction/ 

reconstruction over 15 

years. No change to 

hunting and fishing 

opportunities. 

No measurable change to 

dispersed recreation 

opportunities, except if 

unleased phosphate 

deposits (13,400 acres) 

are developed. 

Feeling of remoteness or 

solitude may change if 

timber cutting or road 

construction/ 

reconstruction occurs 

(projected 42,000 acres 

timber cutting and 180 

miles of road 

construction/ 

reconstruction over 15 

years. No change to 

hunting and fishing 

opportunities. 

No measurable change to 

dispersed recreation 

opportunities, except if 

unleased phosphate 

deposits (12,100 acres) 

are developed. 

Feeling of remoteness or 

solitude may change if 

timber cutting or road 

construction/ 

reconstruction occurs 

(projected 12,000 acres 

timber cutting and 60 

miles of road 

construction/ 

reconstruction over 15 

years. No change to 

hunting and fishing 

opportunities. 

Developed recreation – ability 

to construct or reconstruct 

roads to access new or 

expanded developed 

recreation areas 

No road construction/ 

reconstruction permitted 

to access new developed 

recreations sites (9.3 

million acres). There are 

no foreseeable 

developments. 

Road construction/ 

reconstruction generally 

permitted to access new 

developed recreations 

sites management 

prescriptions similar to 

Backcountry and GFRG 

(5.5 million acres). There 

are no foreseeable 

developments. 

Road construction/ 

reconstruction permitted 

to access new developed 

recreations sites 

management in GFRG (.6 

million acres). There are 

no foreseeable 

developments. 

Recreation 

In general, the magnitude of shifts in recreational opportunity spectrum classes is 

slight across the alternatives because: (i) differences in road construction are 

minimal, and (ii) many constructed roads are likely to be temporary and not 

accessible for recreation purposes. As a consequence, changes in dispersed versus 

developed recreation opportunities are small across alternatives. Relative 

differences include the following: 
Roadless Area Conservation; National Forest System Lands in Idaho DEIS Comparison of Alternatives 

Summary 17 

2001 Roadless Rule Existing Plans Idaho Roadless Rule 

Relatively high potential 

for maintaining existing 

dispersed recreation 

opportunities; little 

potential for increasing 

developed recreation. 

Greatest opportunity for 

developed and roadbased recreation to occur 

and expand, but 

magnitude of shift is 

tempered by limited 

amount of construction 

projected to occur. 

Potentially the greatest 

level of protection for 

dispersed recreation, 

foreseeable threats from 

construction and 

development are remote. 

Recreation special uses – 

existing permits (including ski 

areas) 

Existing permits 

unaffected 

Existing permits 

unaffected 

Existing permits 

unaffected 

Hunting and fishing No effect to opportunities. Opportunities could be 

affected in locations of 

phosphate leasing and 

geothermal development. 

No effect from timber 

cutting and limited road 

construction. 

Opportunities could be 

affected in locations of 

phosphate leasing and 

geothermal development. 

No effect from timber 

cutting and limited road 

construction. 

Wilderness 

Existing Wilderness areas 

1,726,000 acres of 

roadless areas adjacent 

to Wilderness. 

Limited to no indirect 

effect to Wilderness from 

activities in roadless 

areas 

158,000 acres of GFRG 

adjacent to Wilderness; 

842,000 acres of 

Backcountry 

Limited potential for 

impacts to Wilderness 

experience 

9,000 acres of GFRG 

adjacent to Wilderness; 

954,000 acres of 

Backcountry 

Limited potential for 

impacts to Wilderness 

experience 

Recommended wilderness 

No change or effect to 

recommended wilderness 

in existing plans 

Existing plans 

recommend 1,320,900 as 

Wilderness 

There would be no 

change to the 

recommendations in the 

forest plans; however 

there are 1,378,600 acres 

in Wild Land Recreation. 

57,700 acres of additional 

protection over existing 

plans. 

Some recommended 

wilderness areas in 

Boulder-White Clouds 

and Winegar Roadless 

Areas would be managed 

as Primitive. 

 

6,900 acres in Mallard 

Larkins Roadless Area 

would be managed as 

Backcountry. 
Comparison of Alternatives Roadless Area Conservation; National Forest System Lands in Idaho DEIS 

18 Summary 

2001 Roadless Rule Existing Plans Idaho Roadless Rule 

Wilderness characteristic 

Majority of roadless areas 

retain their existing 

character 

 Areas developed could 

have reduced wilderness 

character. Activities in 

GFRG may not change 

wilderness character if 

prior activities are still 

evident 

Areas developed could 

have reduced wilderness 

character. Activities in 

GFRG may not change 

wilderness character if 

prior activities are still 

evident 

Scenic integrity 

Acres maintained in High to 

Very High Scenic Integrity 

 Wild Land Recreation 0 1,320,900 1,378,600 

 Primitive 0 2,130,100 1,656,300 

 SAHTS 0 0 68,600 

 Backcountry 9,295,100 0 0 

 GFRG 

 Forest Plan Special Areas 0 345,100 345,100 

Acres available for reduction 

to Moderate Scenic Integrity 

 Wild Land Recreation 0 0 0 

 Primitive 0 0 0 

 SAHTS 0 0 0 

 Backcountry 9,304,200 4,243,700 5,245,300 

 GFRG 0 1,251,100 598,200 

 Forest Plan Special Areas 0 0 0 

Acres Likely Changed to 

Moderate or Low Scenic 

Integrity 

 

 Wild Land Recreation 0 0 0 

 Primitive 0 1,300 0 

 SAHTS 0 0 0 

 Backcountry 9,100 800 800 

 GFRG 0 11,300 11,300 

 Forest Plan Special Areas 0 0 0 
Roadless Area Conservation; National Forest System Lands in Idaho DEIS Comparison of Alternatives 

Summary 19 

2001 Roadless Rule Existing Plans Idaho Roadless Rule 

Scenic integrity 

High or Very High scenic 

integrity retained on most 

Idaho Roadless Areas. 

Potential for lower scenic 

quality on 5.5 million 

acres due permissions in 

management 

prescriptions for timber 

cutting, road construction/ 

reconstruction and 

discretionary mineral 

activities, but reasonably 

foreseeable losses are 

small given projections of 

activities in Idaho 

Roadless Areas. 

Potential for lower scenic 

quality on 5.9 million 

acres due to management 

theme assignments and 

associated permissions 

for timber cutting, road 

construction/ 

reconstruction and 

discretionary mineral 

activities, but reasonably 

foreseeable losses are 

small given projections of 

activities in Idaho 

Roadless Areas. 

Cultural resources 

Potential for disturbance, 

vandalism, and looting Low Low to Moderate Low 

Cultural resources 

Prior to management actions taking place on the ground under any alternative or 

theme, cultural resource inventories and appropriate mitigation are required by law. 

Differences in risk to cultural resources are not expected to be significant across 

alternatives due to projected levels of road construction and long-term use and fate 

of new roads. 

Idaho and affected Indian tribes 

Impacts on Tribal governments and Tribal practices from resource management 

activities would be minimal because of consultation requirements. Roads, timber 

cutting, and mining may alter the character of places that have historic or cultural 

value, thereby diminishing their value. 

Social 

Values and Beliefs Most environmental 

functions retained, 

roadless characteristics 

remain intact 

Most environmental 

functions retained, some 

roadless characteristics 

changed 

Most environmental 

functions retained, few 

roadless characteristics 

changed 

Collaborative Environment Local communities feel 

left out 

Local communities 

engaged 

Local community interests 

integrated with national 

values 

Lifestyles Significant risks to 

natural resource 

conditions near 

communities remain 

Significant risks to natural 

resource conditions near 

communities reduced 

Significant risks to 

natural resource 

conditions near 

communities reduced 

 Undeveloped recreation 

and cultural opportunities 

continue 

Many undeveloped 

recreation and cultural 

opportunities continue 

Most undeveloped 

recreation and cultural 

opportunities continue 

Economic 

Commodity values – forest 

level outputs 

 Harvest (MBF) 567 13,458 3620 

 Phosphate (tons) 2,000,000 2,000,000 2,000,000 
Comparison of Alternatives Roadless Area Conservation; National Forest System Lands in Idaho DEIS 

20 Summary 

2001 Roadless Rule Existing Plans Idaho Roadless Rule 

 Road decommissioning 

 (miles) 1.00 4.00 3.00 

 Roads (miles) 1.00 12.02 4.35 

Jobs (Yr) 

 Harvest 1 304 91 

 Phosphate 582 582 582 

 Road construction/ 

 reconstruction 

2 12 4 

Labor Income ($/Yr) 

 Harvest 343,000 7,651,000 1,935,000 

 Phosphate 23,000,000 23,000,000 23,000,000 

 Road construction/ 

 reconstruction 100,000 467,000 150,000 

Non-Commodity Values - 

Acres retaining natural 

processes and roadless 

characteristics (million) 

9.3 4.3 3.2 
Roadless Area Conservation; National Forest System Lands in Idaho DEIS 1.1 Document Structure 

Chapter 1. Purpose of and Need for Action 21 

CHAPTER 1. PURPOSE OF AND NEED FOR ACTION 

1.1 Document Structure 

The U.S. Department of Agriculture (USDA), Forest Service, with the State of Idaho as a 

cooperating agency, has prepared this draft environmental impact statement (draft EIS) 

in compliance with the National Environmental Policy Act (NEPA) and other relevant 

Federal and State laws and regulations. This draft EIS discloses the environmental 

consequences that could result from the Proposed Action (proposed Idaho Roadless 

Rule) and alternatives. The document is organized into four chapters: 

• Chapter 1. Purpose of and Need for Action. The chapter includes information 

on the history of the proposal, the purpose of and need for the proposed rule, 

and the Agency’s proposal for achieving that purpose and need. This section also 

details how the Forest Service informed the public of the proposal and how the 

public responded. 

• Chapter 2. Alternatives, Including the Proposed Action. This chapter provides a 

more detailed description of the Agency’s Proposed Action as well as alternative 

methods for achieving the stated purpose. 

• Chapter 3. Affected Environment and Environmental Consequences. This 

chapter describes the environmental consequences of implementing the proposal 

and other alternatives. This analysis is organized by overview, methodology, 

assumptions, and resource area. 

• Chapter 4. Consultation and Coordination. This chapter provides a list of 

preparers and agencies consulted during the development of the EIS. 

• Index. The index provides page numbers by document topics. 

• Appendices. The appendices provide additional detailed information in support 

of the analyses presented in the EIS. 

• Map packet. The map packet is a separate packet that includes alternative maps, 

and maps for appendix A and appendix C. 

Related documentation, including additional detailed analyses of project-area 

resources, may be found in the project planning record located at Northern Rockies 

Regional Office, 200 East Broadway, Missoula, Montana. 
1.2 Background Roadless Area Conservation; National Forest System Lands in Idaho DEIS 

22 Chapter 1. Purpose of a Need for Action 

1.2 Background 

The State of Idaho submitted to the Secretary of Agriculture (Secretary) a petition for 

rule-making: the State of Idaho Petition (Petition) (Risch 2006). The Petition, pursuant to 

section 553(e) of the Administrative Procedures Act and Department of Agriculture 

(Department) regulations at 7 Code of Federal Regulation (CFR) §1.28, requested 

specific regulatory protections and certain management flexibility for the 9.3 million 

acres of National Forest System (NFS) inventoried roadless areas (roadless areas) in 

Idaho. 

The Petition was based on information about each roadless area in existing and 

proposed land and resource management plans (forest plans) that consider the different 

and unique values each roadless area contains, and county and public comments (see 

the Public Involvement section below). The State proposed a management continuum, 

including, at one end, a restrictive approach emphasizing passive management, and 

natural restoration approaches, and, on the other end, active management designed to 

accomplish sustainable forest, rangeland, and grassland management. 

The Forest Service and the State believe that the Proposed Action represents a unique 

opportunity to collaboratively resolve and provide certainty to the roadless issue in the 

State of Idaho. First, the Proposed Action enables the Forest Service to account for 

comments of those most affected or concerned about the contents of State-specific 

rulemaking. Second, it allows the Agency to consider the unique characteristics of each 

individual inventoried roadless area in the State. Third, it balances the integrity and 

natural beauty of these roadless areas with responsible stewardship. 

The Roadless Area Conservation National Advisory Committee (RACNAC) reviewed 

the Petition on November 29 and 30, 2006. Governor James Risch, on behalf of the State 

of Idaho, discussed his views on the scope and intent of the Petition. The committee also 

heard comments from other State and Forest Service officials, and members of the 

public (RACNAC 2006). On December 19, 2006, the RACNAC issued a unanimous 

consensus-based recommendation that the Secretary direct the Forest Service, with the 

State of Idaho as a cooperating agency, to proceed with rulemaking (RACNAC 2006a). 

On December 22, 2006, the Secretary accepted the Petition and directed the Forest 

Service to proceed with developing a rule specific to NFS inventoried roadless areas in 

Idaho (USDA 2006). 
Roadless Area Conservation; National Forest System Lands in Idaho DEIS 1.3 Purpose of and Need for Action 

Chapter 1. Purpose of and Need for Action 23 

1.3 Purpose of and Need for Action 

The purpose of the proposed Idaho Roadless Rule is to provide State-specific direction 

for the conservation and management of inventoried roadless areas within the State of 

Idaho. The proposed Idaho Roadless Rule integrates local management concerns with 

the national objectives for protecting roadless area values and characteristics7. 

The Department and the Forest Service are committed to conserving and managing 

inventoried roadless areas and consider these areas an important component of the 

NFS. The Department believes that the most viable path for lasting conservation of 

these areas must properly integrate local, State, and national perspectives on roadless 

area management. The management direction in the Proposed Action achieves this 

integration because it takes into account State and local resource management 

challenges and the national interest in maintaining roadless characteristics, and it 

provides for management flexibility. 

The management direction is based on individual roadless characteristics for lands (1) 

containing outstanding or unique features, where there is minimal or no evidence of 

human use; (2) containing culturally significant areas; (3) containing general roadless 

characteristics, where human uses may or may not be more apparent; and (4) 

displaying high levels of human use, while: 

• Protecting communities, homes, and property from the risk of severe wildfire or 

other risks existing on adjacent Federal lands; 

• Protecting forests from the negative effects of severe wildfire and insect and 

disease outbreaks; or 

• Protecting access to property, by ensuring that States, Tribes, and citizens 

owning property within roadless areas have access to that property as required 

by existing laws. 

The Secretary, aware of the long, unresolved debates over the management of 

inventoried roadless areas in the absence of wilderness legislation for the State of Idaho, 

considered the State’s Petition, the advice, and recommendations of the RACNAC, and 

associated public comments. The Secretary determined that there is a need to consider 

roadless area management direction specific to the State of Idaho. 

 

7 See section 1.7 for descriptions of roadless characteristics. 
1.4 Proposed Action (Idaho Roadless Rule) Roadless Area Conservation; National Forest System Lands in Idaho DEIS 

24 Chapter 1. Purpose of a Need for Action 

1.4 Proposed Action (Idaho Roadless Rule) 

The Forest Service is proposing to promulgate a State-specific rule in response to the 

Idaho State Petition presented by Governor Risch on November 29 and 30, 2006, to the 

RACNAC. 

The proposed Idaho Roadless Rule would designate a system of lands called Idaho 

Roadless Areas (fig. 1-1) and establish five management area themes for individual 

roadless areas: Wild Land Recreation; Primitive, Special Areas of Historic and Tribal 

Significance; Backcountry/Restoration; and General Forest, Rangeland, and Grassland 

(map packet – Idaho Roadless Rule management themes). The proposed themes span a 

continuum (fig. 1-2) that includes at one end a restrictive approach emphasizing passive 

management and natural restoration approaches, and on the other end, active 

management designed to sustainable forest, rangeland, and grassland management. 

This continuum accounts for stewardship of the uniqueness of each individual roadless 

area’s landscape and the quality of roadless characteristics in that area. 
Roadless Area Conservation; National Forest System Lands in Idaho DEIS 1.4 Proposed Action (Idaho Roadless Rule) 

Chapter 1. Purpose of and Need for Action 25 

Figure 1-1. Idaho Roadless Areas – areas designated pursuant to the proposed Idaho Roadless Rule, based 

on the most current inventory of roadless areas in Idaho 
1.4 Proposed Action (Idaho Roadless Rule) Roadless Area Conservation; National Forest System Lands in Idaho DEIS 

26 Chapter 1. Purpose of a Need for Action 

Figure 1-2. Idaho Roadless Rule continuum 

Allocation to a specific theme is not intended to mandate or direct the Forest Service to 

propose or implement any action; rather the themes provide an array of permitted and 

prohibited activities regarding: 

• Timber cutting, sale, or removal; 

• Road construction and reconstruction; 

• Mineral activities. 

The Proposed Action also provides for the ability to accommodate necessary corrections 

and modifications in the future. 

The subsections below describe each management area theme and its intended purpose 

and describes when timber cutting, sale, or removal; road construction/reconstruction; 

and discretionary mineral activities would be permitted or prohibited. 

WILD LAND RECREATION

A classification of an Idaho Roadless Area assigned to lands that were generally 

identified during the forest planning process as recommended for wilderness 

designation. These lands would show little evidence of human-caused disturbance and 

natural conditions and processes would be predominant. 
Roadless Area Conservation; National Forest System Lands in Idaho DEIS 1.4 Proposed Action (Idaho Roadless Rule) 

Chapter 1. Purpose of and Need for Action 27 

Timber cutting, sale, or removal. Prohibited except for personal or administrative 

use (36 CFR §223); or when incidental to the implementation of a management 

activity not otherwise prohibited (e.g., trail clearing). 

Road construction/reconstruction. Prohibited unless provided for by statute or 

treaty, or pursuant to reserved or outstanding rights, or other legal duty of the 

United States. 

Mineral activities. No recommendation, authorization, or consent to surface 

occupancy, or road construction or reconstruction associated with new mineral 

leases. The sale of common variety minerals would be prohibited. Locatable mineral 

activities pursuant to the General Mining Law of 1872, including road construction 

and reconstruction, would not be affected. 

PRIMITIVE

A classification of an Idaho Roadless Area that would be managed to remain relatively 

undisturbed by human management activities while allowing for limited forest health 

activities including preserving biological strongholds for a variety of species and 

protecting the ecological integrity. 

Timber cutting, sale, or removal. Prohibited unless existing roads or aerial systems 

are used and the responsible official determines that: 

1. The cutting, sale, or removal of timber would maintain or improve one or more 

of the roadless characteristics and is needed for one of the following purposes: 

a. To improve threatened, endangered, proposed, or sensitive species habitat; or 

b. To maintain or restore the characteristics of ecosystem composition and 

structure or to reduce the significant risk of wildland fire effects; or 

2. The cutting, sale, or removal of timber is: 

a. Personal or administrative use (36 CFR §223); or 

b. Incidental to the implementation of a management activity not otherwise 

prohibited (e.g., trail clearing). 

Road construction and reconstruction. Prohibited, unless provided for by statue or 

treaty, or pursuant to reserved or outstanding rights, or other legal duty of the 

United States. 

Mineral activities. No recommendation, authorization, or consent to surface 

occupancy or road construction or reconstruction associated with new mineral or 

energy leases. The sale of common variety minerals would be prohibited. Locatable 

mineral activities pursuant to the General Mining Law of 1872, including road 

construction and reconstruction, would not be affected. 
1.4 Proposed Action (Idaho Roadless Rule) Roadless Area Conservation; National Forest System Lands in Idaho DEIS 

28 Chapter 1. Purpose of a Need for Action 

SPECIAL AREAS OF HISTORIC AND TRIBAL SIGNIFICANCE

A classification of an Idaho Roadless Area managed to be relatively undisturbed by 

human management activities in order to maintain their unique Tribal or historic 

characteristics. This theme would provide for the same management direction as 

Primitive. 

BACKCOUNTRY/ RESTORATION

A classification of an Idaho Roadless Area that would be managed to retain the 

undeveloped character, while providing a variety of recreation opportunities, and 

allowing for limited forest health activities, including preserving biological strongholds 

for a variety of species, and maintaining or restoring the characteristics of ecosystem 

composition and structure. 

Timber cutting, sale, or removal. Permitted if one of the following circumstances 

exists: 

1. The cutting, sale, or removal of timber would maintain or improve one or more 

of the roadless characteristics and is needed for one of the following purposes: 

a. To improve threatened, endangered, proposed, or sensitive species habitat; or 

b. To maintain or restore the characteristics of ecosystem composition and 

structure or to reduce the significant risk of wildland fire effects; or 

2. The cutting, sale or removal of timber is: 

a. Personal or administrative use (36 CFR §223); or 

b. Incidental to the implementation of a management activity not otherwise 

prohibited (e.g., trail clearing 

c. It is within a substantially altered portion of an Idaho Roadless Area 

designated as Backcountry/Restoration, which has been altered because of 

the construction of a forest road and subsequent timber harvest. 

Road construction/reconstruction. Permissible if one or more of the following 

criteria is met: 

1. A road is needed to protect public health and safety in cases of significant risk or 

imminent threat of flood, fire, or other catastrophic event that, without 

intervention, would cause the loss of life or property, or to facilitate forest health 

activities permitted under timber cutting, sale, or removal (1) above; 

2. 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; or 

3. A road is needed pursuant to statute, treaty, reserved or outstanding rights, or 

other legal duty of the United States; or 
Roadless Area Conservation; National Forest System Lands in Idaho DEIS 1.4 Proposed Action (Idaho Roadless Rule) 

Chapter 1. Purpose of and Need for Action 29 

4. Road realignment is needed to prevent resource damage that arises from the 

design, location, use, or deterioration of a road and cannot be mitigated by road 

maintenance. Road realignment may occur only if the road is deemed essential 

for public or private access, natural resource management, or public health and 

safety; or 

5. Road construction is needed to implement a road safety improvement project on 

a road that has been determined to be hazardous based on accident experience or 

accident potential on that road; or 

6. The Secretary of Agriculture determined that a Federal aid highway project, 

authorized pursuant to Title 23 of the U.S. Code (23 USC), is in the public interest 

or is consistent with the purpose for which the land was reserved or acquired 

and no other reasonable and prudent alternative exists; or 

7. A road is needed in conjunction with activities permissible under the limited 

mineral exceptions for Backcountry. 

Road construction must be a temporary road, unless the responsible official 

determines that a permanent road meets one or more of the above criteria and that 

the addition of a permanent road would not substantially alter roadless 

characteristics. Maintenance of forest or temporary roads is permissible. 

Mineral activities. No recommendation, authorization, or consent to road 

construction or reconstruction associated with new mineral leases, except such road 

construction or reconstruction may be authorized in association with phosphate 

leasing. Leasing instruments that allow surface use or occupancy are permissible if 

they do not require road construction or reconstruction. Locatable mineral activities 

pursuant to the General Mining Law of 1872 would not be affected, including road 

construction and reconstruction. 

The Forest Service would not authorize sale of common variety mineral materials, 

but may authorize the use or sale of common variety minerals, and associated road 

construction or reconstruction to access these minerals if the use of these minerals is 

incidental to activity allowed under this rule. 

GENERAL FOREST, RANGELAND, OR GRASSLAND

A classification of an Idaho Roadless Area that would be managed to provide a variety 

of goods and services as well as a broad range of recreational opportunities, and 

conservation of natural resources. 

Timber cutting, sale, or removal. Permitted, consistent with the applicable forest plan, 

after necessary environmental analysis, including public involvement is completed. 

Road construction/reconstruction. Permitted for a forest or temporary road after 

necessary environmental analysis is completed. Maintenance of forest and temporary 

roads is permissible. 
1.4 Proposed Action (Idaho Roadless Rule) Roadless Area Conservation; National Forest System Lands in Idaho DEIS 

30 Chapter 1. Purpose of a Need for Action 

Mineral activities: Permitted, after necessary environmental analysis is completed. 

Road construction or reconstruction associated with mining activities allowed must be 

conducted in a manner that minimizes effects on surface resources, prevents 

unnecessary or unreasonable surface disturbances, and complies with all applicable 

lease requirements, land and resource management plans, regulations, and laws. Road 

constructed or reconstructed must be decommissioned when no longer needed upon 

expiration of the lease, contract, or permit, whichever is sooner. 

OTHER FOREST PLAN SPECIAL AREAS

The Idaho Roadless Rule identified approximately 345,100 acres of roadless areas that 

are already part of other land classification systems—such as research natural areas, 

wild and scenic rivers, special interest areas, and the like (appendix H, table H-9)—that 

are governed by specific Agency directives and forest plan direction. These forest plan 

special areas are included for the sake of completeness; however, the proposed Idaho 

Roadless Rule does not recommend management direction for these lands, which 

would continue to be governed by forest plans. 
Roadless Area Conservation; National Forest System Lands in Idaho DEIS 1.5 Decision Framework 

Chapter 1. Purpose of and Need for Action 31 

1.5 Decision Framework 

The Secretary, U.S. Department of Agriculture, or his designee will consider 

establishing regulation direction for timber cutting, sale or removal; road 

construction/reconstruction; and discretionary mineral activities on NFS lands in Idaho 

Roadless Areas and will determine whether or not to: 

• Promulgate a rule based on the Petition (Proposed Action), 

• Promulgate a rule based on a modified Petition (alternatives), or 

• Not promulgate a rule (no action). 
1.6 Public Involvement Roadless Area Conservation; National Forest System Lands in Idaho DEIS 

32 Chapter 1. Purpose of a Need for Action 

1.6 Public Involvement 

The management of undeveloped areas of the NFS has been a topic of ongoing 

discussion since the 1920s. In the past 10 years, several formal public processes have 

been initiated. These include the involvement of the public in developing the 2001 

Roadless Rule, the 2005 State Petition Rule, individual forest plan revisions, and most 

recently, the Idaho State Roadless Petition. Overall the public response represents two 

main points of view on natural resource management and decision-making regarding 

the management of inventoried roadless areas: 

1. An emphasis on environmental protection and preservation, and support for 

making decisions about roadless area management at the national level; 

2. An emphasis on responsible active management, and support for making 

decisions about roadless area management at the local level. 

2001 ROADLESS AREA CONSERVATION RULE (2001 ROADLESS RULE) 

The Forest Service received more than 360,000 individual responses, representing more 

than 500,000 comments, in response to its 1999 notice of intent to promulgate a rule. 

Close to 1.2 million responses were received by the Forest Service on the proposed 2001 

Roadless Rule and draft EIS during their comment period (USDA Forest Service 2000p). 

More than one million responses were form letters initiated by national interest groups. 

Agency responses to comments on the draft EIS are contained in Volume 3, Agency 

Responses to Public Comments, Forest Service Roadless Area Conservation Final EIS 

(USDA, Forest Service, 2000). Responses in Volume 3 relevant to the final rule are 

summarized in the preamble to the final rule published in the Federal Register on 

January 12, 2001 (USDA Forest Service 2001). 

2005 STATE PETITIONS RULE FOR INVENTORIED ROADLESS AREA MANAGEMENT 

(STATE PETITIONS RULE) 

On May 4, 2001, the Secretary reaffirmed the Administration’s commitment to 

providing protection for inventoried roadless areas in NFS lands. However, 

acknowledging concerns raised by local communities, Tribes, and States affected by the 

2001 Roadless Rule, the Secretary also indicated that the Department would fairly 

address those concerns by re-examining the rule with a responsible and balanced 

approach. 

On July 10, 2001, the Forest Service published an advanced notice of proposed rule in 

the Federal Register (USDA Forest Service 2001a) seeking public comment about how 

best to proceed with long-term protection and management of roadless areas. During 

the public comment period, which closed on September 11, 2001, the Forest Service 

received more than 726,000 responses. 
Roadless Area Conservation; National Forest System Lands in Idaho DEIS 1.6 Public Involvement 

Chapter 1. Purpose of and Need for Action 33 

A proposed rule was published in the Federal Register on July 16, 2004 (USDA Forest 

Service 2004). Approximately 1.8 million comments were received from a wide variety 

of respondents. Responses relevant to the final rule are summarized in the preamble to 

the final rule published in the Federal Register on May 13, 2005 (USDA Forest Service 

2005). 

FOREST PLANNING

Public involvement has been extensive, from the development of the first generation of 

land management planning (forest planning) in the 1980s through subsequent revisions 

of those plans. Moreover, one of the key issues in each public involvement process has 

been the management of inventoried roadless areas. Local, regional, and national 

comments have been received during these extensive public processes. Forests revising 

their plans use a collaborative process for working with the public on the management 

of roadless areas. Five Idaho forests have completed revisions of their plans, three are in 

progress, and two have not initiated revision. 

IDAHO STATE PETITION

On June 23, 2005, the Governor of Idaho announced that the State would develop a 

petition pursuant to the State Petitions Rule. In that announcement, the Governor 

solicited the help of local units of government to invite local communities to develop 

(through a public process) specific recommendations for inventoried roadless areas in 

portions of the national forests within their counties. 

Following that announcement, local communities under the leadership of their 

respective county commissioners outlined a process for providing written 

recommendations to the Governor for review. Affected county commissioners held a 

series of public meetings to solicit public comment and develop their recommendations. 

Statewide, approximately 50 public meetings were held. To provide guidance and 

assistance in the process, a representative from either the Governor’s Office or the 

Governor’s Office of Species Conservation attended nearly every meeting. In addition 

to those meetings, the Governor’s staff explained the Governor’s vision for his local 

process during at least 10 additional meetings across the State. Because of the high 

volume of comments received, the county commissioners hired two independent 

contractors to compile submitted comments and prepare the commissioners’ final 

recommendations to the Governor. 

The State received comments or recommendations from 66 organizations, 30 counties, 

and 1,596 individuals. Some responses focused on individual roadless areas. Based on 

the comments submitted by the commissioners, individuals, and organizations, the 

Governor’s staff developed management recommendations for each individual roadless 

area for the Governor’s consideration. After development of the initial 

recommendations, the State engaged the Native American Tribes in Idaho, as fellow 

sovereigns, in discussions about these recommendations. The State of Idaho also 
1.6 Public Involvement Roadless Area Conservation; National Forest System Lands in Idaho DEIS 

34 Chapter 1. Purpose of a Need for Action 

contacted neighboring States to ensure inter-roadless area consistency. Based on the 

information gathered, the Governor assigned the management emphasis and the uses 

that would be permissible or prohibited for each management area. 

The Governor’s Petition demonstrates substantial engagement with local units of 

government, tribal governments, and the public at large, and well represents those who 

know, live, work, and recreate on these lands. 

ROADLESS AREA CONSERVATION NATIONAL ADVISORY COMMITTEE (RACNAC) 

The RACNAC was chartered by the Secretary to provide a national perspective on 

individual State petitions regarding roadless area management. On November 29 and 

30, 2006, Governor James Risch presented the Idaho State Petition to the RACNAC. 

They also heard comments from other State and Forest Service officials, and nine 

members of the public, including one State-level organization and three national 

organizations (RACNAC 2006). These public comments were transmitted to the Forest 

Service and considered in the development of this EIS.

SCOPING 

A notice of intent to prepare an EIS on “Roadless Area Conservation; National Forest 

System Lands in Idaho” was published in the Federal Register, April 10, 2007 (USDA 

Forest Service 2007). About 38,000 comments were received, of which 32,000 were form 

letters8, while the remaining letters consisted of original responses or form letters with 

additional original text. These comments were evaluated and summarized in a report 

called Summary of Public Comments, which is provided in the Scoping section of the 

project record. The summary analyzes the public’s responses specific to the Proposed 

Action, identifying significant concerns and issues. 

 

8 Form letters are five or more letters that contain identical text but are submitted by different people. 
Roadless Area Conservation; National Forest System Lands in Idaho DEIS 1.7 Issues 

Chapter 1. Purpose of and Need for Action 35 

1.7 Issues 

The Council on Environmental Quality (CEQ) regulations at 40 CFR §1501.7 direct 

agencies to “Determine the scope (§1508.25) and the significant issues to be analyzed in 

depth in the environmental impact statement” and to “identify and eliminate from 

detailed study the issues which are not significant or which have been covered by prior 

environmental review (§1506.3).” Scope consists of the range of actions, alternatives, 

and impacts to be considered in an EIS (40 CFR §1508.24). The scope of this EIS is 

defined by the Proposed Action, alternatives developed to address significant issues 

while meeting the purpose of and need for action, and the potential impacts identified 

in the significant issues. 

The Forest Service identified as significant issues those resources that could directly or 

indirectly be affected as a result of implementation of the Proposed Action.9 The Forest 

Service identified the following significant issues during scoping. The issues represent 

possible effects of implementing the proposed Idaho Roadless Rule. 

CHANGES TO ROADLESS CHARACTERISTICS 

Idaho Roadless Areas provide large, relatively undisturbed landscapes. Key values or 

features characterize these areas and are briefly described below. Over time, whether it 

was in the development of the 2001 Roadless Rule, the 2005 State Petition Rule, or 

individual forest plans, the public has identified as an issue any significant changes to 

these roadless characteristics within individual Idaho Roadless Areas. The proposed 

Idaho Roadless Rule would provide management direction regarding timber cutting, 

road construction/reconstruction, and discretionary mineral activities in Idaho 

Roadless Areas. Implementation of this management direction could result in 

opportunities to change roadless characteristics. 

1. High quality or undisturbed soil, water, and air. These three key resources are 

the foundation on which other resources depend. Healthy watersheds catch, 

store, and safely release water over time and in this way they: 

a. Protect downstream communities from flooding; 

b. Provide clean water for domestic, agricultural, and industrial uses; 

c. Help maintain abundant and healthy fish and wildlife populations; and 

d. Provide the basis for many forms of outdoor recreation. 

The prohibitions and permissions in the Proposed Action could change the 

ability of a roadless area to provide high quality soil, water, and air. 

 

9 Issues identified as not being significant were those: (1) outside the scope of the Proposed Action; (2) 

already decided by law or other regulation; (3) unrelated to the decision to be made; or (4) conjectural 

and not supported by scientific or factual evidence. A list of non-significant issues and reasons regarding 

their categorization as non-significant is provided in the project record. 
1.7 Issues Roadless Area Conservation; National Forest System Lands in Idaho DEIS 

36 Chapter 1. Purpose of a Need for Action 

2. Sources of public drinking water. NFS lands include watersheds that are 

important sources of public drinking water. Several Idaho Roadless Areas 

contain all or portions of municipal watersheds, which contribute drinking water 

to the citizens of Idaho. Careful management of these municipal watersheds is 

crucial in maintaining the flow and affordability of clean water to a growing 

population. The prohibitions and permissions in the Proposed Action could 

change the ability of a roadless area to provide quality sources of drinking water. 

3. Diversity of plant and animal communities. Because of the absence of roads 

and the disturbance activities that accompany them, Idaho Roadless Areas are 

more likely than roaded areas to support enhanced ecosystem health, including 

the diversity of native and desired nonnative plant and animal communities. The 

prohibitions and permissions in the Proposed Action could change the degree to 

which a roadless area provides for the 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. Idaho 

Roadless Areas are biological strongholds and refugia for many species. The 

prohibitions and permissions in the Proposed Action could change the condition 

of biological strongholds and refugia in Idaho Roadless Areas. 

5. Reference landscapes. The body of knowledge is limited with respect to the 

effects of management activities over long periods of time and on large 

landscapes. Reference landscapes, which are landscapes with minimal human 

disturbance, are a barometer for measuring the effects of development on other 

parts of the landscape. Roadless areas, because of their size, lend themselves to 

serve as reference landscapes. The prohibitions and permissions in the Proposed 

Action could change the condition and amount of reference landscapes. 

6. Primitive, semi-primitive non-motorized, and semi-primitive motorized 

classes of recreation. Idaho Roadless Areas often provide outstanding dispersed 

recreation opportunities, such as camping, canoeing, cross-country skiing, 

fishing, hiking, hunting, picnicking, and wildlife viewing. Although roadless 

areas may have many wilderness-like attributes, roadless areas often allow the 

use of mountain bikes and other mechanized means of travel, unlike wilderness 

areas. The prohibitions and permissions in the Proposed Action could change the 

type of dispersed recreation opportunities in Idaho Roadless Areas. 

7. Natural-appearing landscapes with high scenic quality. High-quality scenery, 

especially scenery with natural-appearing landscapes, is a primary reason people 

choose certain settings in which to recreate. High-quality scenery can contribute 

directly to real estate values in nearby communities and residential areas. The 

prohibitions and permissions in the Proposed Action could change the scenic 

quality in a roadless area. 
Roadless Area Conservation; National Forest System Lands in Idaho DEIS 1.7 Issues 

Chapter 1. Purpose of and Need for Action 37 

8. Traditional cultural properties and sacred sites. Traditional cultural properties 

are places, sites, structures, art, or objects that have played an important role in 

the cultural history of a group. Sacred sites are places that hold a special 

religious significance to a group. The prohibitions and permissions in the 

Proposed Action could affect traditional cultural properties and sacred sites in 

Idaho Roadless Areas. 

9. Other locally identified unique characteristics. Idaho Roadless Areas may offer 

other locally identified unique characteristics and values. Examples include 

uncommon geological formations, which are valued for their scientific and scenic 

qualities, or unique wetland complexes. The Proposed Action would not apply 

management direction to 354,100 acres of special areas that are already part of 

another land classification system. These include research natural areas, wild and 

scenic rivers, special interest areas, and others (see appendix H, table H-9); 

therefore, the Proposed Action would not affect locally identified unique 

characteristics. 

ABILITY TO ADDRESS FOREST HEALTH AND FIRE ECOLOGY

The National Fire Plan (NFP) was developed in August 2000, following a landmark 

wildland fire season (USDA Forest Service, USDI 2000). The NFP established an 

intensive, long-term hazardous fuel reduction program in response to the risks posed 

by heavy fuel loads. In 2002, President Bush initiated the Healthy Forests Initiative, and 

in 2003 the Healthy Forests Restoration Act was passed. This initiative and act were 

designed to equip land managers with additional tools to achieve long-term objectives 

in reducing hazardous fuels and restoring fire-adapted ecosystems. The prohibitions 

and permissions in the Proposed Action could affect the ability to reduce hazardous 

fuels and restore fire-adapted ecosystems in Idaho Roadless Areas. 

ABILITY TO UTILIZE MINERALS AND ENERGY RESOURCES

Portions of Idaho Roadless Areas contain important mineral and energy resources. The 

prohibitions and permissions in the Proposed Action could affect the ability to recover 

mineral and energy resources in Idaho Roadless Areas. 

SOCIAL FACTORS

Public involvement has identified competing social views of how Idaho Roadless 

Areas should be managed. These competing views can be placed in two categories: 

utilitarian or naturalist (see chapter 3, Social and Economic, for further discussion). 

The prohibitions and permissions in the Proposed Action could affect one or both of 

these views. 
1.7 Issues Roadless Area Conservation; National Forest System Lands in Idaho DEIS 

38 Chapter 1. Purpose of a Need for Action 

ECONOMIC FACTORS

The prohibitions and permissions in the Proposed Action could affect economic factors 

including timber outputs, energy and non-energy minerals, forest-dependent 

communities, and recreation special uses. 
Roadless Area Conservation; National Forest System Lands in Idaho DEIS 2.1 Introduction 

Chapter 2. Alternatives, Including the Proposed Action 39 

CHAPTER 2. ALTERNATIVES, INCLUDING THE PROPOSED 

ACTION

2.1 Introduction 

This chapter describes and compares the alternatives considered for Roadless Area 

Conservation; National Forest System Land in Idaho. It includes a description and a 

map of each alternative considered (map packet). This chapter also presents the 

alternatives in comparative form, sharply defining the differences between each 

alternative and providing the decision maker and the public with a clear basis for choice 

by the decision maker. Some of the information used to compare the alternatives is 

based on the environmental, social, and economic effects of implementing each 

alternative. 

The National Environmental Policy Act (NEPA) regulation at 40 CFR 1501.2(c) states 

that Federal agencies shall: 

Study, develop, and describe appropriate alternatives to recommended courses of 

action in any proposal which involves unresolved conflict concerning alternative 

uses of available resources.... 

The scoping process was used to: (1) identify significant issues deserving of detailed 

study (see chapter 1 for a discussion); and (2) identify unresolved conflicts associated 

with the proposed Idaho Roadless Rule (Proposed Action), which may help identify 

alternatives. All comments were reviewed to determine whether they identified 

significant issues or unresolved conflicts. 

In addition, the 2001 Roadless Area Conservation Rule (2001 Roadless Rule) and 

individual forest plans (Existing Plans) were brought forward as alternatives because 

they address many of the public’s significant issues and provide a range of reasonable 

options for managing inventoried roadless areas. 

Throughout this document, all acreage values are approximate and have been rounded. 
2.2 Alternatives Considered in Detail Roadless Area Conservation; National Forest System Lands in Idaho DEIS 

40 Chapter 2. Alternatives, Including the Proposed Action 

2.2 Alternatives Considered in Detail 

This draft environmental impact statement (EIS) examines three alternatives 

establishing regulatory direction: 

1. Direction based on the 2001 Roadless Rule (2001 Roadless Rule); 

2. Direction based on existing forest plans (Existing Plans); 

3. Direction based on the Petition, as presented to the Roadless Area Conservation 

National Advisory Committee (RACNAC) (Idaho Roadless Rule). 

The Idaho Roadless Rule recommends Idaho Roadless Areas be managed within a 

spectrum of five management themes: Wild Land Recreation, Primitive, Special Areas 

of Historic and Tribal Significance, Backcountry/Restoration, and General Forest, 

Rangeland and Grassland. To aid in analyzing effects and to better compare 

alternatives, the management prescriptions in the 2001 Roadless Rule and Existing 

Plans were placed in a management theme that would be the closest equivalent 

(appendix B). Table 2-1 describes each theme’s management emphasis and the number 

of acres represented by that theme, by alternative. To account for all acreage identified 

as a roadless area, the table lists other forest plan special areas (FPSA), which are not 

affected by this proposed rule (appendix H, table H-9). 

Table 2-1. Number of acres represented by Idaho Roadless Rule themes and equivalent themes for the 2001 

Roadless Rule and Existing Plans 

Theme 

2001 

Roadless Rule Existing Plans 

Idaho Roadless 

Rule 

Wild Land Recreation. These lands would show little evidence 

of human-caused disturbance and natural conditions and 

processes would be predominant 

0 1,320,800 1,378,600 

Primitive. These lands would remain relatively undisturbed by 

human management activities while allowing for limited forest 

health activities including preserving biological strongholds for 

a variety of species and protecting ecological integrity. 

0 2,131,400 1,656,300 

Special Areas of Historic and Tribal Significance. 

These areas would remain relatively undisturbed by human 

management activities in order to maintain their unique Tribal 

or historic characteristics 

0 0 68,600 

Backcountry/Restoration. These areas would retain their 

undeveloped character, while providing a variety of recreation 

opportunities, and allowing for limited forest health activities, 

including preserving biological strongholds for a variety of 

species, and maintaining or restoring the characteristics of 

ecosystem and structure. 

9,304,200 4,244,500 5,246,100 

General Forest, Rangeland, and Grassland. These areas 

would provide a variety of goods and services as well as a 

broad range of recreational opportunities, and conservation of 

natural resources. 

0 1,262,400 609,500 

Other lands* 

Forest plan special areas ( appendix H, table H-9) 0 345,100 345,100 

Totals 9,304,200 9,304,200 9,304,200 

* The Idaho Roadless Rule would not apply to these other special areas. 
Roadless Area Conservation; National Forest System Lands in Idaho DEIS 2.2 Alternatives Considered in Detail 

Chapter 2. Alternatives, Including the Proposed Action 41 

The following subsections describe each alternative and how it relates to the five 

management themes identified in the proposed Idaho Roadless Rule. Each alternative 

addresses only management actions associated with timber cutting, road 

construction/reconstruction, or future discretionary mineral-related actions for saleable 

or leasable minerals, because the Petition, similar to other efforts, has identified these 

particular activities as having the greatest likelihood of altering roadless area values 

and characteristics. Road construction/reconstruction or timber cutting under any 

alternative would be designed based on applicable forest plan standards and guidelines 

(for example, protection of riparian areas or habitat needs for species). 

ALTERNATIVE 1. THE 2001 ROADLESS RULE (NO ACTION)

10

This alternative presents a roadless area management regime based on the approach set 

out in the 2001 Roadless Rule (See 36 CFR, 294, Subpart B [2004]; 66 Fed. Reg. 3244 [Jan. 

12, 2001]). The purpose of the 2001 Roadless Rule was to ensure that inventoried 

roadless areas sustain their values for this generation and for future generations. By 

sustaining these values, a continuous flow of benefits associated with healthy 

watersheds and ecosystems was expected. 

Timber cutting activities and road construction/reconstruction were identified as 

having the greatest likelihood of altering and fragmenting landscapes, and the greatest 

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

characteristics. The 2001 Roadless Rule was the product of a national process and 

established management direction at the national level with limited focus on State or 

local issues. 

Theme assignment. Management direction in the 2001 Roadless Rule is generally 

equivalent to the Backcountry/Restoration theme in the proposed Idaho Roadless Rule 

and applies to all 9.3 million acres of Idaho Roadless Areas. 

Timber cutting, sale, or removal. The 2001 Roadless Rule prohibits timber cutting, sale, 

or removal in inventoried roadless areas except as provided in the following situations: 

1a. To improve threatened, endangered, proposed, or sensitive species habitat; 

1b. To maintain or restore the characteristics of ecosystem composition and 

structure, such as to reduce the risk of uncharacteristic wildfire effects, which 

would be expected to occur under natural disturbance regimes of the current 

climatic period; 

2. When timber cutting is incidental to the implementation of a management 

activity not otherwise prohibited; 

3. For personal or administrative use; 

 

10 As of the printing of this draft EIS, the 2001 Roadless Rule is in operation by court order and represents 

the legal status quo and operating management direction for these lands. In the absence of the 2001 

Roadless Rule, management would be governed by each forest’s land management plan and any 

applicable agency interim direction. 
2.2 Alternatives Considered in Detail Roadless Area Conservation; National Forest System Lands in Idaho DEIS 

42 Chapter 2. Alternatives, Including the Proposed Action 

4. Where roadless characteristics have been substantially altered in a portion of the 

roadless area because of the construction of a classified road and subsequent 

timber harvest. 

Road construction/reconstruction. The 2001 Roadless Rule prohibits road construction 

and reconstruction in inventoried roadless areas except as provided in the following 

situations: 

1. A road is needed to protect 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; or 

2. 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 CERLA, section 311 of the 

Clean Water Act, or the Oil Pollution Act; or 

3. A road is needed pursuant to reserved or outstanding rights or as provided for 

by statute, treaty; or 

4. Road realignment is needed to prevent irreparable resource damage that arises 

from the design, location, use or deterioration of a road and cannot be mitigated 

by road maintenance. Road realignment may occur under this paragraph only if 

the road is deemed essential for public or private access, natural resource 

management, or public health or safety. 

5. Road construction is needed to implement a road safety improvement project on 

a classified road determined to be hazardous based on accident experience or 

accident potential on that road; or 

6. The Secretary of Agriculture determines that a Federal aid highway project, 

authorized pursuant to Title 23 of the U.S. Code (23 USC), is in the public interest 

or is consistent with the purpose for which the land was reserved or acquired 

and no other reasonable and prudent alternatives exists; or 

7. In conjunction with the continuation, extension, or renewal of an existing mineral 

lease on lands that are under lease by the Secretary of the Interior as of January 

12, 2001, or for a 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 lease 

requirements, land and resource management plan direction, regulations, and 

laws. Roads constructed or reconstructed pursuant to this paragraph must be 

obliterated when no longer needed for the purposes of the lease or upon 

termination or expiration of the lease, whichever is sooner. 

Maintenance of classified roads is permissible in inventoried roadless areas. 
Roadless Area Conservation; National Forest System Lands in Idaho DEIS 2.2 Alternatives Considered in Detail 

Chapter 2. Alternatives, Including the Proposed Action 43 

Mineral activities. The 2001 Roadless Rule provides for the construction or 

reconstruction of roads when needed in conjunction with the continuation, extension, or 

renewal of a mineral lease in existence as of January 12, 2001. Further, the rule allows 

for road construction or reconstruction in the case of reserved or outstanding rights, or 

as provided for by statute or treaty. This would include roads associated with locatable 

mineral activities pursuant to the General Mining Law of 1872. The 2001 Roadless Rule 

prohibits road construction and reconstruction associated with new mineral leases 

(after January 12, 2001) or to access mineral materials. 

The 2001 Roadless Rule would allow surface occupancy for mineral leasing activities if 

roads were not required; it also would allow for the sale of mineral materials in all 

Idaho Roadless Areas. 

Ability to change roadless area boundaries. Although the 2001 Roadless Rule mentions 

subsequent update or revision to inventoried roadless area maps, no specific change 

provision was provided in the rule. 

ALTERNATIVE 2. EXISTING PLANS

Management direction in this alternative represents a roadless area management 

regime based on each forest’s land and resource management plan (forest plan). Each 

forest’s plan is unique to its planning area; collectively the forest plans provide a broad 

range of management from wilderness to intensive management. Overall, as national 

forests have revised their forest plans, the trend has been to move more roadless areas 

into management prescriptions that conserve roadless characteristics. When developing 

or revising their forest plans, each forest or group of forests collaborates with the public 

and interested parties to develop management direction for their roadless areas. 

In Idaho, five forests have revised their plans since 1997.11 Revisions of seven other 

forest plans within Idaho are ongoing12 and are unlikely to be finalized prior to this 

rule. 

Generally, forest plans allow or limit an array of activities in roadless areas. To help 

compare alternatives, the management prescriptions in the existing plans were placed 

in the management themes that would be the closest equivalent to those set forth in the 

Petition. 

Theme assignment. The following subsections describe how management prescriptions 

in Existing Plans corresponds to the proposed Idaho Roadless Rule themes. Not all 

management prescriptions in Existing Plans correspond exactly with the themes; for 

example, some prescriptions may limit road construction for some activities in General 

Forest, Rangeland, and Grassland, or in Backcountry/Restoration, whereas the 

proposed Idaho Roadless Rule does not. For a comparison of the Idaho Roadless Rule 

with the management prescriptions for each national forest, see appendix B. 

 

11 Boise, Caribou, Payette, Sawtooth, Targhee. 

12 Challis, Clearwater, Idaho Panhandle, Kootenai, Nez Perce, Salmon, Wallowa Whitman. 
2.2 Alternatives Considered in Detail Roadless Area Conservation; National Forest System Lands in Idaho DEIS 

44 Chapter 2. Alternatives, Including the Proposed Action 

Forest plan special areas (appendix H, table H-9) include management direction 

associated with research natural areas; wild and scenic rivers (designated, eligible, and 

suitable); special interest areas; and other unique areas. The proposed Idaho Roadless 

Rule would not apply to the 345,100 of forest plan special areas embedded in Idaho 

Roadless Areas. 

Wild Land Recreation 

Areas recommended for wilderness designation in Existing Plans are equivalent to the 

Wild Land Recreation theme; therefore, limited activities are allowed. Road 

construction/reconstruction is prohibited except when provided by statute or treaty, or 

pursuant to valid existing rights or other legal duty of the United States. Timber cutting 

is permitted only where it would be incidental to other activities (such as trail 

construction). Approximately 1,320,800 acres recommended as wilderness would be 

managed in a manner comparable to the Wild Land Recreation theme set out in the 

Idaho Roadless Rule. 

Primitive 

The Primitive theme lands most closely resemble areas managed for non-motorized 

backcountry recreation. Timber cutting may be done on a very limited basis and in 

response to a threat13 (for example, insect and disease, windstorms, hazardous fuels). 

Typically, no road construction/reconstruction is allowed except in some cases to access 

valid existing rights or minerals (locatable, leasable, and saleable). Approximately 

2,131,400 acres would be managed in a manner comparable to the Primitive theme. 

Backcountry/Restoration (Backcountry) 

Backcountry/Restoration (Backcountry) areas would typically be managed for other 

resource benefits, such as wildlife or recreation, not typically including timber 

production. However, some prescriptions have dual objectives—timber production and 

consideration of wildlife resources. Timber cutting is allowed, usually to a lesser extent 

than would be allowed in General Forest, Rangeland and Grassland, when conducted 

for other resource benefits. Road construction/reconstruction may be allowed under 

certain circumstances, but typically includes substantial restrictions, such as road 

closures or use of temporary roads. Existing Plans call for approximately 4,244,500 acres 

to be managed in a manner similar to the Backcountry theme. 

General Forest, Rangeland, or Grassland (GFRG) 

Existing Plans direct that certain areas—represented by the General Forest, Rangeland, 

or Grassland (GFRG) theme—be managed to provide a variety of goods and services 

and a broad range of recreational opportunities, and also to ensure adequate flexibility 

to maintain forest, rangeland, and grassland health. These areas may be managed for 

 

13 Reference the Healthy Forests Restoration Act of 2003 (P.L. 108-148). 
Roadless Area Conservation; National Forest System Lands in Idaho DEIS 2.2 Alternatives Considered in Detail 

Chapter 2. Alternatives, Including the Proposed Action 45 

timber production, where intensive forest management would be expected, including 

associated road construction/reconstruction. Existing Plans call for approximately 

1,262,400 acres to be managed in a manner similar to the GFRG theme. 

Mineral activities. Mineral resources are addressed in each of the equivalent themes in a 

variety of ways under Existing Plans, from limited to full development (see appendix B). 

Ability to change roadless area boundaries. In the absence of the 2001 Roadless Rule or 

other regulatory direction, forest plans could create, delete, or amend inventoried 

roadless areas through plan amendment or revision. 

ALTERNATIVE 3. IDAHO ROADLESS RULE14 (PROPOSED ACTION) 

The Proposed Action represents a strategy for the conservation and management of 

Idaho Roadless Areas that takes into account State and local situations and unique 

resource management challenges, while it recognizes and integrates the national 

interest in maintaining roadless characteristics. 

Building from each forest’s existing or proposed forest plan15, the proposed Idaho 

Roadless Rule assigned individual roadless areas within five broad management 

themes: Wild Land Recreation, Special Areas of Historic or Tribal Significance, 

Primitive, Backcountry/Restoration, and General Forest, Rangeland and Grassland. 

These themes span a continuum (fig. 1-1) that includes at one end, a restrictive 

approach emphasizing passive management and natural restoration approaches, and 

on the other end, active management designed to accomplish sustainable protection of 

roadless characteristics. The continuum accounts for stewardship of the uniqueness of 

each individual roadless area’s landscape and the quality of roadless characteristics in 

that area. 

The Idaho Roadless Rule does not apply to other special areas (referred to as “forest 

plan special areas” such as research natural areas; wild and scenic rivers (designated, 

eligible, and suitable); special interest areas; visual corridors, and the like (table 2-1 and 

appendix H)). These areas would be managed according to applicable current and 

future forest plan direction. These lands are included in the discussion for sake of 

completeness; however, the Proposed Action does not recommend management 

direction for the 345,100 acres found in these lands. 

Allocation to a specific theme is not intended to mandate or direct the Forest Service to 

propose or implement any action; rather the themes provide an array of permitted and 

prohibited activities related to timber cutting, sale, and removal; road 

construction/reconstruction; and discretionary mineral activities. 

 

14 The Idaho Roadless Rule includes clarifications made by Governor Risch at the November 29 and 30, 

2007, RACNAC meeting. Updates are reflected in appendix H. 

15 Existing plans referred to here include the Boise, Caribou, Challis, Payette, Salmon, Sawtooth, Caribou, 

Wallow-Whitman. Proposed plans referred to here are the Clearwater, Idaho Panhandle, Kootenai, Nez 

Perce. 
2.2 Alternatives Considered in Detail Roadless Area Conservation; National Forest System Lands in Idaho DEIS 

46 Chapter 2. Alternatives, Including the Proposed Action 

As in the 2001 Roadless Rule, timber cutting and road construction/reconstruction are 

identified as the management activities having the greatest potential for altering 

landscapes and causing immediate changes to roadless values and characteristics. 

The Proposed Action also establishes prohibitions and permissions for discretionary 

mineral activities because of potential effects on roadless characteristics. Further, the 

Proposed Action allows for road construction/reconstruction in the case of reserved or 

outstanding rights, or as provided for by statute or treaty. This would include roads 

associated with locatable mineral activities pursuant to the General Mining Law of 1872. 

Finally, the Proposed Action provides additional direction regarding common variety 

minerals, which are the sole discretion of the Secretary of Agriculture (Secretary) to 

manage. 

Again, like the 2001 Roadless Rule, the Proposed Action does not seek to restrict 

retroactively any existing mineral authorizations16. However, the Proposed Action 

would establish limitations on the future exercise of discretion available to Forest 

Service line officers. It does not seek to impose restrictions on decision-making that 

Congress has assigned to the Department of the Interior. The Proposed Action also does 

not affect or seek a withdrawal of the mineral estate; such matters are subject to a 

separate statutory process established in the Federal Land Policy Management Act 

(FLPMA). Instead, the Proposed Action seeks direction to be applied where Forest 

Service line officers have discretionary authority to influence whether and how the 

activity may occur. 

The Proposed Action does not address grazing, travel management, or wildland fire 

use. Management direction related to those activities would be regulated by other 

existing regulatory and analytical processes (for example, travel planning). 

The following subsections describe each theme’s desired condition, management intent, 

acres, and specific permissions and prohibitions. 

Wild Land Recreation (WLR) 

A classification of an Idaho Roadless Area assigned to lands that were generally 

identified during the forest planning process as recommended for wilderness 

designation. These lands would show little evidence of human-caused disturbance and 

natural conditions and processes would be predominant. 

Approximately 1,378,600 acres have been identified for inclusion as Wild Land 

Recreation areas. 

Timber cutting, sale, or removal. Prohibited except for personal or administrative use; 

or where incidental to other management actions (such as trail clearing). 

 

16 Mineral authorizations include those for saleable, leasable, and locatable minerals. 
Roadless Area Conservation; National Forest System Lands in Idaho DEIS 2.2 Alternatives Considered in Detail 

Chapter 2. Alternatives, Including the Proposed Action 47 

Road construction/reconstruction. Prohibited except when provided by statute or 

treaty, or pursuant to reserved or outstanding rights or other legal duty of the United 

States. 

Mineral activities. No recommendation, authorization, or consent to surface 

occupancy, or road construction or reconstruction associated with new mineral leases. 

The sale of common variety minerals would be prohibited. Locatable mineral activities 

pursuant to the General Mining Law of 1872, including road construction and 

reconstruction, would not be affected. 

Primitive 

A classification of an Idaho Roadless Area that would be managed to remain relatively 

undisturbed by human management activities while allowing for limited forest health 

activities including preserving biological strongholds for a variety of species and 

protecting the ecological integrity. 

Approximately 1,656,300 acres are identified for inclusion as Primitive. 

Timber cutting, sale, or removal. Prohibited unless existing roads or aerial systems are 

used and the responsible official determines that: 

1. The cutting, sale, or removal of timber would maintain or improve one or more 

of the roadless characteristics and is needed for one of the following purposes: 

a. To improve threatened, endangered, proposed, or sensitive species habitat; or 

b. To maintain or restore the characteristics of ecosystem composition and 

structure or to reduce the significant risk of wildland fire effects; or 

2. The cutting, sale or removal of timber is: 

a. Personal or administrative use (36 CFR §223); or 

b. Incidental to the implementation of a management activity not otherwise 

prohibited (e.g., trail clearing). 

The wording for exception (1)a. is modified from the 2001 Roadless Rule. The 2001 

Roadless Rule uses the terms “reduce the risk of uncharacteristic wildfire effects, within 

the range of variability that would be expected to occur under natural disturbance 

regimes of the current climatic period;” the proposed Idaho Roadless Rule uses the 

terms “or to reduce the significant risk of wildland fire effects.” The change in language 

is focused on allowing activities, when necessary and dictated by site-specific 

circumstance, to perform hazardous fuel treatment in Primitive areas at significant risk 

of wildland fire. It is anticipated that timber cutting would be very infrequent in the 

Primitive theme. 

Treatments would be designed based on site-specific needs to reduce any significant 

risks or to trend toward historic range of conditions. Determination of significant risk 

would be guided by the interagency Healthy Forests Initiative and Healthy Forests 

Restoration Act: Interim Field Guide (USDA Forest Service, USDI BLM 2004). 
2.2 Alternatives Considered in Detail Roadless Area Conservation; National Forest System Lands in Idaho DEIS 

48 Chapter 2. Alternatives, Including the Proposed Action 

Road construction/reconstruction. Prohibited except when provided by statute or 

treaty, or pursuant to reserved or outstanding rights or other legal duty of the United 

States. 

Mineral activities. No recommendation, authorization, or consent to surface occupancy 

or road construction or reconstruction associated with new mineral or energy leases. 

The sale of common variety minerals would be prohibited. Locatable mineral activities 

pursuant to the General Mining Law of 1872, including road construction and 

reconstruction, would not be affected. 

Special Areas of Historic or Tribal Significance (SAHTS) 

A classification of an Idaho Roadless Area managed to be relatively undisturbed by 

human management activities in order to maintain their unique Tribal or historic 

characteristics. 

This theme consists of three areas: 

1. Pilot Knob located within the Pilot Knob (#849) Roadless Area on the Nez Perce 

National Forest; 

2. Nimiipuu and Lewis and Clark National Historic Trails located within the 

Bighorn-Weitas (#306), Eldorado Creek (#312), Hoodoo (#301), North Lochsa 

Slope (#307), and Weir-Post Office Creek (#308) Roadless Areas on the 

Clearwater National Forest; and 

3. The Pioneer Area located within the Mallard Larkins (#300) Roadless Area on the 

Idaho Panhandle National Forest. 

Lands within the SAHTS theme would be managed the same as the Primitive theme. 

Approximately 68,600 acres have been identified for inclusion as SAHTS. 

Backcountry/Restoration (Backcountry or BCR) 

The Backcountry theme would be managed to retain the undeveloped character, while 

providing a variety of recreation opportunities, and allowing for limited forest health 

activities, including preserving biological strongholds for a variety of species, and 

maintaining or restoring the characteristics of ecosystem composition and structure. 

Approximately 5,246,100 acres have been identified for inclusion as Backcountry. 

Timber cutting, sale, or removal. As in the 2001 Roadless Rule (with one modification), 

timber cutting, sale, or removal is permissible under the following circumstances: 

1. The cutting, sale, or removal of timber would maintain or improve one or more 

of the roadless characteristics and is needed for one of the following purposes: 

a. To improve threatened, endangered, proposed, or sensitive species habitat; or 

b. To maintain or restore the characteristics of ecosystem composition and 

structure or to reduce the significant risk of wildland fire effects; or 

2. The cutting, sale or removal of timber is: 
Roadless Area Conservation; National Forest System Lands in Idaho DEIS 2.2 Alternatives Considered in Detail 

Chapter 2. Alternatives, Including the Proposed Action 49 

a. Personal or administrative use (36 CFR §223); or 

b. Incidental to the implementation of a management activity not otherwise 

prohibited (e.g., trail clearing 

c. It is within a substantially altered portion of an Idaho Roadless Area 

designated as Backcountry/Restoration, which has been altered because of 

the construction of a forest road and subsequent timber harvest. 

The wording for exception (1)a. is modified from the 2001 Roadless Rule. The 2001 

Roadless Rule uses the terms “reduce the risk of uncharacteristic wildfire effects, within 

the range of variability that would be expected to occur under natural disturbance 

regimes of the current climatic period”; the proposed Idaho Roadless Rule uses the 

terms “or to reduce the significant risk of wildland fire effects.” As with the Primitive 

theme, the change in language is focused on allowing activities, when necessary and 

dictated by site-specific circumstance to perform hazardous fuel treatment in 

Backcountry areas at significant risk of wildland fire. It is anticipated that timber cutting 

would be infrequent in the Backcountry theme, focusing on what is left behind versus 

what is removed. 

Treatments would be designed based on site-specific needs to reduce any significant 

risks or to trend toward historic range of conditions. Determination of significant risk 

would be guided by the interagency Healthy Forests Initiative and Healthy Forests 

Restoration Act: Interim Field Guide (USDA Forest Service, USDI BLM 2004). 

Road construction/reconstruction. Much like the 2001 Roadless Rule, road construction 

and reconstruction would be permissible if one or more of the following are met: 

1. A road is needed to protect public health and safety in cases of significant risk or 

imminent threat of flood, fire, or other catastrophic event that, without 

intervention, would cause the loss of life or property, or to facilitate forest health 

activities permitted under timber cutting, sale, or removal (1) above; 

2. 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; or 

3. A road is needed pursuant to statute, treaty, reserved or outstanding rights, or 

other legal duty of the United States; or 

4. Road realignment is needed to prevent resource damage that arises from the 

design, location, use, or deterioration of a road and cannot be mitigated by road 

maintenance. Road realignment may occur only if the road is deemed essential 

for public or private access, natural resource management, or public health and 

safety; or 

5. Road construction is needed to implement a road safety improvement project on 

a road that has been determined to be hazardous based on accident experience or 

accident potential on that road; or 
2.2 Alternatives Considered in Detail Roadless Area Conservation; National Forest System Lands in Idaho DEIS 

50 Chapter 2. Alternatives, Including the Proposed Action 

6. The Secretary of Agriculture determined that a Federal aid highway project, 

authorized pursuant to Title 23 of the U.S. Code (23 USC), is in the public interest 

or is consistent with the purpose for which the land was reserved or acquired 

and no other reasonable and prudent alternative exists; or 

7. A road is needed in conjunction with activities permissible under the limited 

mineral exceptions for Backcountry. 

Under (1) above, the phrase “significant risk” is an addition to “imminent threat” which 

is the phrasing in the 2001 Roadless Rule. In addition the phrase “or to facilitate forest 

health activities permitted under timber cutting, sale, or removal” was added. The 

change in the text is focused on allowing forest health activities when necessary and 

dictated by site-specific circumstance to perform expedited hazardous fuel treatment in 

Backcountry areas at significant risk of wildfire and insect and disease epidemics. The 

Forest Service and State do no intend this change in language to be construed as giving 

permission to build roads in areas designated as Backcountry for the purpose of 

engaging in routine forest management activities as denoted by the use of the words 

“significant risk”. The addition is intended to provide additional flexibility where sitespecific conditions pose a significant risk of wildland fire. 

Although the principle objective for this adjustment is to protect at-risk communities 

and municipal water supply systems from adverse effects of wildland fire, this 

provision also contemplates access for: (1) areas where wind throw, blowdown, ice 

storm damage, or the existence or imminent threat of an insect or disease epidemic is 

significantly threatening ecosystem components or resource values that may contribute 

to significant risk of wildland fire; and (2) areas where wildland fire poses a threat to, 

and where the natural fire regimes are important for, threatened and endangered 

species or their habitat, consistent with the Healthy Forests Restoration Act (HFRA P.L 

108-148). 

New roads that would be constructed would be temporary, unless the responsible 

official17 determines that a permanent road meets the exceptions above and the addition 

of a forest road would not substantially alter roadless characteristics. 

Mineral activities. No recommendation, authorization, or consent to road construction 

or reconstruction associated with new mineral leases, except such road construction or 

reconstruction may be authorized in association with phosphate leasing. Leasing 

instruments that allow surface use or occupancy are permissible if they do not require 

road construction or reconstruction. Locatable mineral activities pursuant to the 

General Mining Law of 1872 would not be affected, including road construction and 

reconstruction. 

The Forest Service would not authorize sale of common variety mineral materials, but 

may authorize the use or sale of common variety minerals, and associated road 

 

17 Responsible official in this context refers to the Forest Service line officer responsible for making the 

site-specific decision. 
Roadless Area Conservation; National Forest System Lands in Idaho DEIS 2.2 Alternatives Considered in Detail 

Chapter 2. Alternatives, Including the Proposed Action 51 

construction or reconstruction to access these minerals if the use of these minerals is 

incidental to activity allowed under this rule. 

General Forest, Rangeland, and Grassland (GFRG) 

A classification of an Idaho Roadless Area that would be managed to provide a variety 

of goods and services as well as a broad range of recreational opportunities, and 

conservation of natural resources. The GFRG theme includes lands that are forested, 

rangeland or grassland. About 240,000 acres of the GFRG theme are non-forest. 

Road construction/reconstruction and timber cutting would be permissible and there 

would be no prohibitions on mineral activities except as addressed in existing or 

proposed forest plans. 

When allowed under this theme or the Backcountry theme, road construction or 

reconstruction associated with mining activities would be conducted in a manner that 

minimizes effects on surface resources, prevents unnecessary or unreasonable surface 

disturbances, and complies with all applicable lease requirements, forest plan direction, 

regulations, and laws. Roads constructed or reconstructed would be decommissioned 

when they are no longer needed or when the lease, contract, or permit expires, 

whichever is sooner. 

Ability to change Idaho Roadless Area management. The Proposed Action would 

provide for a process for administrative corrections, as well as other modifications to 

the management of Idaho Roadless Areas in response to changed conditions or other 

need. 

Administrative corrections include, but are not limited to, adjustments that remedy 

clerical, typographical, mapping errors, or improvements in mapping technology. 

Administrative corrections would not require a particular process and would be 

effective upon public notice. 

The Chief of the Forest Service may add, remove, or modify the designations and 

management classifications based on changed circumstances or public need. 

Modifications would be made only after public notice, and those deemed significant 

would require public involvement comparable to rulemaking—that is, notice and 

comment. Factors to be considered in assessing significance include location and size, 

degree of change, and the purpose of the modification. Non-significant modifications 

would require a minimum 30-day public notice prior to becoming effective. 

Examples when rulemaking would not be expected include the following: (1) 

establishment by the Forest Service of a research natural area in a roadless area 

designated as Primitive; (2) redesignation of a small portion of Backcountry adjacent to 

a large block of GFRG into the GFRG theme; (3) redesignation of a small portion of the 

Backcountry theme adjacent to a large block of Primitive into the Primitive theme. 

Examples when rulemaking would be expected include the following: (1) approving the 

use of lands designated as Primitive to construct and operate an all-season resort 
2.2 Alternatives Considered in Detail Roadless Area Conservation; National Forest System Lands in Idaho DEIS 

52 Chapter 2. Alternatives, Including the Proposed Action 

complex; (2) geothermal exploration has discovered a significant energy field in an area 

designated as Primitive and the Forest Service proposes that a portion of the roadless 

area be designated as GFRG to allow development and transmission line corridors; (3) 

during forest plan revision, the Forest Service recommends two primitive areas for 

wilderness designation and consequently proposes their themes be changed to Wild 

Land Recreation. 
Roadless Area Conservation; National Forest System Lands in Idaho DEIS 2.3 Consideration of Comments 

Chapter 2. Alternatives, Including the Proposed Action 53 

2.3 Consideration of Comments 

Federal agencies are required by NEPA to rigorously explore and objectively evaluate 

reasonable alternatives and to briefly discuss the reasons for eliminating alternatives 

that were not developed in detail (40 CFR 1502.14)18. People who commented during 

scoping suggested a number of different alternatives that reflect their values and 

preferred management options. The suggestions generally fall into four primary 

categories: 

1. Distribution of management themes; 

2. Additional conservation measures for GFRG; 

3. Additional limitations; 

4. Additional access. 

The following subsections describe these suggestions and how they were considered. 

DISTRIBUTION OF MANAGEMENT THEMES

Some people requested the acreage of GFRG be reduced. This suggestion is reflected 

in the 2001 Roadless Rule (alternative 1, No Action), which would have no lands in a 

management theme similar to GFRG. The Proposed Action would have 609,500 above 

the 2001 Roadless Rule in GFRG and the Existing Plans (alternative 2) would place 

1,262,400 acres into GFRG. This spread of acreage represents a range of reasonable 

alternatives that provides a clear and sharply defined choice among the alternatives. 

Some people requested areas that serve as key habitats for threatened and 

endangered listed salmon and trout be identified and be placed into a Wild Land 

Recreation or Primitive theme. The request reflects a desire for protections currently in 

place in all alternatives. Under the Endangered Species Act (ESA), agencies seek to 

conserve threatened and endangered species through a variety of programs and 

mechanisms. Further, listed salmon and trout are protected in these areas through 

additional means, such as the Interim Strategy for Managing Anadromous Fishproducing Watersheds in Eastern Oregon and Washington, Idaho, and Portions of 

California (PACFISH) and the Inland Native Fish Strategy (INFISH), as well as other 

direction in existing plans (USDA Forest Service and USDI BLM, 1995; and USDA 

Forest Service, 1995). 

 

18 General criteria for eliminating requests for additional management direction from detailed study 

included: 

1. Management direction would not meet the purpose and need; 

2. Management direction is not within the authority of the Forest Service; 

3. Management direction is conjectural in nature or not supported by scientific evidence; 

4. Management direction is already reflected in an alternative or does not contain a magnitude of 

change that provides a sharply different approach; or 

5. Management direction does not pertain to Idaho Roadless Areas. 
2.3 Consideration of Comments Roadless Area Conservation; National Forest System Lands in Idaho DEIS 

54 Chapter 2. Alternatives, Including the Proposed Action 

Of the 250 roadless areas, portions of 14 roadless areas, (appendix L, tables L-6 and L-7) 

are priority watersheds for listed Chinook salmon, steelhead, and bull trout. Under the 

proposed Idaho Roadless Rule, none of these roadless areas would have GFRG. Most 

lands were placed in the Backcountry theme, which emphasizes preserving biological 

strongholds. 

Some people requested the Wild Land Recreation theme be changed to Backcountry. 

This suggestion is reflected in the 2001 Roadless Rule, since all lands under the rule are 

managed similar to the Backcountry theme. Lands recommended for wilderness 

through forest plans would continue to be managed to maintain their wilderness 

characteristics. 

ADDITIONAL CONSERVATION MEASURES FOR GFRG

Some people requested that additional protections be incorporated into the GFRG 

theme for stream segments with limited water quality, municipal watersheds, and 

habitats for threatened, endangered, and sensitive plant and animal species. This 

request would require the establishment of specific management direction for each of 

these resource areas. This type of direction is better addressed in forest plans because 

none of these elements are unique to roadless areas; therefore, this request is outside of 

the scope of the EIS. In the context of specific issues, these resource areas may be found 

outside as well as inside roadless areas. Management direction in existing and proposed 

plans generally provides direction for activities that occur in sensitive areas. In addition, 

laws and regulations such as the Clean Water Act and ESA provide further direction. 

All actions must adhere to these requirements. The purpose of this Proposed Action is 

not to determine the management direction for activities designed to meet other 

resource needs, but to determine what timber cutting, road 

construction/reconstruction, and discretionary mineral activities will be allowed in 

roadless areas. 

ADDITIONAL LIMITATIONS

Some people asked for an alternative that imposes even stricter limitations on Idaho 

Roadless Areas than the 2001 Roadless Rule. The request does not provide further 

details; therefore, the Idaho Roadless Rule would meet this request, because it imposes 

stricter limitations than would the 2001 Roadless Rule on lands managed as Wild Land 

Recreation, encompassing about 1.378 million acres. These are areas where people can 

find outstanding opportunities for recreation, including exploration, solitude, risk, and 

challenge. In addition, the proposed Idaho Roadless Rule would impose stricter 

limitations for road construction on lands managed as Primitive or SAHTS, 

encompassing about 1.72 million acres. These are areas where people can find primitive 

recreation opportunities or areas of special historical or cultural significance. 

To designate all the Idaho Roadless Areas to either of these themes would not meet the 

purpose and need to take into account State and local situations and unique resource 
Roadless Area Conservation; National Forest System Lands in Idaho DEIS 2.3 Consideration of Comments 

Chapter 2. Alternatives, Including the Proposed Action 55 

management challenges while recognizing and integrating the national interest in 

maintaining roadless characteristics while providing for management flexibility. 

A similar request was also brought forward in the development of the 2001 Roadless 

Rule, where it was rejected because the scope of prohibited actions considered in detail 

was limited to timber harvest and road construction/reconstruction because these 

activities pose disproportionately greater risks of altering and fragmenting natural 

landscapes at regional and nation scales (USDA Forest Service, 2000 Vol. 1, 1-15 to 1-16). 

Further, a similar request was made during the development of the Petition and was 

rejected, because it does not address uniqueness of each individual roadless area’s 

landscapes and the quality of roadless characteristics in that area. 

Some people asked to limit the exceptions that allow for logging and road 

construction. The request does not provide further details on the kinds or levels of 

limitations that should be implemented. As noted in the above response, when 

compared to the 2001 Roadless Rule, additional limitations for logging and road 

construction are provided in the Wild Land Recreation, Primitive, and SAHTS; 

therefore, the Idaho Roadless Rule addresses this request. 

Some people asked to limit logging to fuels reduction in the wildland–urban 

interface (WUI). The proposed Idaho Roadless Rule would allow for timber cutting, 

sale, or removal of timber to maintain roadless characteristics by improving threatened, 

endangered, proposed, or sensitive species or by maintaining or restoring ecosystem 

composition and structure; to reduce the significant risk of wildfire effects; for 

administrative and personal use; when the activity is incidental to other allowed 

management activities, such as trail construction; and when a roadless area had been 

substantially altered by previous timber harvest activities. Any of these circumstances 

could occur outside the WUI. 

Limiting these activities to the WUI would not meet the purpose and need to maintain 

roadless characteristics—including providing habitat for threatened, endangered, 

proposed, candidate, and sensitive species and protecting flows of public drinking 

water from critical watersheds—taking into account State and local situations and 

unique resource management challenges while providing for management flexibility. 

The Coeur d’Alene Tribe requested that all Idaho Roadless Areas within the Tribe’s 

aboriginal territory (AT) be managed primarily to maintain water quality, native fish 

and wildlife, and plant diversity. Landscape diversity and watershed function should 

be maintained through natural ecological processes. 

The 2001 Roadless Rule reflects this request and will be evaluated in the EIS. 

The Tribe further requested that ecological and watershed functions should be 

protected by an expanding buffer of restored lands. The restoration buffers would be 

intended to protect ecological processes and functions within the roadless areas from 

degradation from surrounding landscapes, which have been extensively altered by 

past timber harvest and road building. Within the restoration buffers active 
2.3 Consideration of Comments Roadless Area Conservation; National Forest System Lands in Idaho DEIS 

56 Chapter 2. Alternatives, Including the Proposed Action 

management may be use to control invasive weed species, reduce fuels, or control 

insects and disease. No permanent roads should be allowed. Existing roads should be 

maintained or reconstructed as needed to support restoration efforts. Resource 

extraction should be incidental to watershed restoration. 

The proposed Idaho Roadless Rule, and the decision framework associated with the 

proposed rule, applies only to lands within Idaho Roadless Areas. This request would 

expand the scope of the proposed rule; therefore, because it is outside of the scope of 

this draft EIS, it will not be considered in detail. Management direction outside Idaho 

Roadless Areas is reflected in forest plans. The Idaho Panhandle, Clearwater, and Nez 

Perce National Forests are in the process of revising their plans. This request should be 

provided to these forests during the revision process. 

Some people requested that locatable (hard rock) and leasable mining (oil, gas, 

phosphate, etc.) be prohibited in all roadless areas. Others requested that all roadless 

lands be withdrawn from these activities. 

Like the 2001 Roadless Rule, the proposed rule does not seek to impose any limits 

regarding activities undertaken regarding locatable minerals, because these are 

considered non-discretionary actions and are subject to requirements under the General 

Mining Law of 1872. A decision to withdraw all Idaho Roadless Areas from mineral 

entry is outside the jurisdiction of the Forest Service and is at the discretion of the 

Department of the Interior, subject to environmental analysis and public involvement 

process. Further, such a restriction would not meet the purpose and need, which 

presents a strategy for the conservation and management of Idaho Roadless that takes 

into account State and local situations and unique resource management challenges. 

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. As with locatable 

minerals, pursuing a complete withdrawal from leasing would not meet the purpose 

and need. 

Some people requested road construction be limited to temporary roads. 

The proposed Idaho Roadless Rule encourages the use of temporary roads but would 

not limit the use of permanent roads because constructing/reconstructing some roads 

as permanent roads may result in less resource damage, thereby maintaining a key 

roadless characteristic of healthy watersheds. For example, it may be better to construct 

roads associated with reserved or outstanding rights as permanent roads because longterm access is necessary and permanent roads generally have additional protections for 

limiting sediment. Once the use of a road is no longer necessary it can still be 

decommissioned. 
Roadless Area Conservation; National Forest System Lands in Idaho DEIS 2.3 Consideration of Comments 

Chapter 2. Alternatives, Including the Proposed Action 57 

MOTORIZED ACCESS 

Some people requested an alternative that would convert roads closed to full-sized 

vehicles to all terrain vehicle (ATV) routes; designate all single-track trails on 

multiple-use lands as open to motorcycle use; mitigate the impacts from the loss of 

motorized access and recreation; provide motorized access to historic mines and 

cabins; provide for an adequate number of campsites and trailheads; develop a travel 

plan that would establish a 50/50 ratio for motorized/non-motorized trails; recognize 

and map primitive roads, trails, and single-track trails and allow use of these by 

appropriate vehicle; and allow greater motorized access in roadless areas. 

When taken in total, the suggestions represent the mix of views and actions associated 

with a comprehensive travel management plan. The Proposed Action addresses only 

road construction and reconstruction. The Idaho Roadless Rule makes clear that travelplanning-related actions should be addressed through travel management planning and 

individual forest plans. 
2.4 Responses to Questions Roadless Area Conservation; National Forest System Lands in Idaho DEIS 

58 Chapter 2. Alternatives, Including the Proposed Action 

2.4 Responses to Other Questions Identified During Scoping 

What are Idaho Roadless Areas? What are they based on? Are they different from 

the 2001 Roadless Rule? 

The areas identified as Idaho Roadless Areas may be found the map packet, alternative 

maps and appendix C maps (maps of Idaho Roadless Areas by forest). These roadless 

areas are based on the most current inventory, found either in existing plans, proposed 

plans, or the 2001 Roadless Rule. In most cases, the boundaries from the three sources 

are the same. Where there are differences, several factors contributed (appendix A). 

Most of the roadless area boundaries found in the 2001 Roadless Rule were based on 

forest plan inventories completed in the mid 1980s. Most of these inventories had not 

been updated for the 2001 Roadless Rule to reflect activities that had occurred in the 

1990s. During forest plan revision, most forests updated their inventory according to 

Forest Service direction (Forest Service Handbook [FSH] 1909.12, Chapter 70). Some 

roadless areas decreased in size from Existing Plans or the 2001 Roadless Rule because 

development by timber sales and/or road construction had occurred during the past 15 

years within those areas. Some were just mapping errors. Other areas increased in size, 

generally because of land exchanges or because development of some kind that was 

expected to occur at the time of forest plans did not happen. 

Appendix A provides information regarding inventories for the 2001 Roadless Rule and 

Idaho Roadless Areas and summarizes the changes for each unit. Maps associated with 

appendix A may be found in the map packet. 

What is the relationship between the Proposed Action and forest plans? 

The Forest and Rangeland Renewable Resources Planning Act of 1974 (88 Stat. 476 et 

seq.), as amended by the National Forest Management Act of 1976 (90 Stat. 2949 et seq.; 

16 USC 1601-1614), requires the Secretary to develop land and resource management 

plans (16 USC 1604) for each administrative unit of the Forest Service. 

Forest plans are in place for all national forests in Idaho and provide a strategic vision 

for managing forests for the next 10 to 15 years. They establish the desired conditions to 

be achieved through the management of NFS lands to best meet the needs of the 

American people. The plans blend national and regional priorities with local forest 

capabilities and needs. Thus, each plan provides a vision of how its unit uniquely fits 

within a broader landscape and community context. Plans may contain standards or 

guidelines, which provide further direction for project planning and design. A basic 

requirement for any plan is that any direction established by a plan must be consistent 

with all laws and regulations. 

Direction for the management of Idaho Roadless Areas, as outlined in the Petition, 

would be established in regulation. Regulations supercede forest plan direction and 

cannot be changed by forest plans. Therefore, future projects taken to implement the 

forest plan in roadless areas would be required to be consistent with the rule. 
Roadless Area Conservation; National Forest System Lands in Idaho DEIS 2.4 Responses to Questions 

Chapter 2. Alternatives, Including the Proposed Action 59 

How would the Proposed Action influence future wilderness designations, 

specifically how and whether designation of a roadless area as Wild Land Recreation 

would affect current forest plan wilderness recommendations? 

In general, the Wild Land Recreation theme lands were previously recommended as 

potential wilderness in existing and proposed plans. There are three instances where 

the Proposed Action would deviate from existing and/or proposed plans: 

Boulder-White Clouds on the Sawtooth and Challis National Forests. About 191,100 acres are 

recommended wilderness under the Existing Plans. The proposed Idaho Roadless Rule 

would designate about 231,300 acres as Wild Land Recreation based on pending 

wilderness legislation. Some areas recommended for wilderness were changed to the 

Primitive theme because the pending legislation (Central Idaho Economic Development 

and Recreation Act (CEIDRA, H.R.222, 2007)) did not include them; other areas were 

added because the pending legislation included them, for a net gain of 40,200 acres. 

Those lands not included in the bill were placed into the Primitive theme. These lands 

would still be considered as recommended wilderness under the forest plans, but the 

Primitive theme management direction would apply. 

Mallard Larkins on the Idaho Panhandle and Clearwater National Forests. About 141,900 acres 

are recommended wilderness under the Existing Plans. The Proposed Action would 

designate about 108,900 acres to Wild Land Recreation based on the proposed revised 

forest plans. About 22,100 acres (Pioneer Area) were placed into to SAHTS. The 

remaining 10,900 acres were placed into Backcountry based on recommendations by 

collaborative groups involved in forest plan revision. 

Winegar Hole on the Targhee National Forest. About 2,600 acres are recommended 

wilderness under the Targhee forest plan. This area is adjacent to existing wilderness. 

The Proposed Action would place these acres into a Primitive theme because the 

Congress has already enacted wilderness legislation for the surrounding area and 

declined to incorporate these 2,600 acres into wilderness. 

Recommended wilderness lands placed in the Wild Land Recreation theme would be 

managed in a more protective manner than under the 2001 Roadless Rule; for example, 

there would be more limited opportunities for timber cutting and/or road 

construction/reconstruction. 

For those recommended wilderness lands placed in the Primitive theme, there would be 

more opportunities for timber cutting than under the Wild Land Recreation theme, but 

fewer than under the 2001 Roadless Rule. Further, the Proposed Action would have no 

effect on forest plan wilderness recommendations. Those designations would continue. 

How does the proposed rule affect special areas, such as research natural areas or other 

legislated areas such as wild and scenic rivers? There are about 354,100 acres of existing 

special areas within Idaho Roadless Areas (table 2-1 and appendix H, table H-9). The 

proposed rule would not apply to these areas; management direction under existing 

plans would apply. 
2.4 Responses to Questions Roadless Area Conservation; National Forest System Lands in Idaho DEIS 

60 Chapter 2. Alternatives, Including the Proposed Action 

How does the proposed rule influence future considerations within these areas, such 

as travel management? The proposed rule directly affects only allowances for road 

construction and reconstruction; timber cutting, removal and sale; and discretionary 

mineral activities. It would not regulate travel management. However, as units engage 

in travel planning they would likely consider the management themes during the 

process. 

How can changes be made to inventories? The 2001 Roadless Rule did not include a 

specific mechanism for changing roadless area boundaries or acres and the Forest 

Service has not established such direction. Past experience has shown that such 

direction is needed. The following provides some examples of why boundaries or acres 

may need to be adjusted: 

Currently acres are calculated using geospatial information systems (GIS) technology. 

This technology is advancing in its precision. For example, GIS uses a process called 

Projections, in which a flat surface is projected around the earth’s surface. The earth has 

a different curvature depending on where the area is located. In GIS these areas have 

been broken up into different units (which apply a certain curvature to that polygon). If 

the technician applies the polygon to the wrong unit, the acres will be wrong; therefore, 

there is a need to be able to correct this information. 

Inventoried roadless area boundary lines may be misrepresented when newer 

information for roads or improvements are overlaid. For example, if roads have been 

identified using a global positioning system (GPS), this information is more accurate 

than a line drawn on a map. The boundary line should obviously follow the road and 

not go across it; therefore there would be a need to adjust the boundary. 

Inventoried roadless area boundary lines may be misrepresented because they were 

developed at a different scale than the roads layer. This may cause the boundary line to 

weave on one side of a road to another, whereas in reality the boundary should be just 

on one side; therefore, there would be a need to reconcile the boundary. 

In some cases, there are just errors. Roads or improvements such as facilities may have 

been included in the boundary when they should not have been. 

The Proposed Action recommends a process for updating boundary corrections to 

include, but are not limited to, adjustments that remedy clerical, typographical, or 

mapping errors, or improvements in mapping technology as described above. 

How can changes be made to themes? Because the Proposed Action would be in effect 

until it is repealed or modified, it includes a mechanism for changes to themes (land 

classifications) due to new circumstances. The Secretary of Agriculture may modify the 

land classifications, in any manner whatsoever, based on changed circumstances or 

public need. If a modification would result in a significant change, public involvement 

comparable to that required for the promulgation of the rule would be required. At 

least 30 days public notice is required for any non-significant modification. 

What is the role of the State Implementation Task Force? The Governor of Idaho 

created the Governor’s Roadless Rule Advisory Commission (Executive Order No. 
Roadless Area Conservation; National Forest System Lands in Idaho DEIS 2.4 Responses to Questions 

Chapter 2. Alternatives, Including the Proposed Action 61 

2006-43) in 2006. The advisory commission would assist the Agency and tribal 

governments in ensuring the implementation of the final rule. The commission has no 

decision-making authority. 

Why wasn’t the scoping comment period extended? Why weren’t public meetings 

held during the scoping period? The notice of intent initiates the scoping process in 

compliance with the NEPA and its implementing regulations (40 CFR §1501.7) to 

determine the nature and scope of environmental, social, and economic issues related to 

the rulemaking that should be analyzed in depth in the EIS. 

There have been numerous opportunities in the past for public comment on roadless 

area conservation and management. During the development of the Petition, more than 

50 public meetings were held in Idaho, producing local, regional, and national public 

input for the petition process. The proposed Idaho Roadless Rule also builds from of the 

experience with the 2001 Roadless Area Conservation Rule and the 2005 State Petitions 

Rule. More than two million public comments were received during these rulemaking 

processes; the knowledge gained from the previous public comment periods will help 

inform the identification and analysis of issues for this EIS. 

The Agency believes that additional public meetings outside the State of Idaho or an 

extension of the comment period were not necessary. The Forest Service received more 

than 45,000 comments including many thoughtful and detailed submissions. 

On release of the draft EIS and proposed rule language, additional public comment will 

be solicited and public meetings will be held to take a careful look at the site-specific 

elements of the proposed rule, alternatives, and effects. 
2.5 Comparison of Alternatives Roadless Area Conservation; National Forest System Lands in Idaho DEIS 

62 Chapter 2. Alternatives, Including the Proposed Action 

2.5 Comparison of Alternatives 

2001 Roadless Rule Existing Plans Idaho Roadless Rule 

Idaho Roadless Rule and equivalent themes for the 2001 Roadless Rule and Existing Plans (Acres) 

Wild Land Recreation 0 1,320,800 1,378,600 

Primitive 0 2,131,400 1,656,300 

SAHTS 0 0 68,600 

Backcountry 9,304,200 4,244,500 5,246,100 

GFRG 0 1,262,400 609,500 

Other lands (Acres) 

Forest Plan Special Areas 0 354,100 354,100 

Total Idaho Roadless Area 

Acres 9,304,200 9,304,200 9,304,200 

Projected timber cutting 

Timber harvest yearly 

average (MMBF) 0.5 14 4 

Timber harvest yearly 

average (CCF) 1,137 26,900 7,237 

Timber harvest yearly 

average (acres) 100 2,800 800 

% of average yearly volume 

harvested on all NFS lands in 

Idaho 

.5% 11.5% 3% 

% of average yearly acreage 

harvested on all NFS lands in 

Idaho 

1% 28% 8% 

Projected miles of road construction/reconstruction activities; yearly average 

Permanent – other 0.8 0.8 0.8 

Temporary – other 0.2 0.2 0.2 

Reconstruction – other 0.0 0.0 0.0 

Total 1.0 1.0 1.0 

Permanent – timber 0.0 4.0 0.0 

Temporary – timber 0.0 2.0 1.5 

Reconstruction – timber 0.0 5.0 1.5 

Total 0.0 11.0 3.0 

Grand Total 1.0 12.0 4.0 

Decommissioning 1.0 4.0 3.0 

Net Change 0.0 8.0 1.0 

Percent of Idaho Roadless Areas that permit or prohibit construction/ reconstruction 

Prohibited 0 39 34 

Permitted, under limited 

exceptions 100 0 59 

Permitted, under variable 0 47 0 

Permitted without exceptions 0 14 7 
Roadless Area Conservation; National Forest System Lands in Idaho DEIS 2.5 Comparison of Alternatives 

Chapter 2. Alternatives, Including the Proposed Action 63 

2001 Roadless Rule Existing Plans Idaho Roadless Rule 

Forest health 

Insect and disease 

Most of the 1.4 million 

acres currently at risk of 

25% mortality or 

significant growth loss 

would remain untreated. 

190,000 of high risk 

forests in GFRG. 730,000 

in Backcountry 

Opportunities for 

treatment. 

Projected treatments on 

42,000 acres likely to be 

effective over 15 years. 

26,000 acres of high risk 

forests in GFRG. 940,000 

acres in Backcountry. 

Opportunities to treat 

GFRG. Opportunity for 

treatment in Backcountry 

if done for forest health or 

to reduce hazardous fuels 

Projected treatments on 

12,000 acres likely to be 

effective over 15 years. 

Noxious weeds – Potential for 

Noxious weed spread 

Spreading is unlikely 

given limited potential for 

soil disturbance. 28,000 

acres of weeds currently 

found in Idaho Roadless 

Areas. 

Some potential for 

spreading based on 

acreage assigned to 

GFRG (1.262 million); the 

limited degree of 

projected road 

construction, timber 

cutting, and mineral 

activity would minimize 

the potential for 

spreading. 8,300 acres of 

weeds currently found in 

GFRG. 

Some potential for 

spreading based on 

acreage assigned to 

GFRG (609,500 acres); 

the limited degree of 

projected construction, 

harvest and mineral 

activity would minimize 

the potential for 

spreading. 2,600 acres of 

noxious weeds currently 

found in GFRG. 

Climate change 

The magnitude and rapidity of climate change is uncertain, particularly at the finer 

scales such as Idaho Roadless Areas. Variable impacts across alternatives are 

therefore not quantified. 
2.5 Comparison of Alternatives Roadless Area Conservation; National Forest System Lands in Idaho DEIS 

64 Chapter 2. Alternatives, Including the Proposed Action 

2001 Roadless Rule Existing Plans Idaho Roadless Rule 

Fuel management 

Road construction not 

permitted in conjunction 

with treatments on 100% 

of the WUI. 

Treatments more 

expensive; insignificant 

acreage treated relative to 

acres at risk. Limited 

capacity to treat high 

priority condition class 2 

and 3 areas. 

Does not directly permit 

timber cutting to reduce 

risk of unwanted wildland 

fire. 

Road construction 

permitted in conjunction 

with treatments on 69% of 

the Wildland Urban 

Interface (WUI). 

Mechanical treatments, 

without road construction 

may be permitted on 22% 

of the WUI. 

Mechanical treatments 

not permitted on 9%19 of 

the WUI. 

Projected harvests could 

treat 10% of high priority 

areas (Fire Regimes I, II 

and III, Condition Class 2 

and 3) within WUIs or 1% 

of high priority areas 

overall. 

May permit timber cutting 

to reduce risk of 

unwanted wildland fires 

Road construction 

permitted in conjunction 

with treatments on 71% of 

the Wildland Urban 

Interface (WUI). 

Mechanical treatments, 

without road construction 

may be permitted on19% 

of the WUI. 

Mechanical treatments 

not permitted on 9% of 

the WUI. 

Projected harvests could 

treat 3% of high priority 

areas (Fire Regimes I, II 

and III, Condition Class 2 

and 3) within WUIs or less 

than half a percent of high 

priority areas overall. 

Directly permits timber 

cutting to reduce risk of 

unwanted wildland fires in 

the Primitive, 

Backcountry, and GFRG 

themes. 

Potential for increase in 

human-caused fire starts No increase Potential for increase No measurable increase 

Locatable minerals 

Gold, silver, lead, Etc. 

None of the alternatives affect rights of reasonable access to prospect and explore 

lands open to mineral entry and develop valid claims under the General Mining Act 

of 1872. 

Rights to reasonable access 

for locatable minerals Yes Yes Yes 

 

19 Includes lands in Forest Plan Special Areas 
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Chapter 2. Alternatives, Including the Proposed Action 65 

2001 Roadless Rule Existing Plans Idaho Roadless Rule 

Leasable minerals 

Oil, gas, and coal Differences in activity and revenue associated with oil, gas, and coal development is 

expected to be minimal based on existing trends and inventories. 

Geothermal – acres of high 

geothermal potential within 

the GFRG theme 

0 387,300 351,600 

Geothermal – acres of 

medium geothermal potential 

within the GFRG theme 

0 796,600 236,500 

Geothermal – acres of high 

geothermal potential within 

the GFRG theme, less than 

40% slope 

0 249,500 233,600 

Geothermal – acres of 

medium geothermal potential 

within the GFRG theme, less 

than 40% slope 

0 457,700 140,800 

Geothermal development Negligible opportunities 

for development. 

No opportunities on 40% 

of acreage; 

Limited opportunities on 

46% of acreage; 

Open or unrestricted 

opportunities on 14% of 

acreage. 

No opportunities on 93% 

of acreage; 

Open or unrestricted 

opportunities on 7% of 

acreage. 

Leasable resources: 

phosphate (short term within 

15 yrs) 

Projected output is equal across all alternatives because (i) none of the alternatives 

prohibit road construction and reconstruction associated with existing leases and (ii) 

existing leases are expected to meet demand in reasonably foreseeable future. 

Phosphate – acres 

reasonable foreseeable road 

construction and mining 

disturbance proposed in Sage 

Creek and Meade Peak 

Roadless areas 

1,100 1,100 1,100 

Phosphate – Projected 

phosphate acres currently 

under lease 

8,000 8,000 8,000 

Phosphate (Long term – 

leasing of unleased 

phosphate deposits) 

Opportunities to recover 

phosphate from Idaho 

Roadless Areas are 

negligible. 

Estimated 603 million 

tons of phosphate 

deposits from 13,400 

unleased acres available 

for development. 

Estimated 545 million 

tons of phosphate 

deposits from 12,100 

unleased acres available 

for development (road 

construction prohibited on 

primitive theme acres). 
2.5 Comparison of Alternatives Roadless Area Conservation; National Forest System Lands in Idaho DEIS 

66 Chapter 2. Alternatives, Including the Proposed Action 

2001 Roadless Rule Existing Plans Idaho Roadless Rule 

Saleable minerals 

Acres associated with 

potential developing new 

mineral material sites within 

Idaho Roadless Areas 

(GFRG) 

0 1,262,400 609,500 

Potential for development of 

new mineral material sites 

within Idaho Roadless Areas 

Rare Circumstance Minimal Minimal 

Saleable minerals (sand, 

stone, gravel, pumice, etc.) 

Differences in production of saleable minerals are projected to be minimal across 

alternatives due to the relative inefficiencies of providing saleable minerals from 

Idaho Roadless Areas. 

Abandoned and inactive mines 

Road Construction allowed for 

CERCLA Violations Yes Yes Yes 

Energy corridors 

Energy corridors 

None of the proposed corridors designated for oil, gas, and/or electricity under 

Section 368 of the Energy Policy Act are within Idaho Roadless Areas. Opportunities 

for non-Section 368 corridors within Idaho Roadless Areas are a function of the 

themes assigned to the areas proposed for corridor development; differences in 

opportunities across alternatives cannot be discerned. 

Physical resources 

Acres of high sensitive soils 

by theme 

 Wild Land Recreation 0 221,900 270,200 

 Primitive 0 817,200 610,800 

 SAHTS 0 0 24,100 

 Backcountry 3,094,200 1,503,400 1,842,500 

 GFRG 0 440,300 235,200 

 Forest Plan Special Areas 111,400 111,400 

Acres of high sensitivity 

soils where road construction/ 

reconstruction is permitted 

without restrictions – GFRG 

0 440,300 235,200 

Acres of highly sensitive soils 

where road construction/ 

reconstruction is prohibited 

3,094,200 1,1150,500 1,016,500 

Effect of road building on high 

hazard soils for timber cutting No effect Negligible effect Negligible effect 

Effect of road building on high 

hazard soils for mining Limited risk Likely effect Likely effect 

Miles of 303(d) listed streams 

Wild Land Recreation 0 15 29 

Primitive 0 62 47 

SAHTS 0 0 4 

Backcountry 445 159 210 

GFRG 0 84 31 

Forest Plan Special Areas 0 125 125 
Roadless Area Conservation; National Forest System Lands in Idaho DEIS 2.5 Comparison of Alternatives 

Chapter 2. Alternatives, Including the Proposed Action 67 

2001 Roadless Rule Existing Plans Idaho Roadless Rule 

Acres of watersheds with 

surface drinking water 

 Wild Land Recreation 0 26,800 29,500 

 Primitive 0 165,000 119,900 

 SAHTS 0 0 0 

 Backcountry 409,100 151,600 230,900 

 GFRG 0 61,500 24,600 

 Forest Plan Special Areas 0 4,200 4,200 

Effect of road construction, 

reconstruction, and timber 

harvest on listed streams and 

drinking water 

Negligible effect Minimal effect Negligible effect 

Effect of mining on listed 

streams and drinking water 

Possible effect to 303(d) 

streams from selenium – 

mitigation required at time 

of analysis 

Possible effect to 303(d) 

streams from selenium – 

mitigation required at time 

of analysis 

Possible effect to 303(d) 

streams from selenium – 

mitigation required at time 

of analysis 

Acres within 50 miles of a 

Class I air quality protection 

area 

 

 Wild Land Recreation 0 832,400 879,600 

 Primitive 0 1,712,300 1,406,300 

 SAHTS 0 0 46,500 

 Backcountry 5,542,800 2,370,600 2,871,100 

 GFRG 395,200 107,000 

 Forest Plan Special Areas 232,300 232,300 

Effect to air quality from fuel 

reduction projects Negligible Negligible Negligible 

Botanical resources 

Number of occurrences of 

known sensitive plant 

populations 

 

 Wild Land Recreation 0 127 141 

 Primitive 0 166 147 

 SAHTS 0 0 1 

 Backcountry 1,165 523 601 

 GFRG 0 84 10 

 Forest Plan Special Areas 0 265 265 

Effects on biodiversity Beneficial 

Beneficial in Wild Land 

Recreation, Primitive, or 

SAHTS 

Aquatic 

Effects to aquatic species or 

habitat Beneficial 

Beneficial in Wild Land 

Recreation, Primitive, or 

SAHTS; Some potential 

risk of adverse effects in 

management 

prescriptions similar to 

Backcountry and GFRG 

Beneficial in Wild Land 

Recreation, Primitive, or 

SAHTS; Limited potential 

risk of adverse effects in 

Backcountry; some 

potential risk in GFRG 
2.5 Comparison of Alternatives Roadless Area Conservation; National Forest System Lands in Idaho DEIS 

68 Chapter 2. Alternatives, Including the Proposed Action 

2001 Roadless Rule Existing Plans Idaho Roadless Rule 

Wildlife 

Effects to terrestrial animal 

species or habitat Beneficial 

Beneficial in Wild Land 

Recreation, Primitive, or 

SAHTS; Some potential 

risk of adverse effects in 

management 

prescriptions similar to 

Backcountry and GFRG 

Beneficial in Wild Land 

Recreation, Primitive, or 

SAHTS; Limited potential 

risk of adverse effects in 

Backcountry; some 

potential risk in GFRG 

Recreation 

Dispersed Recreation – 

No measurable change to 

dispersed recreation 

opportunities. Feeling of 

remoteness or solitude 

may change if timber 

cutting or road 

construction/ 

reconstruction occurs 

(projected 1,500 acres 

timber cutting and 15 

miles of road 

construction/ 

reconstruction over 15 

years. No change to 

hunting and fishing 

opportunities. 

No measurable change to 

dispersed recreation 

opportunities, except if 

unleased phosphate 

deposits (13,400 acres) 

are developed. 

Feeling of remoteness or 

solitude may change if 

timber cutting or road 

construction/ 

reconstruction occurs 

(projected 42,000 acres 

timber cutting and 180 

miles of road 

construction/ 

reconstruction over 15 

years. No change to 

hunting and fishing 

opportunities. 

No measurable change to 

dispersed recreation 

opportunities, except if 

unleased phosphate 

deposits (12,100 acres) 

are developed. 

Feeling of remoteness or 

solitude may change if 

timber cutting or road 

construction/ 

reconstruction occurs 

(projected 12,000 acres 

timber cutting and 60 

miles of road 

construction/ 

reconstruction over 15 

years. No change to 

hunting and fishing 

opportunities. 

Developed recreation – ability 

to construct or reconstruct 

roads to access new or 

expanded developed 

recreation areas 

No road construction/ 

reconstruction permitted 

to access new developed 

recreations sites (9.3 

million acres). There are 

no foreseeable 

developments. 

Road construction/ 

reconstruction generally 

permitted to access new 

developed recreations 

sites management 

prescriptions similar to 

Backcountry and GFRG 

(5.5 million acres). There 

are no foreseeable 

developments. 

Road construction/ 

reconstruction permitted 

to access new developed 

recreations sites 

management in GFRG (.6 

million acres). There are 

no foreseeable 

developments. 

Recreation 

In general, the magnitude of shifts in recreational opportunity spectrum classes is 

slight across the alternatives because: (i) differences in road construction are 

minimal, and (ii) many constructed roads are likely to be temporary and not 

accessible for recreation purposes. As a consequence, changes in dispersed versus 

developed recreation opportunities are small across alternatives. Relative 

differences include the following: 
Roadless Area Conservation; National Forest System Lands in Idaho DEIS 2.5 Comparison of Alternatives 

Chapter 2. Alternatives, Including the Proposed Action 69 

2001 Roadless Rule Existing Plans Idaho Roadless Rule 

Relatively high potential 

for maintaining existing 

dispersed recreation 

opportunities; little 

potential for increasing 

developed recreation. 

Greatest opportunity for 

developed and roadbased recreation to occur 

and expand, but 

magnitude of shift is 

tempered by limited 

amount of construction 

projected to occur. 

Potentially the greatest 

level of protection for 

dispersed recreation, 

foreseeable threats from 

construction and 

development are remote. 

Recreation special uses – 

existing permits (including ski 

areas) 

Existing permits 

unaffected 

Existing permits 

unaffected 

Existing permits 

unaffected 

Hunting and fishing No effect to opportunities. Opportunities could be 

affected in locations of 

phosphate leasing and 

geothermal development. 

No effect from timber 

cutting and limited road 

construction. 

Opportunities could be 

affected in locations of 

phosphate leasing and 

geothermal development. 

No effect from timber 

cutting and limited road 

construction. 

Wilderness 

Existing Wilderness areas 

1,726,000 acres of 

roadless areas adjacent 

to Wilderness. 

Limited to no indirect 

effect to Wilderness from 

activities in roadless 

areas 

158,000 acres of GFRG 

adjacent to Wilderness; 

842,000 acres of 

Backcountry 

Limited potential for 

impacts to Wilderness 

experience 

9,000 acres of GFRG 

adjacent to Wilderness; 

954,000 acres of 

Backcountry 

Limited potential for 

impacts to Wilderness 

experience 

Recommended wilderness 

No change or effect to 

recommended wilderness 

in existing plans 

Existing plans 

recommend 1,320,900 as 

Wilderness 

There would be no 

change to the 

recommendations in the 

forest plans; however 

there are 1,378,600 acres 

in Wild Land Recreation. 

57,700 acres of additional 

protection over existing 

plans. 

Some recommended 

wilderness areas in 

Boulder-White Clouds 

and Winegar Roadless 

Areas would be managed 

as Primitive. 

 

6,900 acres in Mallard 

Larkins Roadless Area 

would be managed as 

Backcountry. 
2.5 Comparison of Alternatives Roadless Area Conservation; National Forest System Lands in Idaho DEIS 

70 Chapter 2. Alternatives, Including the Proposed Action 

2001 Roadless Rule Existing Plans Idaho Roadless Rule 

Wilderness characteristic 

Majority of roadless areas 

retain their existing 

character 

 Areas developed could 

have reduced wilderness 

character. Activities in 

GFRG may not change 

wilderness character if 

prior activities are still 

evident 

Areas developed could 

have reduced wilderness 

character. Activities in 

GFRG may not change 

wilderness character if 

prior activities are still 

evident 

Scenic integrity 

Acres maintained in High to 

Very High Scenic Integrity 

 Wild Land Recreation 0 1,320,900 1,378,600 

 Primitive 0 2,130,100 1,656,300 

 SAHTS 0 0 68,600 

 Backcountry 9,295,100 0 0 

 GFRG 

 Forest Plan Special Areas 0 345,100 345,100 

Acres available for reduction 

to Moderate Scenic Integrity 

 Wild Land Recreation 0 0 0 

 Primitive 0 0 0 

 SAHTS 0 0 0 

 Backcountry 9,304,200 4,243,700 5,245,300 

 GFRG 0 1,251,100 598,200 

 Forest Plan Special Areas 0 0 0 

Acres Likely Changed to 

Moderate or Low Scenic 

Integrity 

 

 Wild Land Recreation 0 0 0 

 Primitive 0 1,300 0 

 SAHTS 0 0 0 

 Backcountry 9,100 800 800 

 GFRG 0 11,300 11,300 

 Forest Plan Special Areas 0 0 0 
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2001 Roadless Rule Existing Plans Idaho Roadless Rule 

Scenic integrity 

High or Very High scenic 

integrity retained on most 

Idaho Roadless Areas. 

Potential for lower scenic 

quality on 5.5 million 

acres due permissions in 

management 

prescriptions for timber 

cutting, road construction/ 

reconstruction and 

discretionary mineral 

activities, but reasonably 

foreseeable losses are 

small given projections of 

activities in Idaho 

Roadless Areas. 

Potential for lower scenic 

quality on 5.9 million 

acres due to management 

theme assignments and 

associated permissions 

for timber cutting, road 

construction/ 

reconstruction and 

discretionary mineral 

activities, but reasonably 

foreseeable losses are 

small given projections of 

activities in Idaho 

Roadless Areas. 

Cultural resources 

Potential for disturbance, 

vandalism, and looting Low Low to Moderate Low 

Cultural resources 

Prior to management actions taking place on the ground under any alternative or 

theme, cultural resource inventories and appropriate mitigation are required by law. 

Differences in risk to cultural resources are not expected to be significant across 

alternatives due to projected levels of road construction and long-term use and fate 

of new roads. 

Idaho and affected Indian tribes 

Impacts on Tribal governments and Tribal practices from resource management 

activities would be minimal because of consultation requirements. Roads, timber 

cutting, and mining may alter the character of places that have historic or cultural 

value, thereby diminishing their value. 

Social 

Values and Beliefs Most environmental 

functions retained, 

roadless characteristics 

remain intact 

Most environmental 

functions retained, some 

roadless characteristics 

changed 

Most environmental 

functions retained, few 

roadless characteristics 

changed 

Collaborative Environment Local communities feel 

left out 

Local communities 

engaged 

Local community interests 

integrated with national 

values 

Lifestyles Significant risks to 

natural resource 

conditions near 

communities remain 

Significant risks to natural 

resource conditions near 

communities reduced 

Significant risks to 

natural resource 

conditions near 

communities reduced 

 Undeveloped recreation 

and cultural opportunities 

continue 

Many undeveloped 

recreation and cultural 

opportunities continue 

Most undeveloped 

recreation and cultural 

opportunities continue 

Economic 

Commodity values – forest 

level outputs 

 Harvest (MBF) 567 13,458 3620 

 Phosphate (tons) 2,000,000 2,000,000 2,000,000 
2.5 Comparison of Alternatives Roadless Area Conservation; National Forest System Lands in Idaho DEIS 

72 Chapter 2. Alternatives, Including the Proposed Action 

2001 Roadless Rule Existing Plans Idaho Roadless Rule 

 Road decommissioning 

 (miles) 1.00 4.00 3.00 

 Roads (miles) 1.00 12.02 4.35 

Jobs (Yr) 

 Harvest 1 304 91 

 Phosphate 582 582 582 

 Road construction/ 

 reconstruction 

2 12 4 

Labor Income ($/Yr) 

 Harvest 343,000 7,651,000 1,935,000 

 Phosphate 23,000,000 23,000,000 23,000,000 

 Road construction/ 

 reconstruction 100,000 467,000 150,000 

Non-Commodity Values - 

Acres retaining natural 

processes and roadless 

characteristics (million) 

9.3 4.3 3.2