Tensleep Canyon climbing plan would restrict where routes can go
Tensleep Canyon Climbing Management Plan
U.S. Forest Service· Tensleep Canyon, Bighorn National ForestU.S. Forest Service project page ↗
Forest ServiceWe track this on the agency’s own system of record, where most on-the-ground decisions live.
The groups on this fight
4 groups work Wyoming
By footprint, from the same match the STAND matchmaker runs; none is linked to this decision in our record yet. Give straight to them; nothing routes through us.
- Sierra Club
Works Wyoming: its Wyoming Chapter mobilized public comments ahead of the December 18, 2025 deadline against the administration's rollback of Red Desert ACEC protections in the Rock Springs RMP amendment..
- Western Watersheds Project
Works Wyoming: co-plaintiff in the federal appeal challenging BLM's plan to cut the Adobe Town herd management area roughly in half as part of the largest wild horse removal ever attempted in the Wyoming checkerboard..
- Wyoming Outdoor Council
Works Wyoming: leading opposition to BLM's 2025 reopening of the just-finalized Rock Springs RMP, with program director Alec Underwood arguing the Golden Triangle and Big Sandy Foothills are too special to lease and develop..
- Wyoming Wilderness Association
Works Wyoming: organized citizen outings at Skull Rim to build opposition to BLM lease parcels around Adobe Town Rim and has pressed the agency to shrink lease sales touching the WSA and surrounding lands with wilderness characteristics..
Every group above is on STAND for Public Lands, with its court record, its filings and who backs it.
The Forest Service would decide which canyon walls climbers can and cannot develop new routes on.
What’s at risk
Access to future climbing routes in Tensleep Canyon is at stake. The plan would draw permanent boundaries limiting where new routes may be established, locking in those restrictions going forward.
If this goes through
Once adopted, the Climbing Management Plan would permanently define off-limits zones for new route development and formalize trail and parking infrastructure in Tensleep Canyon.
Our plain-English read of the official notice ↗. Check it against the agency’s own words below.
The agency’s case, tested
What the agency argues, and whether its own record backs it
- 2
- Hold up
- 6
- No support given
- 4
- Never analyzed
The Forest Service wants to adopt a climbing management plan for Tensleep Canyon that adds trails, toilets and a parking lot, ends camping along part of Road 18, closes Leigh Creek Research Natural Area to climbing, and allows new routes only after review. It says rising use is damaging soil, water, wildlife, plants and cultural resources and that the forest plan calls for such a plan.
“The Bighorn National Forest needs a climbing management plan to effectively manage rock climbing and associated recreational activities to support the continued opportunities for rock climbing, minimize user conflict, and protect the area’s resources in a manner that is consistent with the forest plan.”
Purpose and Need for the Proposal
Each Ask below goes into your letter when you write it with PLAN on this page, matched to what you tell it about how this land reaches you.
Effects
No support given
The review process for new routes will keep route development from harming sensitive wildlife and plant species.
The Proposed Action allows route development only where it wouldn't harm sensitive wildlife and plant species. Design features require site-specific surveys (Wildlife 2, Botany 2), limit development where raptor nests or bat roosts are found, and restrict work during seasonal closures. The document says its analyses assume all actions are implemented to estimate maximum effects, and the 88% figure is called a conservative estimate assuming maximum route development. So the listing-trend determinations for fringed myotis, spotted bats and Watson's prickly phlox are worst-case figures, not proof the review will fail. Still, the document doesn't explain how the review would judge harm, leaves the process to Appendix B, which isn't in this text, and never revises those determinations to credit the review.
AskReconcile the trend-toward-listing determinations with the route safeguards, and state how much cliff habitat route development could actually open once surveys and restrictions are applied.
The agency’s words, the record +Hide the words
The agency says
“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.”
Effects on wildlife species
Elsewhere in the same document
“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.””
Effects on wildlife species
Effects
No support given
Inviting tribes to do traditional cultural surveys before implementation will ensure the plan doesn't cause irreversible harm to sacred rock and traditional use areas.
The plan invites tribes to do traditional cultural surveys before implementation (Cultural 2), limits new routes to reviewed areas, bans rock removal except for safety, and bans gluing, artificial holds and mechanically made holds. The survey promise covers traditional cultural use areas, not every rock. The document reports that several tribes see all canyon rock as sacred and bolting as irreversible harm, and it says the plan only attempts to strike a balance. It doesn't explain what happens if tribes decline to survey or how survey results would stop a route, so the word ensure isn't backed up.
AskExplain how new bolting avoids irreversible harm when tribes consider every cliff sacred, and describe what tribes can do if surveys find a proposed route area unacceptable.
The agency’s words, the record and the law +Hide the words
The agency says
“To prevent negative impacts to traditional cultural use areas under the Proposed Action, the Forest Service will invite tribes to conduct traditional cultural surveys prior to implementation to ensure that management actions do not cause irreversible negative impacts (Cultural 2).”
Effects on tribes and tribal resources
Elsewhere in the same document
“Several tribes have expressed that they consider all rocks and cliffs within Tensleep Canyon as sacred and of great importance.”
Effects on tribes and tribal resources
“According to several tribes, actions involved with route development, such as installing bolts into the rock and accidental chipping or removal of rock, irreversibly damage rocks that are considered sacred.”
Effects on tribes and tribal resources
The law
“shall take into account the effect of the undertaking on any historic property.” National Historic Preservation Act, 54 U.S.C. 306108 ↗
Effects
No support given
A 50-space parking lot and signs will improve highway safety by reducing parking shortages and sudden moves in and out of traffic.
The agency's support is anecdotal reports of sudden stops at pullouts. The Wyoming Department of Transportation crash data for 2018 through 2022 showed 34 crashes, only one tied to a pull-off, and the document found no clear link to parking. It gives no count of how many cars now park at pullouts or whether 50 spaces meets demand.
AskProvide counts of vehicles using highway pullouts at peak times, show whether 50 spaces meets that demand, and say whether pullouts would be closed once the lot opens.
The agency’s words, the record +Hide the words
The agency says
“These improvements would mitigate highway safety issues, as the shortage of parking spaces and sudden movements in and out of traffic would decrease.”
Effects on transportation and safety
Elsewhere in the same document
“No clear connection could be made between the crashes reported and the lack of designated parking areas.”
Effects on transportation and safety
“Anecdotal accounts suggest the lack of developed parking areas within Tensleep Canyon has negatively affected highway safety along U.S. Highway 16.”
Effects on transportation and safety
Show 3 more claims +Show fewer
Effects
No support given
With its management recommendations, the plan will have no adverse effects on historic properties.
Archaeologists did a Class III intensive inventory of about 200 acres covering trails, possible toilet locations, parking and staging areas, and cliff faces for existing and future routes. They found no sites near proposed toilets and set conditions for eligible sites crossed by trails. The document says future development, including parking, will occur only inside the surveyed area, and areas with cultural resources will be left out. But the parking lot site isn't chosen, 14 sites across the analysis area remain unevaluated, and consultation on the determination is still pending, so the finding isn't final.
AskComplete consultation and survey the parking lot site before deciding, evaluate the 14 unevaluated sites, and make any finding for future actions conditional on those surveys.
The agency’s words, the record and the law +Hide the words
The agency says
“Following the management recommendations addressed for the proposed action, there are no adverse effects to historic properties.”
Cultural Resource Determination
Elsewhere in the same document
“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.”
Cultural Resource Determination
“The exact location of the parking lot is currently unknown, but it would be sited, designed, and permitted in coordination with the WYDOT, as described in Appendix B: Implementation Guide.”
Effects on transportation and safety
The law
“shall take into account the effect of the undertaking on any historic property.” National Historic Preservation Act, 54 U.S.C. 306108 ↗
Effects
No support given
Closing 1.5 miles of Road 18 to camping and removing creekside sites won't have long-term negative effects on camping because new sites will be made.
The document says 26 sites remain along the 6.5 open miles of Road 18, only four of them would be removed, and new sites are allowed anywhere within 300 feet of the road if they're not within 100 feet of Tensleep Creek. But it doesn't show there's usable ground along those miles to replace the sites lost on the closed 1.5 miles plus the four creekside sites. Resource effects from new campsites are a separate question from camping opportunity.
AskAnalyze where displaced campers are likely to create new sites along Road 18 and the effects on soils, soft aster and invasive weeds.
The agency’s words, the record +Hide the words
The agency says
“However, new sites would likely be established, which is allowed anywhere within 300 feet along Road 18, as long as the site is not within 100 feet of Tensleep Creek.”
Effects to recreation
Elsewhere in the same document
“Four dispersed campsites along Road 18 are within soft aster known population locations.”
Effects on botanical species
Effects
No support given
Vault toilets are far enough from perennial streams that they're unlikely to send substantial sediment into them.
Design feature Hydro 3 places toilets upslope of existing roads to use road drainage. But the document never states the distances to streams, and it gives two different disturbance sizes: less than 0.1 acre per site in the soils section and less than 1.0 acre per site in the cultural section.
AskState the distance from each proposed toilet site to the nearest stream and correct which disturbance figure, less than 0.1 acre or less than 1.0 acre, applies.
The agency’s words, the record +Hide the words
The agency says
“Given the distance of the proposed toilet locations from the mainstem of perennial streams, it is unlikely that the proposed toilets would contribute to substantial sediment delivery to these water systems.”
Effects on soil and water resources
Elsewhere in the same document
“Ground disturbance for the vault toilet locations are limited to less than 1.0 acre at each location.”
Vault Toilets
What the document never analyzes
Not analyzed
Cumulative effects with other activities
The document names grazing allotments, BLM climbing areas and the Salt Lick Trail next door, highway traffic and hunting in the same area, but never adds their effects to the plan's.
Searched all 33 pages for ‘cumulative’, ‘reasonably foreseeable’. None appear.
AskAnalyze the plan's effects together with grazing, BLM recreation, hunting and highway use in and around the canyon.
Not analyzed
Local recreation and tourism economy
The document says tourism has increased substantially, lists private campgrounds nearby and notes comments from the Washakie County Visitor's Council, yet it never analyzes effects on local businesses.
Searched all 33 pages for ‘economy’, ‘economic’, ‘revenue’, ‘businesses’. None appear.
AskDescribe how the plan, including the Leigh Creek closure and camping limits, could affect visitation and businesses in Ten Sleep and nearby communities.
Not analyzed
Fish and aquatic life in Tensleep Creek
The document says campsites sit within 100 feet of Tensleep Creek and that disturbed areas carry sediment to streams, but it never analyzes fish or other aquatic life.
Searched all 33 pages for ‘trout’, ‘fisheries’, ‘aquatic species’, ‘macroinvertebrates’. None appear.
AskAnalyze how sediment from trail and parking construction and changes to creekside camping would affect fish and aquatic life in Tensleep Creek and Leigh Creek.
Not analyzed
Wildfire risk from recreation
The document describes heavy dispersed camping along Road 18 and illegal fire pits, plus forested habitat covering 61% of the project area, but never discusses fire risk.
Searched all 33 pages for ‘wildfire’, ‘fire risk’, ‘fuels’. None appear.
AskAssess whether shifting and concentrating camping and visitors changes wildfire risk in the canyon.
Where its own record backs the agency
EffectsLosing the 25 routes in Leigh Creek Research Natural Area will be made up by new route development elsewhere.Why it holds +
The loss is 25 routes, about 2% of the roughly 1,350 in the project area. Only about 74 of the approximately 835 acres of cliff habitat have climbing routes, and the rest of the project area opens to reviewed route development. Some areas will be excluded for cultural and natural resources, and no count is given, but replacing 25 routes across that much undeveloped cliff is a reasonable conclusion from the document's own figures.
The agency says
“However, allowing for additional route development elsewhere in the project area would make up for this loss.”
Effects to recreation
Its own record backs it
“Areas that have cultural resources present will be omitted from designated locations where future climbing development can occur.”
Future Route Development - Review Process
ScienceSurveys found rock climbing was the only activity harming the values of Leigh Creek Research Natural Area, justifying its closure to climbing.Why it holds +
The document describes 2021 and 2023 botanical surveys finding Watson's prickly phlox next to bare climbing routes, frequent climbing use with spiderwebbed trails in the first quarter mile, and little other use: no horseback evidence, hiking limited to two climbing access trails, no ski use seen. That supports the finding.
The agency says
“Rock climbing was the only activity found to impact the RNA values and viability.”
Effects to Leigh Creek Research Natural Area
Its own record backs it
“Botanical surveys conducted in 2021 and 2023 noted Linanthus watsonii populations directly next to climbing routes on cliff walls, but noted climbing routes were completely devoid of vegetation.”
Effects to Leigh Creek Research Natural Area
“Climbing use was evident and frequent in the first ¼ mile of the western edge of the RNA, with many spiderwebbed access trails leading to the base of climbing routes and bouldering areas.”
Effects to Leigh Creek Research Natural Area
Read from the agency’s own decision document ↗, all 33 pages. Every quote is checked word for word against it, a claim marked contradicted stands on a quote from the same document, and a second reading argued the agency’s side of every verdict before it was published. The verdicts are our reading; the quotes are the agency’s. A court can set aside agency action it finds “arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law” (5 U.S.C. 706(2)(A) ↗), which is why these gaps are worth putting in the record.
What to say
Make these points, in your own words
- I oppose this action as proposed, and I ask the agency to weigh the specific harms below.
- The EA acknowledges that two sensitive bat species -- fringed myotis and spotted bats -- will be pushed toward federal listing under the Proposed Action, yet the agency still issues a FONSI rather than preparing an EIS. The effects determination in the wildlife section explicitly states the action 'may contribute to a trend towards federal listing or cause a loss of viability to the population or species' for these species, which is precisely the kind of significant effect that triggers an EIS under NEPA. The agency's only response is to say route development will be blocked where impacts are found, but that future gatekeeping mechanism is unenforceable without a permit system, which the agency elsewhere says it lacks authority to create. The agency should prepare an EIS or, at minimum, provide a detailed reasoned explanation for why this effects determination is consistent with a FONSI.
- The EA states that Section 106 consultation on determinations of potential effects 'is pending and will be completed before the Responsible Official issues a decision on this project,' but the document is already the final EA presented for a decision. This means the agency is preparing to issue a Decision Notice before legally required NHPA Section 106 consultation is complete. Issuing a decision while consultation remains open violates the procedural requirements of Section 106, which requires the agency to take into account the effects of its undertaking on historic properties before approving the action. The agency should complete Section 106 consultation and document the outcome in a supplemental analysis before issuing any decision.
- The EA allows future route development across the project area but defers all site-specific survey, review, and approval to Appendix B: Implementation Guide, a post-decision document. For Watson's prickly phlox, the botany section already determines the Proposed Action 'may contribute to a trend towards federal listing or cause a loss of viability,' yet the only mitigation offered is that route development 'would be prohibited where it would cause negative impacts to botany sensitive species' -- a determination to be made later. NEPA requires that the agency analyze the significance of effects before making a decision, not after. The agency should either complete site-specific botanical surveys for all areas open to route development prior to the decision, or prepare an EIS that analyzes the full range of potential impacts.
- The EA documents that the Southwest Bighorns mule deer herd is 58.8 percent below its objective herd size, and the Paint Rock herd is 16.8 percent below objective, yet the Proposed Action increases the proportion of WGFD-mapped deer and elk winter range affected from 22 percent under No Action to 27 percent. The EA acknowledges that the project 'would not contribute to the forest plan strategy to improve big game habitat value to support population objectives.' This is an internal admission that the Proposed Action conflicts with an express forest plan strategy, but the agency provides no analysis of whether this conflict requires a forest plan amendment or an EIS. The agency should provide a direct consistency finding under 36 CFR 219 or explain why the forest plan strategy is not binding, and analyze cumulative effects on these herds at the herd-unit scale.
Show all 12 points from the document
- The EA proposes to allow development of new climbing routes throughout the project area once a Forest Service review process is satisfied, but the EA's own analysis states that unrestricted route development would affect approximately 88 percent of cliff habitat in the project area. The agency treats design features and a post-decision review process as sufficient mitigation, but provides no analysis of what percentage of cliff habitat would realistically be opened under the review process, no cap on total new routes, and no cumulative effects analysis combining existing routes with potential new ones. The agency should analyze a range of route-development scenarios with specific acreage and disturbance estimates, or prepare an EIS to bound the cumulative impacts.
- The EA states that several tribes expressed that 'there are already too many climbing routes in Tensleep Canyon, and therefore any allowance of existing climbing or future route development goes against their wishes.' The tribal consultation section also notes that tribal representatives raised the idea of a permit system and that some tribes consider all rocks and cliffs in the canyon sacred. Despite these concerns, the agency selected the Proposed Action, which allows existing climbing to continue and opens the door to hundreds of additional routes. The EA provides no reasoned explanation for how it weighed tribal objections against recreational interests, other than saying the plan 'attempts to strike a balance.' This conclusory statement does not satisfy the government-to-government consultation obligation or NEPA's requirement to analyze the full range of effects on tribal…
- The EA eliminates a designated dispersed camping alternative from detailed study on the grounds that it is 'outside the scope' of the project, but the purpose and need explicitly identifies reducing erosion and protecting riparian resources as core needs, and the document acknowledges that dispersed camping within 100 feet of Tensleep Creek is currently out of compliance with forest plan Standard Soil, Water, Riparian, and Wetland 1. Eliminating a management tool directly responsive to stated project needs without substantive analysis is an unreasoned scope limitation. NEPA requires consideration of a reasonable range of alternatives that meet the stated purpose and need. The agency should either analyze designated dispersed camping as an alternative or provide a substantive explanation for why it cannot be part of the same decision.
- The EA's transportation and safety section acknowledges that crash data for the five-year period 2018 through 2022 shows 34 crashes on the affected highway stretch, but states 'no clear connection could be made between the crashes reported and the lack of designated parking areas.' The agency simultaneously describes anecdotal accounts of sudden stops and vehicles pulling back into traffic, and proposes a 50-space parking lot as a safety improvement. The EA cannot justify a major capital facility on a safety rationale while simultaneously conceding the safety data does not support that rationale. The agency should either commission a formal traffic safety study to establish whether a causal link exists, or reframe the parking lot justification around documented resource and recreation needs rather than unsubstantiated safety claims.
- The EA proposes to add up to 16 miles of trails to the NFS trail network and states these Class 1 trails would require maintenance every 9 years, but provides no analysis of the long-term funding or staffing capacity needed to maintain this network. The document notes the project was put on hold in 2021 due to staff turnover and that a climbing ranger was only hired in 2022, suggesting the district is already resource-constrained. Adding a 2.5 percent increase to the Bighorn National Forest trail system without any maintenance funding analysis raises a direct question about whether the agency can meet its own maintenance standard. The agency should provide an analysis of projected maintenance costs and funding sources, or explain how it will meet the 9-year maintenance cycle before approving the trail additions.
- The EA states that the parking lot location 'will be determined after survey and design' and that the exact location is currently unknown, yet the document purports to analyze the environmental effects of parking lot construction, including impacts to soils, wildlife habitat, scenic quality, and cultural resources. The analysis assumes the lot will be sited in an area with 'low soil erosion potential,' will be screened from the scenic byway, and will avoid cultural resources -- all site-specific determinations that cannot be made without a known location. Analyzing a facility of approximately 2 acres without a defined location does not constitute a hard look under NEPA. The agency should identify and survey the parking lot location, complete site-specific environmental and cultural resource analyses, and make those findings available for public comment before issuing a decision.
- Say something only you can say. The law requires the agency to consider and respond to substantive comments, and specifics are what make a comment substantive.
In the agency’s own words
The Powder River Ranger District proposes to develop a Climbing Management Plan for Tensleep Canyon. The Climbing Management Plan will outline where future route development may or may not occur and identify new system trails and parking areas.
Did the agency answer?
12 issues are on this record. The agency has not published its decision document yet, so each one stays pending until the agency answers.
Issues on the record, awaiting the decision
- PendingThe document states Leigh Creek Campground is the only developed campground in the project area, with 10 campsites and a vault toilet, open Memorial Day through Labor Day.
The document states Leigh Creek Campground is the only developed campground in the project area, with 10 campsites and a vault toilet, open Memorial Day through Labor Day.
- PendingThe document asserts that surveys found several dispersed campsites along Road 18 currently sit within 100 feet of Tensleep Creek.
The document asserts that surveys found several dispersed campsites along Road 18 currently sit within 100 feet of Tensleep Creek.
- PendingThe EA allows future route development across the project area but defers all site-specific survey, review, and approval to Appendix B: Implementation Guide, a post-decision document.
The EA allows future route development across the project area but defers all site-specific survey, review, and approval to Appendix B: Implementation Guide, a post-decision document. For Watson's prickly phlox, the botany section already determines the Proposed Action 'may contribute to a trend towards federal listing or cause a loss of viability,' yet the only mitigation offered is that route development 'would be prohibited where it would cause negative impacts to botany sensitive species' -- a determination to be made later. NEPA requires that the agency analyze the significance of effects before making a decision, not after. The agency should either complete site-specific botanical surveys for all areas open to route development prior to the decision, or prepare an EIS that analyzes the full range of potential impacts.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA documents that the Southwest Bighorns mule deer herd is 58.8 percent below its objective herd size, and the Paint Rock herd is 16.8 percent below objective, yet the Proposed Action increases th
The EA documents that the Southwest Bighorns mule deer herd is 58.8 percent below its objective herd size, and the Paint Rock herd is 16.8 percent below objective, yet the Proposed Action increases the proportion of WGFD-mapped deer and elk winter range affected from 22 percent under No Action to 27 percent. The EA acknowledges that the project 'would not contribute to the forest plan strategy to improve big game habitat value to support population objectives.' This is an internal admission that the Proposed Action conflicts with an express forest plan strategy, but the agency provides no analysis of whether this conflict requires a forest plan amendment or an EIS. The agency should provide a direct consistency finding under 36 CFR 219 or explain why the forest plan strategy is not binding, and analyze cumulative effects on these herds at the herd-unit scale.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA proposes to allow development of new climbing routes throughout the project area once a Forest Service review process is satisfied, but the EA's own analysis states that unrestricted route deve
The EA proposes to allow development of new climbing routes throughout the project area once a Forest Service review process is satisfied, but the EA's own analysis states that unrestricted route development would affect approximately 88 percent of cliff habitat in the project area. The agency treats design features and a post-decision review process as sufficient mitigation, but provides no analysis of what percentage of cliff habitat would realistically be opened under the review process, no cap on total new routes, and no cumulative effects analysis combining existing routes with potential new ones. The agency should analyze a range of route-development scenarios with specific acreage and disturbance estimates, or prepare an EIS to bound the cumulative impacts.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA states that several tribes expressed that 'there are already too many climbing routes in Tensleep Canyon, and therefore any allowance of existing climbing or future route development goes again
The EA states that several tribes expressed that 'there are already too many climbing routes in Tensleep Canyon, and therefore any allowance of existing climbing or future route development goes against their wishes.' The tribal consultation section also notes that tribal representatives raised the idea of a permit system and that some tribes consider all rocks and cliffs in the canyon sacred. Despite these concerns, the agency selected the Proposed Action, which allows existing climbing to continue and opens the door to hundreds of additional routes. The EA provides no reasoned explanation for how it weighed tribal objections against recreational interests, other than saying the plan 'attempts to strike a balance.' This conclusory statement does not satisfy the government-to-government consultation obligation or NEPA's requirement to analyze the full range of effects on tribal resources. The agency should document the specific tribal concerns raised, explain the reasoning for rejecting tribal-preferred alternatives such as a permit system or route cap, and analyze a reduced-development alternative.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA acknowledges that two sensitive bat species -- fringed myotis and spotted bats -- will be pushed toward federal listing under the Proposed Action, yet the agency still issues a FONSI rather tha
The EA acknowledges that two sensitive bat species -- fringed myotis and spotted bats -- will be pushed toward federal listing under the Proposed Action, yet the agency still issues a FONSI rather than preparing an EIS. The effects determination in the wildlife section explicitly states the action 'may contribute to a trend towards federal listing or cause a loss of viability to the population or species' for these species, which is precisely the kind of significant effect that triggers an EIS under NEPA. The agency's only response is to say route development will be blocked where impacts are found, but that future gatekeeping mechanism is unenforceable without a permit system, which the agency elsewhere says it lacks authority to create. The agency should prepare an EIS or, at minimum, provide a detailed reasoned explanation for why this effects determination is consistent with a FONSI.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA's transportation and safety section acknowledges that crash data for the five-year period 2018 through 2022 shows 34 crashes on the affected highway stretch, but states 'no clear connection cou
The EA's transportation and safety section acknowledges that crash data for the five-year period 2018 through 2022 shows 34 crashes on the affected highway stretch, but states 'no clear connection could be made between the crashes reported and the lack of designated parking areas.' The agency simultaneously describes anecdotal accounts of sudden stops and vehicles pulling back into traffic, and proposes a 50-space parking lot as a safety improvement. The EA cannot justify a major capital facility on a safety rationale while simultaneously conceding the safety data does not support that rationale. The agency should either commission a formal traffic safety study to establish whether a causal link exists, or reframe the parking lot justification around documented resource and recreation needs rather than unsubstantiated safety claims.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA proposes to add up to 16 miles of trails to the NFS trail network and states these Class 1 trails would require maintenance every 9 years, but provides no analysis of the long-term funding or s
The EA proposes to add up to 16 miles of trails to the NFS trail network and states these Class 1 trails would require maintenance every 9 years, but provides no analysis of the long-term funding or staffing capacity needed to maintain this network. The document notes the project was put on hold in 2021 due to staff turnover and that a climbing ranger was only hired in 2022, suggesting the district is already resource-constrained. Adding a 2.5 percent increase to the Bighorn National Forest trail system without any maintenance funding analysis raises a direct question about whether the agency can meet its own maintenance standard. The agency should provide an analysis of projected maintenance costs and funding sources, or explain how it will meet the 9-year maintenance cycle before approving the trail additions.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA states that the parking lot location 'will be determined after survey and design' and that the exact location is currently unknown, yet the document purports to analyze the environmental effect
The EA states that the parking lot location 'will be determined after survey and design' and that the exact location is currently unknown, yet the document purports to analyze the environmental effects of parking lot construction, including impacts to soils, wildlife habitat, scenic quality, and cultural resources. The analysis assumes the lot will be sited in an area with 'low soil erosion potential,' will be screened from the scenic byway, and will avoid cultural resources -- all site-specific determinations that cannot be made without a known location. Analyzing a facility of approximately 2 acres without a defined location does not constitute a hard look under NEPA. The agency should identify and survey the parking lot location, complete site-specific environmental and cultural resource analyses, and make those findings available for public comment before issuing a decision.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA eliminates a designated dispersed camping alternative from detailed study on the grounds that it is 'outside the scope' of the project, but the purpose and need explicitly identifies reducing e
The EA eliminates a designated dispersed camping alternative from detailed study on the grounds that it is 'outside the scope' of the project, but the purpose and need explicitly identifies reducing erosion and protecting riparian resources as core needs, and the document acknowledges that dispersed camping within 100 feet of Tensleep Creek is currently out of compliance with forest plan Standard Soil, Water, Riparian, and Wetland 1. Eliminating a management tool directly responsive to stated project needs without substantive analysis is an unreasoned scope limitation. NEPA requires consideration of a reasonable range of alternatives that meet the stated purpose and need. The agency should either analyze designated dispersed camping as an alternative or provide a substantive explanation for why it cannot be part of the same decision.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA states that Section 106 consultation on determinations of potential effects 'is pending and will be completed before the Responsible Official issues a decision on this project,' but the documen
The EA states that Section 106 consultation on determinations of potential effects 'is pending and will be completed before the Responsible Official issues a decision on this project,' but the document is already the final EA presented for a decision. This means the agency is preparing to issue a Decision Notice before legally required NHPA Section 106 consultation is complete. Issuing a decision while consultation remains open violates the procedural requirements of Section 106, which requires the agency to take into account the effects of its undertaking on historic properties before approving the action. The agency should complete Section 106 consultation and document the outcome in a supplemental analysis before issuing any decision.
A hole PLAN found in the agency’s own analysis, quote verified against the document
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