/11 Case 2:09-cv-01750-LKK-JFM Document 34 Filed 01/08/10 Page 21 of 43 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 /Specifically, Plaintiffs seek to compel implementation of the following broad directives:12 • Claim III: Plaintiffs seek to enforce the discretionary authority of the Secretary under: (1) 16 U.S.C. § 1608(a) (“The Congress declares that the installation of a proper system of transportation to service the National Forest System, as is provided for in sections 532 to 538 of this title, shall be carried forward in time to meet anticipated needs on an economical and environmentally sound basis, and the method chosen for financing the construction and maintenance of the transportation system should be such as to enhance local, regional, and national benefits.”); and (2) 16 U.S.C. § 535 (giving the Secretary discretion to “provide for the acquisition, construction, and maintenance of forest development roads within and near the national forests and other lands administered by the Forest Service in locations and according to specifications which will permit maximum economy in harvesting timber from such lands tributary to such roads and at the same time meet the requirements for protection, development, and management thereof, and for utilization of the other resources thereof.”).