Each issue against the decision, unreviewed

• PLAN’s match, not yet checked by a personThe agency's own No Action discussion states that under the recently passed EXPLORE Act, climbing use in the project area 'including the Leigh Creek RNA' must continue as it currently exists because the Act protects continued use and maintenance of routes and fixed anchors that existed when it was signed in January 2025.

  The agency's own No Action discussion states that under the recently passed EXPLORE Act, climbing use in the project area 'including the Leigh Creek RNA' must continue as it currently exists because the Act protects continued use and maintenance of routes and fixed anchors that existed when it was signed in January 2025.

  The Proposed Action then closes all of Leigh Creek RNA to sport climbing and removes all 25 established routes there, without explaining why the EXPLORE Act protection the agency itself invokes does not bar this removal. The Forest Service should directly address the EXPLORE Act conflict and justify, in the decision document itself, why removing pre-existing protected routes and anchors is lawful.

  A hole PLAN found in the agency’s own analysis

  “The EXPLORE Act includes direction that provides for the continued use and maintenance of recreational climbing routes (including fixed anchors along the routes) in existence as of the date the EXPLORE Act was passed. Therefore, climbing use in the project area, including the Leigh Creek RNA, would continue as it currently exists.”

  The agency’s own words, 01 Tensleep Canyon Climbing Management Plan Final EA ↗, Alternative 1: No Action · PLAN’s match, unchecked, an answer in part

• PLAN’s match, not yet checked by a personFor fringed myotis and spotted bats, and separately for Watson's prickly phlox, the agency's own effect determination under the Proposed Action is that the project 'may contribute to a trend towards federal listing or cause a loss of viability.' That is a significance-level finding, yet the EA proceeds toward a FONSI pathway rather than analyzing whether this triggers the need for an EIS.

  For fringed myotis and spotted bats, and separately for Watson's prickly phlox, the agency's own effect determination under the Proposed Action is that the project 'may contribute to a trend towards federal listing or cause a loss of viability.' That is a significance-level finding, yet the EA proceeds toward a FONSI pathway rather than analyzing whether this triggers the need for an EIS.

  The Forest Service should explain why a determination that a species may trend toward federal listing does not require preparation of an environmental impact statement.

  A hole PLAN found in the agency’s own analysis

  “For fringed myotis and spotted bats, the effects determination is 'Will impact individuals or habitat with a consequence that the action may contribute to a trend towards federal listing or cause a loss of viability to the population or species.' However, as part of the route development guidelines outlined in the Proposed Action, route development would be prohibited where it would cause negative impacts to wildlife sensitive species.”

  The agency’s own words, 01 Tensleep Canyon Climbing Management Plan Final EA ↗, Effects on wildlife species · PLAN’s match, unchecked, an answer in part

• PLAN’s match, not yet checked by a personThe wildlife section states climbing currently affects about 22% of cliff habitat, but then separately states that unrestricted route development, the very scenario the Proposed Action's open-ended review process could allow over time, would affect approximately 88% of cliff habitat.

  The wildlife section states climbing currently affects about 22% of cliff habitat, but then separately states that unrestricted route development, the very scenario the Proposed Action's open-ended review process could allow over time, would affect approximately 88% of cliff habitat.

  The EA never analyzes what actual cap, if any, applies to cumulative future route development, leaving a four-fold jump in potential cliff habitat impact unaddressed as the basis for a FONSI. The Forest Service should analyze and disclose the reasonably foreseeable long-term cliff habitat impact of its review process, not just a bookend 'unrestricted' scenario, or explain what actually limits total development.

  A hole PLAN found in the agency’s own analysis

  “Unrestricted route development would affect approximately 88% of cliff habitat in the project area. This is a conservative estimate that assumes a 50-meter buffer from adopted NFS trails and maximum route development of cliffs in Tensleep Canyon.”

  The agency’s own words, 01 Tensleep Canyon Climbing Management Plan Final EA ↗, Effects on wildlife species · PLAN’s match, unchecked, an answer in part

• PLAN’s match, not yet checked by a personThe EA documents that the Medicine Lodge elk herd is 2.9% below objective, the Paint Rock mule deer herd is 16.8% below objective, and the Southwest Bighorns mule deer herd is 58.8% below objective.

  The EA documents that the Medicine Lodge elk herd is 2.9% below objective, the Paint Rock mule deer herd is 16.8% below objective, and the Southwest Bighorns mule deer herd is 58.8% below objective.

  It then admits that expanding affected winter range from 23% to 27% means 'the Proposed Action would not contribute to the forest plan strategy to improve big game habitat value to support population objectives.' The agency proposes an action it acknowledges works against its own forest plan goal for herds already substantially below target. The Forest Service should explain why it is selecting an alternative that its own analysis says will not help, and may hinder, recovery of herds already below objective.

  A hole PLAN found in the agency’s own analysis

  “the Proposed Action would not contribute to the forest plan strategy to improve big game habitat value to support population objectives. However, design features would reduce short-term effects by restricting construction during seasonal wildlife closures (Wildlife 1), and reduce long-term effects by limiting new trails and staging areas in winter range and parturition habitat (Wildlife 1)”

  The agency’s own words, 01 Tensleep Canyon Climbing Management Plan Final EA ↗, Effects on wildlife species · PLAN’s match, unchecked, an answer in part

• PLAN’s match, not yet checked by a personThe cultural resources section concludes the Proposed Action would have no adverse effect to historic properties, yet the same section discloses that consultation on the effects determination is not finished.

  The cultural resources section concludes the Proposed Action would have no adverse effect to historic properties, yet the same section discloses that consultation on the effects determination is not finished.

  Fourteen of 103 documented sites also remain unevaluated for National Register eligibility. The agency is reaching a 'no adverse effect' conclusion before the Section 106 consultation that is supposed to inform that conclusion is complete. The Forest Service should complete tribal and SHPO consultation and evaluate the remaining unevaluated sites before finalizing an effects determination.

  A hole PLAN found in the agency’s own analysis

  “Consultation on the determinations of potential effects from the undertaking on historic properties is pending and will be completed before the Responsible Official issues a decision on this project.”

  The agency’s own words, 01 Tensleep Canyon Climbing Management Plan Final EA ↗, Effects on cultural resources · PLAN’s match, unchecked, an answer in part