Rulemaking for Colorado Roadless Areas

Revised Draft Environmental Impact Statement

Lead Agency: USDA Forest Service 

Cooperating Agency: State of Colorado 

Responsible Official: Secretary of Agriculture

For Information, contact: Ken Tu, Team Leader

USDA Forest Service

Colorado Roadless Rule 

(303) 275-5156

www.roadless.fs.fed.us

Abstract: 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Table of Contents

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Summary—1

SUMMARY OF THE ENVIRONMENTAL IMPACT STATEMENT

DOCUMENT STRUCTURE

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

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

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

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

abbreviated form.

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

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

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

BACKGROUND

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

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

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

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

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

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

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

direction exist. 

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

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

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

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

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

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

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

Service 2000a). 

 

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

2001 Roadless Rule. 
Rulemaking for Colorado Roadless Areas DEIS

2—Summary

Figure 1. Inventoried roadless areas in Colorado

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

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

congressionally designated land was removed from the inventory. Management of 

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

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

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

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

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

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

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

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

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

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

 

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

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

Summary—3

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

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

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

person bipartisan taskforce to make recommendations to the Governor regarding the 

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

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

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

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

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

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

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

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

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

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

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

initiate rulemaking (USDA RACNAC 2007b).

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

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

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

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

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

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

of its petition.

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

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

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

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

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

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

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

proposed rule and this EIS. 

PURPOSE OF AND NEED FOR ACTION

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

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

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

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

the following reasons:

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

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

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

roadless area characteristics. 
Rulemaking for Colorado Roadless Areas DEIS

4—Summary

2. As recognized in the 2001 Roadless Rule, tree-cutting, sale or removal, and road 

construction/reconstruction have the greatest likelihood of altering and fragmenting 

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

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

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

construction zones (LCZs) also need to be restricted. 

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

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

following: 

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

systems

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

coal mining area

c. permitting of construction and maintenance of water conveyance structures

d. permitting access to current and future electrical power lines

e. accommodating existing permitted or allocated ski areas. 

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

PROPOSED ACTION 

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

in Colorado. 

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

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

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

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

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

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

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

adjust roadless area boundaries by: 

a. correcting mapping errors that primarily resulted from improvements in 

inventory data and mapping technology;

b. excluding private land; 

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

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

development; 

e. excluding congressionally designated lands such as wilderness and other 

designations that take legal precedence over roadless area regulations; and 

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

Summary—5

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

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

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

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

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

would be readily available to the public.

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

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

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

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

detail, along with other alternatives considered in this analysis.

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

National forests in Colorado Date of approved forest plan

Arapaho-Roosevelt National Forests 1997

Grand Mesa, Uncompahgre, and Gunnison National Forests 1983

Manti-La Sal National Forest 3

1986

Routt National Forest 1998

Pike-San Isabel National Forests 1984

Rio Grande National Forest 1996

San Juan National Forest

1983 

(Revision in progress; draft revised plan 2007)

White River National Forest 2002

The proposed Colorado Roadless Rule establishes boundaries for Colorado roadless areas 

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

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

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

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

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

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

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

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

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

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

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

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

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

some additional unroaded acreages that are outside IRAs. 

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

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

 

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

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

6—Summary

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

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

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

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

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

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

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

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

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

more restrictive direction would prevail. 

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

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

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

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

Summary—7

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

DECISION FRAMEWORK

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

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

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

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

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

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

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

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

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

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

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

(alternative 3); or 

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

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

8—Summary

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

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

PUBLIC INVOLVEMENT

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

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

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

Forest Service Public Involvement

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

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

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

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

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

comments were received.

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

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

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

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

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

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

approximately 106,000 comments were received.

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

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

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

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

of Agriculture.

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

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

Colorado Roadless Rule is ongoing.

State of Colorado Public Involvement

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

following ways:

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

member bipartisan task force to make recommendations to the Governor regarding 

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

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

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

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

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

Summary—9

TRIBAL CONSULTATION

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

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

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

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

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

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

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

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

predominately on the San Juan National Forest.

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

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

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

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

decision-making process. 

ISSUES

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

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

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

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

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

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

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

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

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

characteristics within the context of Colorado specific situations and concerns. 

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

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

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

issues are:

General opinions or position statements not specific to the proposed action 

Addressed by other laws, regulations, or policies 

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

scope of this analysis. 

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

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

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

Framework and Scope and Applicability of the Rule):

National Park Service management issues
Rulemaking for Colorado Roadless Areas DEIS

10—Summary

General conditions of public lands

Conditions of roads and facilities on national forests

Political motivations or integrity of government officials

Public participation processes or procedures

Funding priorities and government expenditures 

Alternative energy on national forests

Wilderness protection or recommendations for wilderness designation

Motorized vehicle use and routes or other travel management topics

Access associated with livestock grazing permits and allotment management

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

in other states. 

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

consequences among the alternatives.

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

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

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

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

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

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

in a loss of roadless area characteristics. 

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

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

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

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

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

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

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

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

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

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

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

reductions in unfragmented interior habitat, migration corridor connections, and 

security and quality of habitat for some “at risk” species or important game species.

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

populations.

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

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

in areas that have not been leased (prior to the effective date of rulemaking) and/or are located 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Summary—11

outside the North Fork coal mining area may result in a loss of opportunities to explore for and 

develop coal resources in those areas.

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

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

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

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

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

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

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

and downstream from the roadless areas.

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

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

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

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

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

A reduction in opportunities for solitude

A reduction in scenic quality

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

undeveloped nature of roadless areas for future generations

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

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

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

and gas resources. 

ALTERNATIVES

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

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

IRA boundaries and roadless area management provisions for management of roadless 

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

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

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

effective date of the final Rule. 

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

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

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

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

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

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

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

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

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

12—Summary

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

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

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

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

are the same IRAs as those in alternative 1.

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

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

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

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

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

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

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

final Rule.

Features Common to All Alternatives

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

descriptions. 

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

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

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

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

authorities are not affected.4

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

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

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

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

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

restrictive. 

Project Specific Environmental Analysis. All future proposals for road construction 

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

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

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

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

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

authority. 

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

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

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

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

 

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

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

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

Summary—13

“existing” authorizations under the alternatives that establish a state-specific roadless 

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

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

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

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

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

o Livestock grazing

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

camping, mountain biking, and skiing.

Management of congressionally designated areas is governed by legislated direction that 

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

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

areas under any alternative.

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

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

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

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

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

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

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

according to the forest plan.

Alternative 1: Provisions of the 2001 Roadless Rule 

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

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

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

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

under this alternative. 

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

certain circumstances, such as those needed for: 

Protect public health and safety

Emergency environmental response under the Comprehensive Environmental 

Response, Compensation, and Liability Act (CERCLA)

Reserved and outstanding rights, existing land use authorizations

Road-related resource damage

Certain federal highway projects

Road traffic safety

Reasonable access to leaseable minerals in existing lease areas.

 

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

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

14—Summary

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

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

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

as to reduce the risk of uncharacteristic wildfire effects

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

prohibited by this subpart

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

and Disposal of National Forest System Timber

Within portions of IRAs where roadless area characteristics have been substantially 

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

Alternative 2: Proposed Action – Colorado Roadless Rule

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

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

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

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

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

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

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

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

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

building restrictions would be appropriate. 

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

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

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

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

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

exceptions:

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

proposed Rule; 

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

National Forest System Timber.

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

“non-upper tier acres”), the above exceptions apply as do these:

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

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

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

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

 

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

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

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

Summary—15

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

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

practical as appropriate to the forest type;

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

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

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

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

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

extent practical as appropriate to the forest type;

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

composition, structure and processes; or

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

coordination with the Colorado Department of Natural Resources including the 

Colorado Division of Wildlife.

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

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

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

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

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

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

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

CRAs are those needed to:

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

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

CRAs;

Repair road-related resource damage;

Improve road traffic safety; or

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

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

water court decree.

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

reconstructed in CRAs are:

For public health and safety;

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

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

zone;

When the Regional Forester determines a temporary road is needed to facilitate treecutting to maintain or restore the characteristics of ecosystem composition, structure and 

processes within the first one-half mile of the community protection zone;
Rulemaking for Colorado Roadless Areas DEIS

16—Summary

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

prohibit road construction or reconstruction; or

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

area. 

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

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

law enforcement purposes.

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

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

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

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

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

the following exceptions applies: 

The construction, reconstruction, or maintenance of water conveyance structures 

operated pursuant to a pre-existing water court decree

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

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

to be implemented outside a CRA without causing substantially greater environmental 

damage. 

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

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

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

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

such a connection would cause substantially less environmental damage than alternative 

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

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

exclusively outside of a CRA shall not be authorized.

Alternative 3: Forest Plans 

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

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

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

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

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

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

4.24 million acres. 

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

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

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

plan, roadless areas overlap a number of different land management allocations.

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

conditions or specific public or management needs. The revision process includes a review and 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Summary—17

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

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

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

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

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

prescriptions that conserve roadless area characteristics.

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

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

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

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

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

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

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

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

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

categories: 

Road construction is prohibited except where needed for reserved and outstanding 

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

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

not a mandatory restriction 

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

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

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

with law, regulation, or policy.

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

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

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

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

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

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

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

forest plan. 

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

generally falls into one of four categories: 

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

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

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

guidelines; non-mandatory direction

Tree-cutting, sale, or removal is limited to certain circumstances, such as those related 

to the purpose of the activity or protection of natural resources

Tree-cutting, sale, or removal is allowed as needed to meet multiple-use management 
Rulemaking for Colorado Roadless Areas DEIS

18—Summary

purposes. 

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

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

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

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

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

suitable for timber production. 

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

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

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

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

Alternative 4: Colorado Roadless Rule with Public Proposed Upper 

Tier Acres

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

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

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

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

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

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

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

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

Alternatives Considered but Eliminated from Detailed Study

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

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

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

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

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

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

study:

An alternative that provides the roadless area conservation provisions from alternative 

1, together with the CRA boundaries from alternative 2. 

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

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

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

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

 

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

packet.

8

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

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

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

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

Summary—19

An alternative that allows for more commercial use such as increased timber harvesting. 

Alternative 3 allows for increased levels of commercial use. Another alternative that allows for 

increased levels of commercial use compared to alternative 2, but less than alternative 3, while 

meeting the purpose and need of protecting roadless area characteristics would not result in 

differences that can be meaningfully analyzed.

An alternative that offers reduced road densities, creation of new roadless areas, and 

more protective management than any of the alternatives analyzed in the DEIS. 

Reducing road densities is outside the scope of this rule-making and decision framework and is 

best decided during travel management analysis. In addition, alternatives 2 and 4 allow for 

additions to CRAs, if needed. Alternatives 2 and 4, in response to public comments, have 

identified CRAs or portions of CRAs that are proposed to be managed as upper tier acres. On 

upper tier acres, more limited exceptions to the tree-cutting and road construction prohibitions 

are allowed. Additional protections would not meet the purpose and need to accommodate 

state-specific situations and concerns.

ENVIRONMENTAL CONSEQUENCES

This section compares the estimated environmental consequences of each alternative in 

summary form (Table 2). These environmental consequences are described in detail in chapter 3 

of the full EIS, and are summarized at the end of chapter 2 of the full EIS. The comparison table 

focuses on the key differences among the alternatives and the most likely consequences. 

Comparisons are based on the purpose and need for the proposed Colorado Roadless Rule as 

well as the issues associated with this proposed action, as previously described. Because the 

proposed rulemaking and its alternatives are broad, programmatic, and do not involve any 

proposed site-specific actions, the consequences are appropriately broad and qualitative rather 

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

20—Summary

Table 2. Comparison of alternatives by environmental consequences (refer to chapter 3 for details)9

Issue or Affected Resource

Alternative 1

Provisions of the 2001 

Roadless Rule

Alternative 2

Proposed Action

Colorado Roadless Rule

Alternative 3

No Action

Forest Plans

Alternative 4 

Colorado Roadless Rule

Fire and Fuels 1,800 acres in the analysis 

area have projected treecutting activities to reduce 

hazardous fuels each year 

(900 acres within IRAs).

Least flexibility to conduct 

hazardous fuel reduction 

and reduce fire risk to 

communities and municipal 

water supply systems.

5,900 acres in the analysis 

area have projected treecutting activities to reduce 

hazardous fuels each year 

(5,300 acres within CRAs).

Medium flexibility to conduct 

hazardous fuel reduction 

and reduce fire risk to 

communities and municipal 

water supply systems.

Unable to conduct hazardous 

fuels reduction on 12% of 

0.5 mile CPZ and 13% of 

1.5 mile CPZ due to upper 

tier acre prohibitions.

13,100 acres in the analysis 

area have projected treecutting activities to reduce 

hazardous fuels each year.

Greatest flexibility to conduct 

hazardous fuel reduction 

and reduce fire risk to 

communities and municipal 

water supply systems.

2,200 acres in the analysis 

area have projected treecutting activities to reduce 

hazardous fuels each year 

(1,600 acres within CRAs).

Within the CRAs that are not 

upper tier acres, the 

flexibility to conduct 

hazardous fuel reduction 

and reduce fire risk to 

communities and municipal 

water supply systems is 

identical to alternative 2.

Unable to conduct hazardous 

fuels reduction on 48% of 

0.5 mile CPZ and 52% of 

1.5 mile CPZ due to upper 

tier acre prohibitions.

Ecosystem Composition, 

Structure and Processes

500 acres per year in the 

analysis area have 

projected tree-cutting 

activities (300 acres within 

IRAs) for forest health 

purposes.

Fewest opportunities to 

maintain and restore 

ecosystem characteristics, 

including resilience to 

insect and disease

outbreaks and climate 

induced stressors.

1,000 acres per year in the 

analysis area have 

projected tree-cutting 

activities for forest health

purpose (400 acres within 

CRAs).

More opportunities than 

alternatives 1 and 4, but 

fewer opportunities than 

alternative 3 to maintain 

and restore ecosystem

characteristics, including 

resilience to insect and 

disease outbreaks and 

climate induced stressors.

Unable to treat upper tier

3,500 acres per year within 

the analysis area have 

projected tree-cutting 

activities for forest health

purposes.

Greatest opportunities to

maintain and restore 

ecosystem characteristics, 

including resilience to 

insect and disease

outbreaks and climate 

induced stressors.

800 acres per year in the 

analysis area have 

projected tree-cutting 

activities for forest health

purposes (200 acres within 

CRAs).

More opportunities to 

maintain and restore 

ecosystem characteristics, 

including resilience to 

insect and disease

outbreaks and climate 

induced stressors than 

alternative 1 but less than 

alternative 3 and alternative 

 

9

The analysis area is all acres within either the IRAs or the CRAs, or acres that are common between the two and are within both the IRAs and the CRAs. This 

totals 4,653,100 acres. Table 3-1 explains this in more detail. 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Summary—21

Issue or Affected Resource

Alternative 1

Provisions of the 2001 

Roadless Rule

Alternative 2

Proposed Action

Colorado Roadless Rule

Alternative 3

No Action

Forest Plans

Alternative 4 

Colorado Roadless Rule

acres. 2 due to upper tier acres.

Aquatic Species and Habitat Least risk for adverse impacts 

on aquatic species.

Site specific design criteria 

and mitigation measures 

are expected to minimize 

risk.

More risk than alternatives 1 

and 4, less than alternative 

3 for adverse impacts on 

aquatic species. 

Site specific design criteria 

and mitigation measures 

are expected to minimize 

risk.

Greatest risk of adverse 

impacts on aquatic species.

Site specific design criteria 

and mitigation measures 

are expected to minimize 

risk.

Less risk for adverse impacts 

on aquatic species than 

alternatives 2 and 3; 

greater risk than alternative 

1. 

Site specific design criteria 

and mitigation measures 

are expected to minimize 

risk.

Threatened Endangered or 

Sensitive Plants

No adverse impacts to 

threatened or endangered 

plants because no road 

construction or tree-cutting, 

sale or removal is projected 

to occur where threatened 

or endangered plants exist.

Least risk to adverse impacts 

to sensitive plants

Site specific design criteria 

and mitigation measures 

are expected to minimize 

risk.

No adverse impacts to 

threatened or endangered 

plants because no road 

construction or tree-cutting, 

sale or removal is projected 

to occur where threatened 

or endangered plants exist.

More risk of adverse impacts

to sensitive plants than 

alternatives 1 or 4; less 

than alternative 3.

Site specific design criteria 

and mitigation measures 

are expected to minimize 

risk.

No adverse impacts to 

threatened or endangered 

plants because no road 

construction or tree-cutting, 

sale or removal is projected 

to occur where threatened 

or endangered plants exist.

Greatest risk of adverse 

impacts to sensitive plants.

Site specific design criteria 

and mitigation measures 

are expected to minimize 

risk.

No adverse impacts to 

threatened or endangered 

plants because no road 

construction or tree-cutting, 

sale or removal is projected 

to occur where threatened 

or endangered plants exist.

More risk of adverse impacts 

to sensitive plants than 

alternative 1; less than 

alternatives 2 or 3.

Site specific design criteria 

and mitigation measures 

are expected to minimize 

risk.

Economics Average annual jobs 

associated with –

Oil/gas drilling = 489 jobs

Oil/gas production = 360 jobs

Coal production = 1,033 jobs

Average annual labor income

associated with –

Oil/gas drilling = $25.3 million

Oil/gas production =$ 24.6 

million

Coal production = $75.2 

Average annual jobs 

associated with –

Oil/gas drilling = 489 jobs

Oil/gas production = 360 jobs

Coal production = 1,912 jobs

Average annual labor income

associated with –

Oil/gas drilling = $25.3 million

Oil/gas production =$ 24.6 

million

Coal production = $139.1 

Average annual jobs 

associated with –

Oil/gas drilling = 553 jobs

Oil/gas production = 406 jobs

Coal production = 1,912 jobs

Average annual labor income

associated with –

Oil/gas drilling = $28.6 million

Oil/gas production =$ 27.8 

million

Coal production = $139.1 

Average annual jobs 

associated with –

Oil/gas drilling = 489 jobs

Oil/gas production = 360 jobs

Coal production = 1,912 jobs

Average annual labor income

associated with –

Oil/gas drilling = $25.3 million

Oil/gas production =$ 24.6 

million

Coal production = $139.1 
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

22—Summary

Issue or Affected Resource

Alternative 1

Provisions of the 2001 

Roadless Rule

Alternative 2

Proposed Action

Colorado Roadless Rule

Alternative 3

No Action

Forest Plans

Alternative 4 

Colorado Roadless Rule

million

Average annual value of 

production associated w/ –

Oil/gas drilling = $156.9 

million

Oil/gas production = $269.4 

million

Coal production = $305.9 

million 

million

Average annual value of 

production associated w/ –

Oil/gas drilling = $156.9 

million

Oil/gas production = $269.4 

million

Coal production = $566.2 

million 

million

Average annual value of 

production associated w/ –

Oil/gas drilling = $177.6 

million

Oil/gas production = $303.9 

million

Coal production = $566.2 

million

million

Average annual value of 

production associated w/ –

Oil/gas drilling = $156.9 

million

Oil/gas production = $269.4 

million

Coal production = $566.2 

million

No difference expected between alternatives at the State level in recreation, tourism, or wood products due to the lack of project 

specific data needed for analysis, and the ability to substitute sites and resources at the larger, State-wide scale.

Soils No major difference among alternatives related to the risk of soil impacts. Alternatives 1 and 4 would have the least risk of 

adverse effects, and alternative 2 would have a slightly higher risk, followed by alternative 3. However, these differences are 

insignificant because they would be small in magnitude and spread over a wide geographic area. Most of the potential effects 

would be mitigated by site-specific mitigation measures. The risk of post-fire soil erosion may be higher under alternative 1 and 

lowest under alternative 3 as a result of projected levels of fuel treatments. 

Developed Ski Areas Least opportunities for ski 

area development and 

expansion.

6,600 acres within the IRA 

boundaries and under 

permit prior to the effective 

date of rulemaking would 

allow for road construction 

and tree-cutting, sale or 

removal.

Forest Plan allocations for ski 

areas outside of existing 

permit areas (1,700 acres) 

would prohibit road 

construction.

Greater opportunity for ski 

area development and 

expansion.

Forest Plan allocations for ski 

areas outside of existing 

permit areas (1,700 acres) 

would allow road 

construction and treecutting more than 

alternative 1.

Forest plans can be amended 

or revised to expand ski 

area allocations beyond the 

current allocation.

Same as alternative 2.

Scenic Quality Least risk to scenic

resources.

More risk to scenic resources

than alternatives 1 and 4.

Upper tier acres same as 

alternative 1.

Greatest risk to scenic

resources.

Same as alternative 2 within 

CRA boundaries that are 

not upper tier; upper tier 

areas same as alternative 

1.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

Summary—23

Issue or Affected Resource

Alternative 1

Provisions of the 2001 

Roadless Rule

Alternative 2

Proposed Action

Colorado Roadless Rule

Alternative 3

No Action

Forest Plans

Alternative 4 

Colorado Roadless Rule

Social Values No disproportionate negative 

impact on minority or lowincome groups as defined 

in the Bureau of the 

Census' Current Population 

Reports.

Preference towards 

preservation of nondevelopment social values.

No disproportionate negative 

impact on minority or lowincome groups as defined 

in the Bureau of the 

Census' Current Population 

Reports.

Slightly less than alternative 1 

preference towards nondevelopment social values.

No disproportionate negative 

impact on minority or lowincome groups as defined 

in the Bureau of the 

Census' Current Population 

Reports.

Less preference towards nondevelopment social values

than alternatives 1, 2, and 

4.

Same as alternative 2.

Terrestrial Species and 

Habitat

Least risk to terrestrial

species and habitat.

Site specific design criteria 

and mitigation measures 

are expected to minimize 

risk.

More risk than alternative 1 

and 4 to terrestrial species 

and habitat.

Tree-cutting to improve 

habitat for TEPS species 

prohibited in upper tier

acres.

Site specific design criteria 

and mitigation measures 

are expected to minimize 

risk.

Greatest risk to terrestrial

species and habitat.

Site specific design criteria 

and mitigation measures 

are expected to minimize 

risk.

More risk than alternative 1 to 

terrestrial species and 

habitat.

Tree-cutting to improve 

habitat for TEPS species 

prohibited in upper tier

acres.

Site specific design criteria 

and mitigation measures 

are expected to minimize 

risk.

Recreation Settings Likely to retain the greatest 

proportion of acreage in 

primitive or semi-primitive

settings

The substantially altered

portion of the IRA inventory 

would continue to be 

inconsistent with primitive

or semi-primitive settings.

The newly identified roadless 

acres (409,500 acres)

where road construction 

and tree-cutting, sale or 

removal is projected to 

occur that are not within the 

IRAs could shift to less 

Likely to retain a high 

proportion of acreage in 

primitive or semi-primitive

settings. However, some 

areas where road 

construction and treecutting, sale or removal is 

projected to occur could 

shift to less primitive 

settings.

The exclusion of the 

substantially altered

acreage and inclusion of 

new roadless acres would

create a more 

homogeneous primitive or 

semi-primitive recreation 

Least likely to retain a high 

proportion of acreage in 

primitive or semi-primitive

settings; especially where 

road construction and treecutting, sale or removal is 

projected to occur.

Same as alternative 2.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

24—Summary

Issue or Affected Resource

Alternative 1

Provisions of the 2001 

Roadless Rule

Alternative 2

Proposed Action

Colorado Roadless Rule

Alternative 3

No Action

Forest Plans

Alternative 4 

Colorado Roadless Rule

primitive settings. setting.

Lands-Special Use 

Authorizations

Special use authorizations 

issued prior to the effective 

date of rulemaking would 

be unaffected.

Future special use 

authorizations in IRAs 

would generally prohibit 

road construction.

There would be no prohibition 

on the use of LCZs for 

future electrical power lines 

or telecommunication lines, 

water conveyance 

structures and oil and gas

pipelines from sources 

outside of IRAs.

Special use authorizations 

issued prior to the effective 

date of rulemaking would 

be unaffected.

Future special use 

authorizations in CRAs 

would generally prohibit 

road construction.

Limited exceptions for the use

of LCZ for future electrical 

power lines or 

telecommunication lines, 

water conveyance 

structures and oil and gas

pipelines from sources 

outside of CRAs.

Current and future special use 

authorizations would 

generally allow for road 

construction; except where 

prohibited under forest 

plans.

There would be no prohibition 

on the use of LCZs for 

future electrical power lines

or telecommunication lines, 

water conveyance 

structures or oil and gas

pipelines.

Same as alternative 2.

Invasive Plants Least risk of spread of 

invasive plants because 

this alternative has the least 

projections of road 

construction or tree-cutting, 

sale or removal.

Site specific design criteria 

and mitigation measures 

are expected to minimize 

risk.

Slightly higher risk than 

alternatives 1 and 4 for the 

spread of invasive plants 

because this alternative has 

a higher projection of road 

construction or tree-cutting, 

sale or removal.

Site specific design criteria 

and mitigation measures 

are expected to minimize 

risk.

Greatest risk of the spread of 

invasive plants because 

this alternative has the 

highest projections for road 

construction or tree-cutting, 

sale or removal.

Site specific design criteria 

and mitigation measures 

are expected to minimize 

risk.

Slightly higher risk than 

alternative 1 but less than 

alternative 2 for the spread 

of invasive plants because 

this alternative has a higher 

projection of road 

construction or tree-cutting, 

sale or removal.

Site specific design criteria 

and mitigation measures 

are expected to minimize 

risk.

Cultural Resources Least risk of damage to 

cultural resources because 

this alternative has the least 

projections for tree-cutting, 

sale or removal.

Site specific design criteria 

and mitigation measures 

Slightly higher risk of damage 

to cultural resources than 

alternative 1 because this 

alternative has a high 

projection of tree-cutting, 

sale or removal and road 

construction.

Highest risk of damage to 

cultural resources because 

this alternative has the 

highest projection of treecutting, sale or removal and 

road construction.

Site specific design criteria 

Less risk than alternative 2

due to more acres in the 

upper tier.

Site specific design criteria 

and mitigation measures 

are expected to minimize 

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

Summary—25

Issue or Affected Resource

Alternative 1

Provisions of the 2001 

Roadless Rule

Alternative 2

Proposed Action

Colorado Roadless Rule

Alternative 3

No Action

Forest Plans

Alternative 4 

Colorado Roadless Rule

are expected to minimize 

risk.

Site specific design criteria 

and mitigation measures 

are expected to minimize 

risk.

and mitigation measures 

are expected to minimize 

risk.

Roadless Area 

Characteristics

Minimal effect to roadless 

area characteristics

because there is little 

projected activity to occur.

No consideration or regulatory 

protection of roadless area 

characteristics on 409,500 

acres outside of IRA 

boundaries.

Minimal effect to roadless 

area characteristics

because there is little 

projected activity to occur.

Consideration and protection 

of roadless area 

characteristics on 409,500 

acres within CRA 

boundaries.

More effect to roadless area 

characteristics because 

there is an increase in 

projected activities to occur 

compared to the other 

alternatives. 

Some risk of adverse effects 

to roadless area 

characteristics because 

there are no regulatory 

prohibitions on road 

construction, use of linear 

construction zones or treecutting, sale or removal on 

any of the analysis area. 

Minimal effect to roadless 

area characteristics

because there is little 

projected activity to occur.

Consideration and protection 

of roadless area 

characteristics on 409,500 

acres within CRA 

boundaries.

Air Resources Differences in effects on air quality do not substantially differ between the alternatives. Atmospheric emissions within the analysis 

area are not expected to increase to a level that would be likely to exceed State or federal air quality standards.

Administratively and 

Congressionally 

Designated Areas

There are no differences between the alternatives to administratively or congressionally designated areas because none of the 

alternatives project tree-cutting, sale or removal or road construction in administratively designated areas and tree-cutting, sale 

or removal or road construction is prohibited in congressionally designated areas.

Wilderness Alternatives 1 and 2 have a low likelihood of affecting 

wilderness characteristics because tree-cutting, sale or 

removal and road construction are prohibited in Wilderness 

areas and projected activities within roadless areas are not 

expected to occur adjacent to Wilderness area boundaries.

Higher risk of adverse effect 

to wilderness areas 

because of the high 

projections for tree-cutting, 

sale or removal and road 

construction and a higher 

likelihood that these 

activities could occur 

adjacent to Wilderness 

boundaries.

Same as alternatives 1 and 2.
Roadless Area Conservation; National Forest System Land in Colorado RDEIS

26—Summary