Idaho Conservation League v. Guzman
ELR Citation: 41 ELR 20090 No(s). CV 4:10-26-E-REB (D. Idaho Feb 4, 2011)
A district court held that the U.S. Forest Service's travel management plan for the Salmon-Challis National Forest violates NEPA. Environmental groups argued that the travel plan fails to ensure that motor vehicle use is properly sited and managed on the Forest in order to minimize adverse environmental impacts. The Forest Service, meanwhile, argued that the plan drastically reduces the miles of roads and trails open to motorized use and reflects a fair compromise among diverse user groups. The court upheld the Forest Service's determinations concerning the cumulative impact of past motorized use and the range of action alternatives proposed. Nevertheless, the Forest Service's decision adopting the travel plan for the Forest is arbitrary and capricious because the administrative record does not reflect that the Forest Service: (1) considered the possible cumulative impact of routes less than one-half-mile long on the recommended wilderness areas and inventoried roadless areas; (2) chose routes with the objective of minimizing effects; or (3) considered the site-specific concerns environmental groups raised in the comment process. In addition, the record of decision must be amended to clarify that it does not include a minimum road system determination for the forest.