Full opinion text
HOLMES, Circuit Judge. Defendants Forest Service and Defendants-Intervenors-Appellants Environmental Groups appeal the district court’s order setting aside and permanently enjoining the Roadless Area Conservation Rule (“Roadless Rule”), which the Forest Service promulgated in 2001. In setting-aside the Roadless Rule, the district court held that the rule violated the Wilderness Act of 1964 (‘Wilderness Act”), 16 U.S.C. §§ 1131-36, and the National Environmental Policy Act of 1969 (“NEPA”), 42 U.S.C. §§ 4321-70. See Wyoming v. U.S. Dep’t of Agric., 570 F.Supp.2d 1309 (D.Wyo. 2008). On appeal, the Forest Service and the Environmental Groups ask us to hold that the Roadless Rule was not promulgated in violation of the Wilderness Act or NEPA. Furthermore, even if we were to conclude that the rule was promulgated in violation of federal law, they ask us to nevertheless reverse the district court’s order establishing a permanent nationwide injunction. Plaintiff-Appellee State of Wyoming and Intervenor-Appellee Colorado Mining Association (“CMA”) ask us to affirm the district court order on the grounds that the rule does in fact violate the Wilderness Act and NEPA. In the event that we conclude that the Roadless Rule complies with the Wilderness Act and NEPA, they ask us to affirm on the alternate grounds that the rule was promulgated in violation of the Multiple-Use Sustained-Yield Act (“MUSYA”), 16 U.S.C. §§ 528-31, and also the National Forest Management Act (“NFMA”), 16 U.S.C. §§ 1600-14. Exercising jurisdiction pursuant to 28 U.S.C. § 1291, we REVERSE the district court’s order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction. I. BACKGROUND Due to the complexity of this case, we initially offer an overview of the applicable statutory framework, the factual background of the Roadless Rule, and the procedural history. A. Statutory Framework The Forest Service currently manages over 191 million acres of National Forest System (“NFS”) land, including 155 national forests, 20 national grasslands, 8 land utilization projects, 20 research and experimental areas, and 33 “other areas.” 36 C.F.R. § 200.1. The Forest Service is responsible for managing the NFS under, inter alia, the Organic Administration Act of 1897 (“Organic Act”), 16 U.S.C. §§ 473-482, 551, MUSYA, and NFMA. On a general level, these statutes authorize the Forest Service to manage NFS lands for multiple uses. In managing the NFS, however, the Forest Service also must comply with the Wilderness Act and NEPA. These relevant statutes are briefly discussed in turn. In 1897, Congress passed the Organic Act. 16 U.S.C. §§ 473-482, 551. The Act “established a limited multiple-use mandate for management of the National Forests,” Wyoming, 570 F.Supp.2d at 1320, including such purposes as “improving] and protect[ing] the forest[s],” “securing favorable conditions of water flows,” and “furnish[ing] a continuous supply of timber for the use and necessities of citizens of the United States.” 16 U.S.C. § 475. The Act authorizes the Secretary of Agriculture to “make provisions for the protection against destruction by fire and depredations upon the public forests and national forests,” in order “to regulate their occupancy and use and to preserve the forests thereon from destruction.” Id. § 551. More than sixty years later, in 1960, Congress enacted MUSYA. 16 U.S.C. §§ 528-31. MUSYA codified the multiple-use mandate first articulated in the Organic Act, directing the Forest Service to “administer the renewable surface resources of the national forests for multiple use and sustained yield,” including for the purposes of “outdoor recreation, range, timber, watershed, and wildlife and fish purposes.” Id. §§ 528, 529. In 1964, Congress enacted the Wilderness Act, 16 U.S.C. §§ 1131-36, which “established a National Wilderness Preservation System to be composed of federally owned areas designated by Congress as ‘wilderness areas,’ ” id. § 1131. More specifically, the Act put in place a process under which Congress designates “wilderness areas,” id. § 1132, and established requirements for the management and protection of such areas, see id. § 1133 (listing the uses permitted in congressionally designated wilderness areas). In order to aid Congress in designating “wilderness,” the Act required the Forest Service to review “primitive” areas of the NFS to determine their “suitability or nonsuitability for preservation as wilderness.” Id. § 1132(b). In 1972, the Forest Service completed the Roadless Area Review and Evaluation project (RARE I), which resulted in a nationwide inventory of NFS areas — totaling approximately 56 million acres — -that the agency deemed to be suitable for “wilderness” designation pursuant to the Wilderness Act. However, the RARE I inventory was abandoned following a successful judicial challenge under NEPA. See Wyo. Outdoor Coordinating Council v. Butz, 484 F.2d 1244 (10th Cir.1973). In 1976, Congress passed NFMA. 16 U.S.C. §§ 1600-14. The Act, “which is primarily concerned with planning,” Utah Envtl. Cong. v. Richmond, 483 F.3d 1127, 1131 (10th Cir.2007), “requires the Forest Service to ‘develop, maintain, and, as appropriate, revise land and resource management plans for units of the National Forest System.’ ” Citizens’ Comm. to Save Our Canyons v. Krueger, 513 F.3d 1169, 1176 (10th Cir.2008) (quoting 16 U.S.C. § 1604(a)). NFMA establishes both substantive and procedural requirements for the development and implementation of forest management plans under the Act, see 16 U.S.C. § 1604, including the requirement that each forest plan comply with MUSYA’s multiple-use mandate, id. § 1604(e)(1). From 1977 until 1979, the Forest Service embarked on a second Roadless Area Review and Evaluation project (RARE II), which again created a national inventory of roadless areas that were potentially suitable for “wilderness” designation under the Wilderness Act. See, e.g., California v. Block, 690 F.2d 753, 758 (9th Cir.1982) (describing the development of the RARE II inventory). Based on the RARE II inventory (and subsequent presidential recommendations), see 16 U.S.C. § 1132, Congress designated several NFS areas as “wilderness,” which — combined with the designations included in the Wilderness Act itself, see 16 U.S.C. § 1132(a) — total approximately 35 million acres. See 66 Fed.Reg. 35,918, 35,919 (July 10, 2001). B. History of the Roadless Rule The RARE II undertaking, completed in 1979, produced a nationwide inventory of roadless areas that the Forest Service found worthy of some level of protection. Over the next two decades, however, the Forest Service began permitting road construction to occur in some of those inventoried roadless areas (“IRAs”) on a site-specific basis. 66 Fed.Reg. 3244, 3246 (Jan. 12, 2001); see also Kootenai Tribe of Idaho v. Veneman, 313 F.3d 1094, 1105 (9th Cir.2002) (stating that, in 1982, the Forest Service started “permitting] road construction, industrial logging!,] and other development in inventoried roadless areas on a local, site-specific basis” (citing Block, 690 F.2d 753)), abrogated in part on other grounds by Wilderness Soc’y v. U.S. Forest Serv., 630 F.3d 1173, 1180 (9th Cir.2011) (abandoning the “federal defendant” rule and holding that “[w]hen considering motions to intervene of right ..., courts need no longer apply a categorical prohibition on intervention on the merits, or liability phase, of NEPA actions”). During that time, roads were constructed, and other development occurred, on 2.8 million acres of those IRAs. 66 Fed.Reg. at 3246; Kootenai Tribe, 313 F.3d at 1105. In the late 1990s, the Forest Service began to reevaluate its road-management policy in response to changes in public opinion, shifts in resource demands, budget constraints regarding the management of the NFS road system, and an increase in scientific knowledge regarding the effects that roads have on NFS lands. See 63 Fed.Reg. 4350, 4350 (Jan. 28, 1998). The agency published an advance notice of proposed rulemaking in January of 1998, which solicited public comment on future regulation and protection of IRAs. Id. The Forest Service thereafter adopted an eighteen-month moratorium on road construction in most IRAs — the “Interim Roadless Rule” — which ran from March 1999 through August 2000. 64 Fed.Reg. 7290, 7290 (Feb. 12, 1999). The Interim Road-less Rule “temporarily suspended] decisionmaking regarding road construction and reconstruction in many unroaded areas within the National Forest System,” in order to “retain resource management options in those unroaded areas subject to suspension from the potentially adverse effects associated with road construction, while the Forest Service develop[ed] a revised road management policy.” Id. While the Interim Roadless Rule was in effect, in October of 1999, President William J. Clinton “direct[ed] the Forest Service to develop ... regulations to provide appropriate long-term protection for most or all of these currently inventoried ‘road-less’ areas” in the NFS. Aplt.App. at 1524 (Memorandum from President William Clinton to the Secretary of Agriculture (Oct. 13, 1999)). On October 13, 1999, in response to President Clinton’s directive, as well as public comments received on the 1998 advanced notice of proposed rulemaking and the Interim Roadless Rule, the Forest Service published a notice of intent (“NOI”) to prepare an environmental impact statement (“EIS”) in accordance with NEPA, and to “initiat[e] a public rulemaking process to propose the protection of remaining roadless areas within the National Forest System.” 64 Fed.Reg. 56,-306, 56,306 (Oct. 19, 1999). The NOI announced the agency’s intent to promulgate a two-part rule for protection of roadless areas: (1) “[P]art one would immediately restrict certain activities, such as road construction, in unroaded portions of inventoried roadless areas, as previously identified in RARE II and existing forest plan inventories”; and (2) “[p]art two would establish national direction for managing [IRAs], and for determining whether and to what extent similar protections should be extended to uninventoried roadless areas,” a process that “would be implemented at the forest plan level through the plan amendment and NEPA process.” Id. at 56,307. The NOI also initiated a sixty-day “scoping period,” during which the agency sought public comment on the nature and scope of the issues and alternatives to be analyzed during the NEPA process. Id. During the sixty-day scoping period, the Forest Service received more than 517,000 comments in response to the NOI, held 187 meetings around the nation (including several in Wyoming) attended by approximately 16,000 citizens, and launched a Roadless Area Conservation website (road-less.fs.fed.us) to provide information about the rulemaking. 66 Fed.Reg. at 3248; 64 Fed.Reg. 67,822, 67,825-29 (Dec. 3, 1999). Despite several requests, the Forest Service declined to extend the scoping period beyond the initial sixty days. On May 10, 2000, the Forest Service issued a draft EIS (“DEIS”) and proposed Roadless Rule. See generally 65 Fed.Reg. 30,276 (May 10, 2000); ApltApp. at 425 (Draft Environmental Impact Statement, dated May 2000) [hereinafter DEIS]. The DEIS identified 54.3 million acres of IRAs that were subject to the proposed rule. 65 Fed.Reg. at 30,276. The stated purposes of the proposed rule were “to immediately stop activities that have the greatest likelihood of degrading desirable characteristics of inventoried roadless areas,” and “to ensure that ecological and social characteristics of inventoried roadless and other unroaded areas are identified and considered through local forest planning efforts.” DEIS at S — 4; see also id. at 1-12 (stating that the first objective of the rule was to “[p]revent activities that can most directly threaten [IRAs] by implementing national prohibitions against road construction and reconstruction”). The proposed rule was two-fold, composed of (1) a “Prohibition Rule,” which banned road construction and reconstructions in IRAs, and (2) a “Procedural Rule,” which required forest managers to identify additional roadless areas during the forest planning process and determine whether such areas warranted protection under individual forest plans. See 65 Fed.Reg. at 30,288 (to be codified at 36 C.F.R. §§ 294.12, 294.13). The Forest Service considered four alternatives to the Prohibition Rule in detail in the DEIS — a “no-action” alternative and three alternatives prohibiting road building and timber harvest to varying degrees. See id. at 2-3 to 2-6. Specifically, the four prohibition alternatives analyzed were: (1) Alternative 1 — the “no action” alternative, id. at 2-4; (2) Alternative 2 — a prohibition on “road construction and reconstruction within unroaded portions of [IRAs],” id. at 2^1 to 2-5; (3) Alternative 3 — a prohibition on “road construction, reconstruction, and timber harvest except for stewardship purposes within unroaded portions of [IRAs],” id. at 2-5; and (4) Alternative 4 — a prohibition on “road construction, reconstruction[,] and all timber harvest within unroaded portions of [IRAs],” id. at 2-6. In the DEIS, the Forest Service designated Alternative 2 as the preferred alternative for the prohibition rule. Id. at 2-13. Other alternatives to the Prohibition Rule were addressed by the Forest Service, such as allowing more (rather than less) road building and development, but those alternatives were eliminated from detailed environmental analysis because they were inconsistent with the purpose of protecting IRAs or for other reasons. Id. at 2-15 to 2-20. The Forest Service provided sixty-nine days for public comment on the DEIS and proposed rule, 65 Fed. Reg. at 30,276, during which it received more than a million responses and held more that 430 public meetings drawing at least 23,000 people nationwide. 66 Fed. Reg. at 3248. In November 2000, the Forest Service issued a final EIS (“FEIS”). 65 Fed.Reg. 69,512 (Nov. 17, 2000); Aplt.App. at 520 (Final Environmental Impact Statement, dated Nov. 9, 2009) [hereinafter FEIS]. The FEIS included several changes to the proposed action that were not included in the DEIS. First, it increased the total acreage of IRAs subject to the Prohibition Rule from 54.3 million acres to 58.5 million acres. FEIS at 2-23. The revised figure included 4.2 million acres of IRAs not identified in the DEIS or proposed rule. Id. Second, it made the rule applicable to both the “unroaded” and “roaded” portions of IRAs; that is, the Roadless Rule would “now apply to the entire area within the boundaries of an [IRA],” whereas the 2.8 million acres of “roaded” IRAs were not subject to the prohibitions in the proposed rule as it was described in the DEIS. Id. Third, the FEIS changed the preferred alternative — previously identified as Alternative 2, which prohibited road construction and reconstruction in IRAs — to Alternative 3, which, as described in the FEIS, prohibited “[r]oad construction, reconstruction (including temporary construction) and timber harvest except for stewardship purposes” in IRAs, subject to a few limited exceptions. FEIS at 2-13 to 2-14 (emphasis added). Fourth, the FEIS eliminated the procedural aspect of the rule, leaving only the Prohibition Rule, due to the Forest Service’s decision to incorporate such procedures into a separate and distinct set of forest planning regulations. See FEIS at 1-16 (stating that “the Forest Service determined that the procedures contemplated in the [proposed] Roadless Rule should be an explicit part of the plan revision process, and addressed them at 36 CFR 219.9(b)(8) of the final Planning Regulations”). Following the issuance of the FEIS, the Forest Service received additional public comments on the FEIS and the modified preferred alternative. 66 Fed.Reg. at 3248. The comments submitted in response to the FEIS “were considered by the agency in the development of the final rule” and were admitted into the administrative record. Id. On January 12, 2001, the Forest Service issued the final Roadless Rule and the Record of Decision on the rule. 66 Fed. Reg. at 3244-72. The final Roadless Rule — which mirrors the preferred alternative from the FEIS (Alternative 3)— prohibits road construction and reconstruction in IRAs, and prohibits the cutting, sale, or removal of timber from IRAs, subject to limited exceptions. Id. at 3272-73 (to be codified at 36 C.F.R. §§ 294.10-,14). The final Roadless Rule was applicable to the 58.5 million acres of IRAs identified in the FEIS, which amounts to approximately one-third of all NFS lands and approximately 2% of the land base of the continental United States. 66 Fed.Reg. at 3245. As specific to Wyoming, “[t]he Roadless Rule affects 3.25 million acres (or 35%) of the 9.2 million acres of National Forest System land in [the state].” Wyoming, 570 F.Supp.2d at 1326; see also FEIS at 3-4 tbl.3-1, 3-61 tbl.3-9, A-4. The Roadless Rule was to take effect on March 12, 2001. 66 Fed.Reg. at 3244. Under the Roadless Rule, as promulgated, “this vast national forest acreage, for better or worse, was more committed to pristine wilderness, and less amenable to road development for purposes permitted by the Forest Service.” Kootenai Tribe, 313 F.3d at 1106. C. Procedural History This is not the first instance in which this court has considered a challenge to the Roadless Rule brought by Wyoming. On May 18, 2001, shortly after the Road-less Rule was promulgated, Wyoming filed its first complaint in the United States District Court for the District of Wyoming challenging the legality of the Roadless Rule under several federal environmental statutes, including NEPA, the Wilderness Act, the Wyoming Wilderness Act of 1984, NFMA, and MUSYA. A number of environmental organizations intervened on behalf of the Forest Service, in defense of the rule. On July 14, 2003, the Wyoming district court ruled that the Roadless Rule was promulgated in violation of NEPA and the Wilderness Act, and therefore permanently enjoined enforcement of the rule. Wyoming v. U.S. Dep’t of Agric., 277 F.Supp.2d 1197, 1239 (D.Wyo.2003). The Forest Service chose not to appeal the district court’s decision to this court; however, the Defendant-Intervenors did file an appeal with the Tenth Circuit. During the pendency of that appeal — in May of 2005 — the Forest Service adopted the State Petitions Rule, which superseded the Roadless Rule. See State Petitions for Inventoried Roadless Area Management, 70 Fed.Reg. 25,654 (May 13, 2005) (to be codified at 36 C.F.R. pt. 294). Because the Roadless Rule had been superseded, this court dismissed the appeal as moot, vacated the district court’s July 14, 2003, decision, and remanded the case to the district court to dismiss without prejudice. Wyoming v. U.S. Dep’t of Agric., 414 F.3d 1207, 1213 (10th Cir.2005). Subsequently, several states and environmental groups challenged the Forest Service’s State Petitions Rule in the United States District Court for the Northern District of California. On October 11, 2006, a district court judge of that court set aside the State Petitions Rule for violating NEPA and the Endangered Species Act of 1973, 16 U.S.C. §§ 1531-44, and reinstated the Roadless Rule, despite the fact that the Wyoming district court had already found that the rule violated federal law. California ex rel. Lockyer v. U.S. Dep’t of Agric., 459 F.Supp.2d 874 (N.D.Cal.2006). After the Roadless Rule was reinstated by the California district court, Wyoming brought a renewed challenge to the rule in the District of Wyoming, asserting violations of the Wilderness Act, NEPA, MUS-YA, and NFMA. On August 12, 2008, the Wyoming district court ruled — for the second time — that the Roadless Rule was promulgated in violation of the Wilderness Act and NEPA, and issued a permanent, nationwide injunction. Wyoming v. U.S. Dep’t of Agric., 570 F.Supp.2d 1309, 1355 (D.Wyo.2008). The Environmental Groups filed a timely appeal with this court. II. DISCUSSION A. Standard of Review Because NEPA, NFMA, MUSYA, and the Wilderness Act do not provide a private right of action, we review the Forest Service’s promulgation of the Roadless Rule as “final agency action” under the Administrative Procedure Act (“APA”), 5 U.S.C. §§ 551-59. E.g., Forest Guardians v. U.S. Forest Serv., 641 F.3d 423, 428 (10th Cir.2011) (per curiam); Utah Envtl. Cong. v. Russell, 518 F.3d 817, 823 (10th Cir.2008); Utah Envtl. Cong. v. Bosworth, 443 F.3d 732, 739 (10th Cir.2006). Under the APA, we review the district court’s decision de novo, Forest Guardians, 641 F.3d at 428, but we will not overturn the agency’s action unless it is “arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law.” 5 U.S.C. § 706(2)(A); accord New Mexico ex rel. Richardson v. Bureau of Land Mgmt., 565 F.3d 683, 704 (10th Cir.2009). In conducting our review, “we must determine whether the [agency]: (1) acted within the scope of [its] authority, (2) complied with prescribed procedures, and (3) took action that was neither arbitrary and capricious, nor an abuse of discretion.” Forest Guardians v. U.S. Fish & Wildlife Serv., 611 F.3d 692, 704 (10th Cir.2010) (alterations in original) (internal quotation marks omitted). Agency action is “arbitrary and capricious” if the agency “has relied on factors which Congress has not intended it to consider, entirely failed to consider an important aspect of the problem, offered an explanation for its decision that runs counter to the evidence before the agency,” or if the agency action “is so implausible that it could not be ascribed to a difference in view or the product of agency expertise.” Copar Pumice Co. v. Tidwell, 603 F.3d 780, 793-94 (10th Cir.2010) (quoting Motor Vehicle Mfrs. Ass’n of the U.S. v. State Farm Mut. Auto. Ins. Co., 463 U.S. 29, 43, 103 S.Ct. 2856, 77 L.Ed.2d 443 (1983)) (internal quotation marks omitted). In applying this standard, we also “accord agency action a presumption of validity,” and “the burden is on the petitioner to demonstrate that the action is arbitrary and capricious.” Tidwell, 603 F.3d at 793. We review the district court’s order of injunctive relief for abuse of discretion. FTC v. Accusearch Inc., 570 F.3d 1187, 1201 (10th Cir.2009). “An abuse of discretion occurs only when the trial court bases its decision on an erroneous conclusion of law or where there is no rational basis in the evidence for the ruling.” Wilderness Workshop v. U.S. Bureau of Land Mgmt., 531 F.3d 1220, 1223-24 (10th Cir.2008). We have previously characterized an “abuse of discretion” as “an arbitrary, capricious, whimsical, or manifestly unreasonable judgment.” Attorney Gen. of Okla. v. Tyson Foods, Inc., 565 F.3d 769, 776 (10th Cir.2009). B. Wilderness Act Claim Wyoming’s Wilderness Act claim asserts that the Roadless Rule constitutes a de facto designation of “wilderness” in contravention of the process established by Congress in the Wilderness Act of 1964. The district court agreed, holding that the “Forest Service, through the promulgation of the Roadless Rule, designated 58.5 million acres of National Forest land as a de facto wilderness area in violation of the Wilderness Act,” and therefore the rule was “promulgated in excess of [the] Forest Service’s statutory jurisdiction and authority.” Wyoming, 570 F.Supp.2d at 1349-50. We conclude that the district court erred in finding that the Forest Service promulgated the rule in violation of the Wilderness Act. 1. Overview of Wilderness Act Congress passed the Wilderness Act in 1964, 16 U.S.C. §§ 1131-36, for the purpose of “securing] for the American people of present and future generations the benefits of an enduring resource of wilderness.” Id. § 1131(a). The Wilderness Act established the National Wilderness Preservation System, which was “to be composed of federally owned areas designated by Congress as ‘wilderness areas.’” Id. Congress immediately designated certain areas as “wilderness areas” in the Act. See id. § 1132(a) (“All areas within the national forests classified ... by the Secretary of Agriculture or the Chief of the Forest Service as ‘wilderness’, ‘wild’, or ‘canoe’ are hereby designated as wilderness areas.”). The Wilderness Act also established a process by which NFS lands could be designated as “wilderness areas” in the future. Id. § 1132(b). Under this process for designating “wilderness” in the future, the Secretary of Agriculture determines which NFS lands are suitable for preservation as wilderness and reports those findings to the President, who then submits recommendations to Congress as to which NFS lands should be regulated as wilderness areas under the Act. Id. Such lands actually become “wilderness areas” protected by the provisions of the Wilderness Act only if Congress enacts legislation to that effect. Id. Indeed, Congress explicitly stated that “no Federal lands shall be designated as ‘wilderness areas’ except as provided for in [the Wilderness Act] or by a subsequent Act.” Id. § 1131(a). The Act defines “wilderness” as “an area where the earth and its community of life are untrammeled by man, where man himself is a visitor who does not remain,” as well as “an area of undeveloped Federal land retaining its primeval character and influence, without permanent improvements or human habitation.” Id. § 1131(c). Congress further defined “wilderness” as an area that (1) generally appears to have been affected primarily by the forces of nature, with the imprint of man’s work substantially unnoticeable; (2) has outstanding opportunities for solitude or a primitive and unconfined type of recreation; (3) has at least five thousand acres of land or is of sufficient size as to make practicable its preservation and use in an unimpaired condition; and (4) may also contain ecological, geological, or other features of scientific, educational, scenic, or historical value. Id. Areas designated as “wilderness areas” by Congress under the Act must be maintained so as to “preserv[e] the wilderness character of the area” and “shall be devoted to the public purposes of recreational, scenic, scientific, educational, conservation, and historical use,” unless an exception applies. Id. § 1133(b). In order to preserve the character of areas designated by Congress as “wilderness,” the Act prohibits a wide array of uses within such areas: [T]here shall be no commercial enterprise and no permanent road within any wilderness area designated by this chapter and, except as necessary to meet minimum requirements for the administration of the area for the purpose of this chapter (including measures required in emergencies involving the health and safety of persons within the area), there shall be no temporary road, no use of motor vehicles, motorized equipment or motorboats, no landing of aircraft, no other form of mechanical transport, and no structure or installation within any such area. Id. § 1133(c). The Act includes seven “special provisions,” which serve as exceptions to the general use prohibitions found in § 1133(c). See id. § 1133(d)(l)-(7). These “special provisions” allow, among other things, for (1) “measures ... [for] control of fire, insects, and diseases, subject to such conditions as the Secretary deems desirable”; (2) “prospecting” and activities carried out “for the purpose of gathering information about mineral or other resources, if such activity is carried on in a manner compatible with the preservation of the wilderness environment”; (3) certain development of water resources, if approved by the President; (4) “grazing of livestock,” but only if established before September 1964; and (5) “[c]ommercial services ... to the extent necessary for activities which are proper for realizing the recreational or other wilderness purposes of the areas.” Id. § 1133(d)(1), (2), (4), & (5). Lastly, the Wilderness Act establishes that its provisions are “declared to be within and supplemental to the purposes for which national forests ... are established and administered,” id. § 1133(a), and therefore Congress made clear that “[njothing in [the Wilderness Act] shall be deemed to be in interference with the purpose for which national forests are established as set forth in the [Organic Act] (30 Stat. 11), and [MUSYA] (74 Stat. 215).” Id. § 1133(a)(1). 2. Discussion As stated by the district court, the narrow issue presented by this claim is “whether the Forest Service has usurped Congresses] power regarding access to, and management of, public lands by a de facto designation of ‘wilderness’ in violation of the Wilderness Act of 1964.” Wyoming, 570 F.Supp.2d at 1346. The district court held that the Roadless Rule established de facto wilderness areas and was therefore promulgated in violation of the Wilderness Act, which gives Congress the sole authority to establish “wilderness areas.” Mat 1349-50. On appeal, the Forest Service first argues that the Wilderness Act did not repeal or in any way limit its broad authority to regulate NFS lands for conservation purposes, including “wilderness,” and therefore it was authorized to promulgate the Roadless Rule. In the alternative, even assuming, arguendo, that the Wilderness Act did repeal or limit the Forest Service’s authority to regulate “wilderness areas” by administrative rule, the Forest Service and the Environmental Groups argue that the IRAs governed by the Roadless Rule are not de facto wilderness areas. Therefore, they assert that the Roadless Rule was a valid exercise of the authority granted under the Organic Act and MUSYA “to manage NFS lands for an array of uses or combinations of use, including conservation uses that fall short of statutory ‘wilderness’ designations.” Forest Serv. Opening Br. at 32 (emphasis added). We agree with the latter argument — viz., that the Forest Service did not usurp congressional authority because the Roadless Rule did not establish de facto wilderness areas— and, therefore, conclude that the district court erred in holding otherwise. Accordingly, we need not address the first argument advanced by the Forest Service regarding whether it retains the authority under the Organic Act and MUSYA to regulate de facto wilderness areas by administrative rule. a. Roadless Rule Did Not Establish De Facto Wilderness Areas The district court’s conclusion that the Roadless Rule created de facto wilderness in violation of the Wilderness Act was based largely on its finding that “wilderness areas” governed by the Wilderness Act and IRAs governed by the Roadless Rule “are essentially the same,” and that “[i]n fact, uses in [IRAs] are even more restricted than those permitted in congressionally designated wilderness areas.” Wyoming, 570 F.Supp.2d at 1349. However, a comparison of the provisions of the Wilderness Act and the Roadless Rule demonstrates that IRAs and wilderness areas are not functionally equivalent or “essentially the same.” To the contrary, the two types of areas are distinct. In fact, such a comparison demonstrates that the scope of the Wilderness Act is broader than the scope of the Roadless Rule; that is, the Wilderness Act is more restrictive and prohibitive than the Roadless Rule. As a general matter, the Roadless Rule restricts only two activities — road construction and commercial timber harvesting, unless an exception applies. See 66 Fed.Reg. at 3272-73 (to be codified at 36 C.F.R. §§ 294.12-.13). On the other hand, although the Wilderness Act likewise prohibits permanent and temporary roads and commercial logging, it additionally prohibits all “commercial enterprise,” “motor vehicles, motorized equipment or motorboats,” all “form[s] of mechanical transport,” and any “structure or installation,” unless an exception applies. 16 U.S.C. § 1133(c). This rudimentary comparison of the general use prohibitions in IRAs and wilderness areas demonstrates that they are not the same; the uses prohibited in wilderness areas under the Wilderness Act are greater in number and scope than those prohibited in IRAs under the Roadless Rule. We acknowledge that the Wilderness Act and Roadless Rule do in fact overlap in coverage in many ways. However, the issue we are to consider is whether the IRAs governed by the Roadless Rule are de facto wilderness areas; that is, whether the Roadless Rule essentially mirrors the Wilderness Act by a different label. A closer examination of the precise differences between IRAs and wilderness areas further demonstrates that the Roadless Rule does not establish de facto wilderness. First, although the Wilderness Act prohibits permanent structures and installations, the Roadless Rule does not prohibit the construction of permanent or temporary structures or installations. Compare 16 U.S.C. § 1133(c), with 66 Fed.Reg. at 3272-73 (to be codified at 36 C.F.R. §§ 294.10-14). Therefore, structures and installations that can be erected without the construction of a new road — for example, through the use of an existing road— are permitted in IRAs, but not in wilderness areas. Second, the Wilderness Act imposes significantly more stringent prohibitions on recreational activities. Under the Wilderness Act, any “use of motor vehicles, motorized equipment or motorboats, ... landing of aircraft, ... [or] other form of mechanical transport” is prohibited. 16 U.S.C. § 1133(c). On the other hand, the Roadless Rule contains no prohibitions on the use of motorized vehicles or equipment, boats or aircraft, or other forms of mechanical transport. Therefore, many recreational uses allowed to continue under the Roadless Rule — such as off-road vehicle use, biking, snowmobiling, and other motorized and mechanical activities— would be prohibited under the Wilderness Act. See, e.g., 66 Fed.Reg. at 3245 (stating that “unlike Wilderness,” the Roadless Rule permits the “use of mountain bikes, and other mechanized means of travel”); id. at 3249 (“The Roadless [Rule], unlike the establishment of wilderness areas, will allow a multitude of activities including motorized uses....”); id. at 3267 (“[IRAs] provide a remote recreation experience without the activity restrictions of Wilderness (for example, off-highway vehicle use and mountain biking).”). Third, the Wilderness Act is more restrictive in terms of road maintenance, road construction, and use of existing roads. The Wilderness Act prohibits any “permanent road” or any “temporary road,” and road maintenance activities, subject to limited exceptions, and prohibits any use of motor vehicles. 16 U.S.C. § 1133(c); 36 C.F.R. § 293.6. On the other hand, the Roadless Rule allows all existing classified roads — defined as roads “wholly or partially within or adjacent to [NFS] lands that [are] determined to be needed for long-term motor vehicle access, including State roads, county roads, privately owned roads, National Forest System roads, and other roads authorized by the Forest Service,” 66 Fed.Reg. at 3272 (to be codified at 36 C.F.R. § 294.11) — to be maintained. Id. at 3273 (to be codified at 36 C.F.R. § 294.12(c)). Therefore, unlike the Wilderness Act, the Roadless Rule permits unlimited maintenance of all existing roads and does not prohibit the use of motorized vehicles or other motorized transportation on such existing roads. Furthermore, the Roadless Rule provides broader exceptions for when new road construction or reconstruction can occur. For example, unlike in wilderness areas, “a road may be constructed or reconstructed in an [IRA] ... as provided for by statute or treaty,” id. at 3272 (to be codified at 36 C.F.R. § 294.12(b)(3)); when “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, [§ ] 311 of the Clean Water Act, or the Oil Pollution Act,” id. (to be codified at 36 C.F.R. § 294.12(b)(2)); or when the “Secretary of Agriculture determines that a Federal Aid Highway project ... is in the public interest or is consistent with the purposes for which the land was reserved or acquired,” id. (to be codified at 36 C.F.R. § 294.12(b)(6)), among other instances. The Wilderness Act includes no exceptions of this kind to its prohibition of temporary and permanent roads. Fourth, the Roadless Rule is less restrictive in terms of “grazing.” Under the Wilderness Act’s mandate that “there shall be no commercial enterprise ... within any wilderness area,” 16 U.S.C. § 1133(c), commercial livestock grazing is prohibited. The Act includes a grandfather clause that permits “the grazing of livestock ... [that was] established prior to September 3, 1964,” id. § 1133(d)(4)(2), more than four decades ago, but otherwise completely bars such activity. By contrast, the Road-less Rule does not explicitly prohibit any type of “commercial enterprise,” with the exception of commercial logging, and therefore permits commercial grazing within IRAs. The district court found this distinction meaningless because “one could not meaningfully set cattle out to pasture in a roadless area with no way of rounding those cattle back up or tracking them in and out of the forest allotment,” unless a new road was constructed. Wyoming, 570 F.Supp.2d at 1350. However, this conclusion does not take into account that all existing roads — as well as any roads constructed or reconstructed under exceptions to the Roadless Rule — could be used to facilitate commercial grazing. This would not be permitted in a wilderness areas due to the general prohibition on commercial enterprises (unless such grazing was established more than four decades ago), as well as the Act’s prohibition on the use of motorized vehicles or equipment. Accordingly, the court’s dismissal of this distinction was unfounded. Fifth, the Roadless Rule allows for mineral development to a greater extent than does the Wilderness Act. Although the Wilderness Act initially permitted mineral development under United States mining laws, wilderness areas governed by the Act are now closed to mineral-development activities. 16 U.S.C. § 1133(d)(3). On the other hand, the Roadless Rule imposes no general prohibition on mining or mineral-development activities, other than the limitations imposed through the road-building prohibition. Therefore, “leasing activities not dependent on road construction, such as directional (slant) drilling and underground development,” and mineral-leasing activities that could be carried out through utilization of existing roads, “would not be affected by the prohibition.” 66 Fed.Reg. at 3265; see also Wilderness Workshop, 531 F.3d at 1224-28 (affirming the district court’s holding that the Forest Service and Bureau of Land Management had not acted arbitrarily, capriciously, or not in accordance with law in approving the installation of a natural-gas pipeline across an IRA protected by the Roadless Rule; the agencies’ approval was based on the conelusion that “there would be no violation of the Roadless Rule because the proposed [natural-gas] pipeline could be built within IRA’s [sic] without road construction” (internal quotation marks omitted)). The exceptions to the Roadless Rule’s road-building prohibition would also permit new road construction or reconstruction for mineral development in certain situations. Under the exception for existing mineral leases, road construction is permitted “in conjunction with the continuation, extension, or renewal of a 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.” 66 Fed.Reg. at 3272-73 (to be codified at 36 C.F.R. § 294.12(b)(7)). This exception “extends indefinitely the timeframe for which roads can be constructed on areas currently under lease.” Id. at 3265-66. In addition, under the exception permitting road construction “as provided for by statute or treaty,” id. at 3272 (to be codified at 36 C.F.R. § 294.12(b)(3)), “[reasonable access to conduct exploration and development of valid claims for locatable minerals (metallic and nonmetallic minerals subject to appropriation under the General Mining Law of 1872)” would not be prohibited under the Roadless Rule. Id. at 3268. “Reasonable access” could “involve some level of road construction that, depending on the stage of exploration or development, could range from helicopters, temporary or unimproved roads, more permanent, improved roads, or nonmotorized transport.” Id. In sum, the Roadless Rule is less restrictive than the Wilderness Act in regard to mineral development. These distinctions clearly demonstrate that wilderness areas governed by the Wilderness Act and IRAs governed by the Roadless Rule are not only distinct, but that the Wilderness Act is more restrictive and prohibitive than the Roadless Rule. Accordingly, we conclude that the IRAs governed by the Roadless Rule are not de facto administrative wilderness areas; therefore, the district court erred by holding otherwise. In reaching the contrary conclusion that “uses in [IRAs] are even more restricted than those permitted in congressionally designated wilderness areas,” Wyoming, 570 F.Supp.2d at 1349, the district court relied heavily on one exception found in the Roadless Rule. The district court stated that a road could be constructed in a wilderness area to “control fire, insects, and diseases,” whereas a road could only be constructed in a roadless area in the “case of an imminent flood, fire, or other catastrophic event that, without intervention, would cause the loss of life or property.” Compare 16 U.S.C. § 1133(d)(1) ivith 36 C.F.R. § 294.12(b)(1). Id. at 1349-50 (emphasis added). However, this distinction alone, when viewed in light of the numerous distinctions discussed above, does not demonstrate that the uses in IRAs are overall more restricted than those permitted in wilderness areas. The district court’s reliance on this single distinction in concluding that the Roadless Rule is more restrictive than the Wilderness Act was erroneous. In sum, we conclude that the Roadless Rule did not designate de facto administrative wilderness areas in contravention of the procedures set out in the Wilderness Act. b. Roadless Rule Was Promulgated Pursuant to Broad Authority Granted in Organic Act and MUSYA Because we conclude that the Roadless Rule did not establish de facto wilderness areas in contravention of the procedures established in the Wilderness Act, and therefore did not usurp congressional authority under the Act, the only remaining issue is whether the Forest Service otherwise acted within its statutory authority in promulgating the Roadless Rule. We conclude that the Forest Service acted within the authority that Congress granted to it under the Organic Act and MUSYA. As stated above, the Organic Act of 1897 empowers the Secretary of Agriculture, through the Forest Service, to “make provisions for the protection against destruction by fire and depredations upon the public forests and national forests” and “make such rules and regulations ... to regulate [the national forests’] occupancy and use and to preserve the forests thereon from destruction.” 16 U.S.C. § 551. The Organic Act gives the Forest Service broad discretion to regulate the national forests, including for conservation purposes. See United States v. Grimaud, 220 U.S. 506, 31 S.Ct. 480, 55 L.Ed. 563 (1911) (discussing the general authority granted under the Organic Act and upholding the Secretary of Agriculture’s establishment of criminal penalties for violations of forest-wide grazing regulations); City & Cnty. of Denver v. Bergland, 695 F.2d 465, 476 (10th Cir.1982) (stating that the Organic Act “confers upon the forest service the duty to protect the forests from injury and trespass, and the power to condition their use and prohibit unauthorized uses”); United States v. Hymans, 463 F.2d 615, 617 (10th Cir.1972) (discussing the broad authority delegated to the Forest Service under the Organic Act to regulate the “occupancy and use” of national forests (citing McMichael v. United States, 355 F.2d 283 (9th Cir.1965))); see also Burlison v. United States, 533 F.3d 419, 435 (6th Cir.2008) (“Congress has given the Forest Service broad power [under the Organic Act] to regulate Forest System land.” (citation omitted) (internal quotation marks omitted)); Skranak v. Castenada, 425 F.3d 1213, 1217 (9th Cir.2005) (stating that “16 U.S.C. § 551 confers broad powers on the Forest Service to regulate roads for the good of the forests” (citing Clouser v. Espy, 42 F.3d 1522, 1538 (9th Cir.1994))); Wilson v. Block, 708 F.2d 735, 758 (D.C.Cir.1983) (“The Department of Agriculture now has adequate authority to issue revocable permits for all purposes under the [Organic Act of] 1897.” (citation omitted) (internal quotation marks omitted)); United States v. Weiss, 642 F.2d 296, 298 (9th Cir.1981) (“The authority of the Secretary [of Agriculture] to regulate activity on national forest land pursuant to [16 U.S.C. § 551] has been upheld in a variety of ... instances.”); Koniag, Inc., Vill. of Uyak v. Andrus, 580 F.2d 601, 605 (D.C.Cir.1978) (The “Forest Service and the Fish and Wildlife Service have broad mandates to protect our forests and wildlife.” (citing 16 U.S.C. § 551)); Mountain States Tel. & Tel. Co. v. United States, 499 F.2d 611, 614 (Ct.Cl.1974) (stating that the Organic Act “reveals a clear intent of Congress to commit regulation of the national forests to the discretion of the Secretary [of Agriculture]”); McMichael, 355 F.2d at 286 (upholding Department of Agriculture’s regulations establishing primitive, wilderness, and wild areas and providing limitations upon the use to be made of such areas under the Organic Act). The broad rulemaking authority granted the Forest Service under the Organic Act — to regulate “occupancy and use” of NFS lands and “to preserve the forests thereon from destruction” (for example, from road construction and logging) — is alone sufficient to support the Forest Service’s promulgation of the Roadless Rule. See Kootenai Tribe, 313 F.3d at 1117 n. 20 (“[T]he general rulemaking authority of the 1897 Organic Act is sufficient to support the Roadless Rule’s promulgation to achieve the objects of our National Forest System.” (citing 16 U.S.C. § 551; McMichael, 355 F.2d 283)). Indeed, the Forest Service cited this authority in the final Roadless Rule. 66 Fed.Reg. at 3272 (citing 16 U.S.C. §§ 472, 551). The Forest Service was further authorized to manage NFS lands through MUS-YA, which reaffirmed the Forest Service’s authority to manage national forests for a wide range of uses. Specifically, MUSYA directs the Forest Service to manage the national forests for “multiple uses,” including “outdoor recreation, range, timber, watershed, and wildlife and fish purposes.” 16 U.S.C. § 528. Congress directed the Forest Service to “mak[e] the most judicious use of the land for some or all of these resources,” and acknowledged “that some land will be used for less than all of the resources.” Id. § 531(a). Furthermore, MUSYA states that “establishment and maintenance of areas of wilderness are consistent with the purposes and provisions of [the Act].” Id. § 529. Congress expressly indicated that MUSYA was “to be supplemental to, but not in derogation of,” the Organic Act. Id. § 528. As with the Organic Act, the provisions of MUSYA give the Forest Service broad discretion to regulate NFS lands for a wide variety of purposes. See Perkins v. Bergland, 608 F.2d 803, 806-07 (9th Cir.1979) (The language found in 16 U.S.C. §§ 528, 529, and 531 “can hardly be considered concrete limits upon agency discretion. Rather, it is language which ‘breathe(s) discretion at every pore.’ ” (quoting Strickland v. Morton, 519 F.2d 467, 469 (9th Cir.1975))); see also United States v. New Mexico, 438 U.S. 696, 713, 98 S.Ct. 3012, 57 L.Ed.2d 1052 (1978) (“[W]e conclude that the Multiple-Use Sustained-Yield Act of 1960 was intended to broaden the purposes for which national forests had previously been administered____”). Under MUSYA’s statutory scheme, which supplemented the broad authority granted in the Organic Act, Congress clearly authorized the Forest Service to regulate NFS lands for multiple uses, including those protected by the Roadless Rule, such as “outdoor recreation,” “watershed,” and “wildlife and fish purposes.” 16 U.S.C. § 528. We therefore conclude that the Forest Service had the authority — under the Organic Act and MUSYA— to promulgate a rule protecting NFS lands through restrictions on commercial logging and road construction. C. NEPA Claims Wyoming asserts that the Forest Service, in promulgating the Roadless Rule, violated NEPA in seven ways. Specifically, it argues that the Forest Service failed to comply with the NEPA requirements regarding: (1) scoping, (2) cooperating-agency status, (3) consideration of a reasonable range of alternatives in the EIS, (4) consideration of the cumulative impacts of the proposed action in the EIS, (5) preparation of a supplemental impact statement, (6) inclusion of site-specific analysis in the EIS, and (7) an objective “hard look” at the environmental consequences of agency action, by instead predetermining the outcome of the NEPA process. The district court ruled in favor of Wyoming on all its NEPA claims except for two — the site-specific analysis claim, on which it found in favor of the Forest Service, Wyoming, 570 F.Supp.2d at 1340-41, and the predetermination claim, which it did not specifically rule on. On appeal, we consider all seven of Wyoming’s NEPA claims. 1. Overview of NEPA Congress enacted NEPA in 1969. 42 U.S.C. §§ 4321-70. The statute, which has been described as “[t]he centerpiece of environmental regulation in the United States,” Forest Guardians, 611 F.3d at 711 (quoting New Mexico ex rel. Richardson, 565 F.3d at 703) (internal quotation marks omitted), requires federal agencies to integrate environmental values into the decisionmaking process by considering the environmental impacts of proposed actions and reasonable alternatives to such actions, see, e.g., Barnes v. U.S. Dep’t of Transp., 655 F.3d 1124, 1131 (9th Cir.2011) (“Congress passed NEPA ‘to protect the environment by requiring that federal agencies carefully weigh environmental considerations and consider potential alternatives to the proposed action before the government launches any major federal action.’ ” (quoting Lands Council v. Powell, 395 F.3d 1019, 1026 (9th Cir.2005))). “NEPA established a ‘national policy [to] encourage productive and enjoyable harmony between man and his environment,’ and was intended to reduce or eliminate environmental damage and promote ‘the understanding of the ecological systems and natural resources important to’ the United States.” Ecology Ctr., Inc. v. U.S. Forest Serv., 451 F.3d 1183, 1185 (10th Cir.2006) (alteration in original) (quoting 42 U.S.C. § 4321). NEPA has two aims: “First, it places upon an agency the obligation to consider every significant aspect of the environmental impact of a proposed action. Second, it ensures that the agency will inform the public that it has indeed considered environmental concerns in its decisionmaking process.” Forest Guardians, 611 F.3d at 711 (quoting Balt. Gas & Elec. Co. v. Natural Res. Def. Council, Inc., 462 U.S. 87, 97, 103 S.Ct. 2246, 76 L.Ed.2d 437 (1983)) (internal quotation marks omitted); see also New Mexico ex rel. Richardson, 565 F.3d at 703 (“By focusing both agency and public attention on the environmental effects of proposed actions, NEPA facilitates informed decisionmaking by agencies and allows the political process to check those decisions.”). However, NEPA is strictly a procedural statute; it does not mandate substantive results. E.g., Winter v. Natural Res. Def. Council, Inc., 555 U.S. 7, 129 S.Ct. 365, 376, 172 L.Ed.2d 249 (2008); Utah Envtl. Cong. v. Russell, 518 F.3d at 821. Under NEPA, before a federal agency “undertakes a ‘major Federal aetion[ ] significantly affecting the quality of the human environment,’ it must prepare an environmental impact statement (‘EIS’) that details, among other things, the environmental impacts of the proposed action, any adverse environmental effects that would occur as a result, and alternatives to the proposed action.” Greater Yellowstone Coal. v. Flowers, 359 F.3d 1257, 1274 (10th Cir.2004) (quoting 42 U.S.C. § 4332(2)(C)). Through the NEPA process, “the agency must take a ‘hard look’ at information relevant to its decision.” Forest Guardians, 611 F.3d at 711. We have described the multi-stage process for preparation of an EIS as follows: Initially, an agency announces its intent to study a proposed action through a process called scoping, during which the agency solicits comments and input from the public and other state and federal agencies with the goal of identifying specific issues to be addressed and studied. 40 C.F.R. § 1501.7. After assessing the input from the scoping process, the government then prepares a draft Environmental Impact Statement (DEIS), id. § 1502.9(a), which is then presented to the public and other government agencies for notice and comment. Id. § 1503.1(a). After evaluating the feedback received during the notice and comment process, the agency prepares a FEIS. Id. § 1502.9(b). If after preparing either a DEIS or FEIS, the proposed action substantially changes in a way “relevant to environmental concerns,” or if new information comes to light about environmental impacts, an agency must prepare a supplemental EIS (SEIS). Id. § 1502.9(c)(1). Citizens’ Comm. to Save Our Canyons v. U.S. Forest Serv., 297 F.3d 1012, 1022 (10th Cir.2002). In every EIS prepared under NEPA, agencies must include a “detailed statement” on: (i) the environmental impact of the proposed action, (ii) any adverse environmental effects which cannot be avoided should the proposal be implemented, (iii) alternatives to the proposed action, (iv) the relationship between local short-term uses of man’s environment and the maintenance and enhancement of long-term productivity, and (v) any irreversible and irretrievable commitments of resources which would be involved in the proposed action should it be implemented. 42 U.S.C. § 4332(2)(C). After completing the NEPA process and making a final decision on the proposed action, the agency “then must publish a record of its decision, showing how its final decision-making process incorporated the [EIS’s] findings.” BioDiversity Conservation Alliance v. Bureau of Land Mgmt., 608 F.3d 709, 712 (10th Cir.2010) (citing 23 C.F.R. § 771.127). The requirements of NEPA “have been augmented by longstanding regulations issued by the Council on Environmental Quality (‘CEQ’).” New Mexico ex rel. Richardson, 565 F.3d at 703; see 40 C.F.R. pts. 1500-08. 2. Scoping Wyoming’s first claim under NEPA alleges that the scoping period of the Forest Service was inadequate. Specifically, Wyoming argues that the Forest Service acted arbitrarily and capriciously when it failed to (a) extend the scoping period beyond the initial sixty days allotted, and (b) provide during the scoping period detailed maps of the IRAs affected by the Roadless Rule. The district court held that the Forest Service’s failure to extend the scoping period and provide maps accurately depicting the areas covered by the rule was arbitrary and capricious in that it deprived Wyoming of the opportunity to “meaningfully ‘participate’ in determining the scope and significant issues to be analyzed in the EIS.” Wyoming, 570 F.Supp.2d at 1333-34. On appeal, the Forest Service argues that it fully complied with its scoping obligations under NEPA, that it was not required to extend the scoping period, and that the district court erred in finding that its failure to provide maps prevented Wyoming from meaningfully participating in the scoping process. We hold that the Forest Service fulfilled its scoping obligations under NEPA, and therefore did not act arbitrarily and capriciously. “Scoping” is the initial phase of the overall EIS process under NEPA. Citizens’ Comm, to Save Our Canyons, 297 F.3d at 1022. The scoping process is “an early and open process for determining the scope of issues to be addressed and for identifying the significant issues related to a proposed action.” 40 C.F.R. § 1501.7; see Citizens’ Comm, to Save Our Canyons, 297 F.3d at 1022 (stating that the goal of the scoping process is to “identify! ] specific issues to be addressed and studied” during the EIS process (citing 40 C.F.R. § 1501.7)). To initiate the scoping process, the agency is required to publish a NOI in the Federal Register “[a]s soon as practicable after its decision to prepare an [EIS].” 40 C.F.R. § 1501.7. As part of this process, the lead agency is required to, inter alia, “[i]nvite the participation of affected Federal, State, and local agencies” and “[d]etermine the scope ... and the significant issues to be analyzed in depth in the [EIS].” Id. § 1501.7(a)(1), (2). In addition, the agency “may ... [s]et time limits” for the scoping process and “[h]old an early scoping meeting or meetings.” Id. § 1501.7(b)(2), (4) (emphasis added). In regard to setting time limits for the scoping process, the only requirement is that such limits comply with 40 C.F.R. § 1501.8. Id. § 1501.7(b)(1). Section 1501.8 does not “prescribe! ] universal time limits for the entire NEPA process,” but instead merely authorizes agencies to set time limits — including times limits on the scoping process — that are “appropriate to individual actions” and “are consistent with the purposes of NEPA and other essential considerations of national policy.” Id. § 1501.8. More specifically, the principal regulations governing scoping — i.e., the CEQ Regulations — do not set minimum time limits for the scoping period and do not require an agency to extend or reopen the scoping period; those determinations are generally left to the agency’s discretion. In accordance with 40 C.F.R. § 1501.7, the Forest Service published a NOI commencing the scoping period for the Road-less Rule on October 19, 1999. 64 Fed. Reg. at 56,306. The NOI stated that the “Forest Service is initiating a public rule-making process to propose the protection of remaining roadless areas within the [NFS].” Id. The scoping period for the proposed rulemaking was to close on December 20,1999, sixty days after it opened. Id. The NOI gave an overview of the proposed rulemaking, see id. at 56,307 (stating that the “Forest Service proposes to promulgate a [two-part] rule” that would “restrict certain activities, such as road construction, in unroaded portions of [IRAs]” and “establish national direction for managing inventoried roadless areas, and for determining whether and to what extent similar protections should be extended to uninventoried roadless areas”); listed the possible alternatives that would be considered in the DEIS, see id. (listing the four alternatives, including the “no action” alternative); and gave a tentative timeline for completion of the overall NEPA process, see id. (stating that the “[DEIS] and proposed rule are expected ... in Spring 2000, and a [FEIS] and final rule will follow”). The NOI did not indicate the existence of any maps depicting the geographic scope of the Roadless Rule, but it did indicate that the proposed rule would apply to “unroaded portions of inventoried roadless areas, as previously identified in RARE II and existing forest plan inventories.” Id. Turning to the Forest Service’s refusal to extend the scoping period, we conclude that it was not unreasonable— that is, not arbitrary, capricious, or an abuse of discretion — to limit the period to sixty days and to decline to extend it any further. As stated above, there