Failed to execute its duties under the ESA by not initiating consultation with the Fish and Wildlife Service on gray wolves. Claim added in Amended Complaint filed on 10/9/2017 and 10/23/2017. Decision is inconsistent with the Forest Plan (i.e., inconsistent with standards and guidelines for Rocky Mountain elk and mule deer habitat - disturbance during caving season; failed to comply with road density standards/guidelines; failure to minimize stream crossings; failed to comply with ROS (motorized trails in semi-primitive non-motorized areas); failed to comply with old growth and scabland area requirements (i.e., new road construction should be avoided). Failure to take a “hard look” at impacts (i.e., failure to provide accurate baseline data on road, sediment, elk and elk habitat, impacts to gray wolves, wolf habitat or wolf prey; failure to consider cumulative impacts - impacts from grazing on streams, sediment, vegetation; Blue Mountains Resiliency Project, unauthorized OHV use). Failed to demonstrate implementation of and compliance with “minimization criteria” (i.e., damage to soil, watersheds, vegetation, harassment of wildlife and destruction of habitat, minimize conflicts of forest users).
Failed to execute its duties under the ESA by not initiating consultation with the Fish and Wildlife Service on gray wolves. 1) Failed to adequately demonstrate consistency with its Forest Plan regarding Standards and Guidelines associated with elk calving habitat and elk wallows; 2) Improperly amended INFISH “riparian management objectives” by relying on non-site-specific data; 3) Failed to demonstrate consistency with its own road density requirements; 4) Failed to comply with INFISH requirements in modifying Resource Management Objectives. 5) Failed to take a “hard look” at the Project’s effects on gray wolves. and elk security habitat vis-a-vis open and closed user-created roads. 6) Failure to disclose and analyze direct, indirect, and cumulative effects of elk-caving and rutting sites. 7) Cumulative impacts analysis was insufficient, and arbitrary and capricious, as to the road density and user-created and closed roads analysis. 8) Failed to comply with the Travel Management Rule’s minimization criteria.