Here is page 5
Wish I could figure out how to get the 29 pages in a link
new WATV routes. Sierra Club brings this action on its own behalf and on behalf of its adversely
affected members. The relief requested in this lawsuit can redress Sierra Club’s and its members’
injuries.
9. This suit is brought by ALPS, Kittitas Audubon and Sierra Club on their own behalf as
well as their adversely affected members and staff. Plaintiffs and their members’ present and future
intended use of OWNF and the waters therein is and will be directly and adversely affected by the
decisions, actions, and failures to act alleged in this Complaint. Those adverse effects include, but are
not limited to: (1) disruption of their recreation experiences; (2) reduction and impairment of recreation
opportunities; (3) impacts to native plants and wildlife and their habitats within OWNF; (4) impacts to
riparian areas, wet meadows, and water quality; and (5) impaired aesthetic value of trails and other areas
caused by USFS’ mismanagement of motorized travel on OWNF lands. The ongoing injuries caused by
Defendants’ failure to follow mandatory procedures in designating and reviewing motorized travel
include, but are not limited to, increased water, noise and air pollution on OWNF lands and surrounding
environs, degradation and impairment of the Forest landscape, disruption of wildlife, destruction of
native plants, destruction of soil structure and quality, increased user conflicts, and loss of opportunities
for solitude and nature appreciation. In addition, Plaintiffs and their members have an interest in
ensuring that the Forest Service complies with all applicable laws, regulations, and procedures
pertaining to the management of public lands.
10. Plaintiffs and their members use OWNF lands and the waters therein that will be
managed under the challenged decision for recreational, scientific, educational, aesthetic, and
commercial purposes and intend to continue to do so in the future. Plaintiffs and their members derive
recreational, scientific, educational, aesthetic, and commercial benefits from the OWNF lands through
fish and wildlife observation, hiking, study, photography, recreational boating and rafting,
and recreational fishing.
11. The decision at issue herein approves motorized use and activities that will significantly
degrade the natural values currently enjoyed by Plaintiffs and their members
