Stop Tensleep Canyon's climbing plan from risking wildlife habitat unchecked
Tensleep Canyon Climbing Management Plan
U.S. Forest Service· Tensleep Canyon, Bighorn National Forest, Powder River Ranger DistrictU.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 predicted likely to care in Wyoming
Predicted likely to care is a guess from footprint in Wyoming, by the same match the STAND matchmaker runs, with no link to this decision. Give straight to them; nothing routes through us.
- Sierra Club
Predicted likely to care · a guess
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
Predicted likely to care · a guess
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
Predicted likely to care · a guess
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
Predicted likely to care · a guess
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's own analysis shows unrestricted future route development could affect up to 88% of cliff habitat, up from 22% today, while big game herds already below population objectives would see winter range impacts rise from 23% to 27%.
What’s at risk
Big game herds already below objective, including a Southwest Bighorns mule deer herd 58.8% below objective, would see winter range impacts increase, something the agency admits would not support the forest plan's goal to improve big game habitat. Fringed myotis bats, spotted bats, and Watson's prickly phlox all carry an effect determination that the project may contribute to a trend toward federal listing. Twenty-five established climbing routes in Leigh Creek Research Natural Area would be removed even though the agency's own EXPLORE Act discussion says climbing use there should continue as it currently exists.
If this goes through
The plan opens the 26,544-acre project area to new route development under a review process whose actual limits are deferred to an implementation appendix, with the agency's own worst-case estimate putting up to 88% of cliff habitat in play over time. It also authorizes a 50-space parking lot and four vault toilets at locations not yet chosen, and finalizes a cultural resources effects determination before Section 106 tribal and SHPO consultation is complete.
Our plain-English read of the official notice ↗. Check it against the agency’s own words below.
By the numbers, from the agency’s own document
- Total project area
- 26,544 acres
- Cliff habitat affected today
- 22% of cliff habitat
- Cliff habitat if development unrestricted
- up to 88% of cliff habitat
- Deer/elk winter range affected, No Action
- up to 23%
- Deer/elk winter range affected, Proposed Action
- up to 27%
- Existing named climbing walls and routes
- 144 walls, about 1,350 routes
Project Location
Open the document ↗“The Tensleep Canyon Climbing Management Plan project area encompasses 26,544 acres located on the Powder River Ranger District”
Effects on wildlife species
Open the document ↗“Climbing currently affects approximately 22% of cliff habitat in the project area”
Effects on wildlife species
Open the document ↗“Unrestricted route development would affect approximately 88% of cliff habitat in the project area”
Effects on wildlife species
Open the document ↗“Existing climbing and camping activities currently affect up to 23% of deer and elk winter range mapped by WGFD”
Effects on wildlife species
Open the document ↗“The Proposed Action would affect up to 27% of WGFD-mapped deer and elk winter range”
Effects on recreation
Open the document ↗“144 named climbing walls each containing between one and 75 individual climbing routes for a total of about 1,350 existing routes”
Each figure is checked word for word against the decision document ↗; open a label to read the sentence it comes from and the document it’s in.
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 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.
- 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.
- 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.
- 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.
Show every point from the document
- 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.
- The purpose and need cites unsafe roadside parking as a driver for building a 50-space, roughly 2-acre parking lot, and the transportation section claims the lot 'would mitigate highway safety issues.' But the agency's own crash data for the same stretch of highway, 34 crashes from 2018 through 2022, found only one crash tied to a pullout maneuver, with the agency stating no clear connection could be made between the other crashes and the lack of designated parking. The Forest Service should justify the scale and necessity of the parking lot with data that actually links crash history to parking conditions, or scale the project to what the safety data supports.
- The Proposed Action opens the entire project area to new route development but defers the actual standards, timing, and limits of that development to Appendix B, describing only that this process 'would allow for the sustainable expansion of climbing opportunities.' The EA does not itself analyze a bounded impact level for this open-ended future development, relying instead on an appendix implementation guide outside the main NEPA effects analysis. The Forest Service should bring the route development review criteria and an analyzed cap on cumulative new development into the EA itself so the public can comment on the actual scope of future impacts.
- Throughout the soil, wildlife, scenic, and safety sections, the EA analyzes effects of a parking lot on up to 2 acres of sagebrush/shrubland and soil, while repeatedly noting the exact site has not been chosen. The agency is drawing conclusions about erosion potential, scenic screening, and wildlife impact for a facility whose location is still undetermined. The Forest Service should identify the parking lot site, or at minimum a defined set of candidate sites, and analyze site-specific effects before relying on this analysis to support a finding of no significant impact.
- The No Action discussion documents that dispersed camping within 100 feet of Tensleep Creek is currently out of compliance with the forest plan's Water Influence Zone standard. Commenters asked for designated dispersed camping sites along Road 18 to fix this, but the responsible official pushed that idea out of this project as a separate future project, while the Proposed Action only prohibits camping on 1.5 of the road's 8 miles and relies on informal expectation that new sites will simply appear more than 100 feet from the creek. The Forest Service should explain how it will actually prevent new streamside camping without the designated-site tool it removed from this decision, or fold designated dispersed camping into this plan.
- The botany section admits that species abundance for Watson's prickly phlox at the forest level is not known, yet the same section assigns this species an effect determination that the project 'may contribute to a trend towards federal listing.' Making a significance-level call about a species whose population size the agency admits it cannot quantify undercuts confidence in the conclusion. The Forest Service should conduct or cite a forest-level abundance survey for Watson's prickly phlox before relying on this effect determination to support the 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?
10 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 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 t
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, quote verified against the document
- PendingFor 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 f
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, quote verified against the document
- PendingThe 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 re
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, quote verified against the document
- PendingThe 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, quote verified against the document
- PendingThe 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 f
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, quote verified against the document
- PendingThe purpose and need cites unsafe roadside parking as a driver for building a 50-space, roughly 2-acre parking lot, and the transportation section claims the lot 'would mitigate highway safety issues.
The purpose and need cites unsafe roadside parking as a driver for building a 50-space, roughly 2-acre parking lot, and the transportation section claims the lot 'would mitigate highway safety issues.' But the agency's own crash data for the same stretch of highway, 34 crashes from 2018 through 2022, found only one crash tied to a pullout maneuver, with the agency stating no clear connection could be made between the other crashes and the lack of designated parking. The Forest Service should justify the scale and necessity of the parking lot with data that actually links crash history to parking conditions, or scale the project to what the safety data supports.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe Proposed Action opens the entire project area to new route development but defers the actual standards, timing, and limits of that development to Appendix B, describing only that this process 'wou
The Proposed Action opens the entire project area to new route development but defers the actual standards, timing, and limits of that development to Appendix B, describing only that this process 'would allow for the sustainable expansion of climbing opportunities.' The EA does not itself analyze a bounded impact level for this open-ended future development, relying instead on an appendix implementation guide outside the main NEPA effects analysis. The Forest Service should bring the route development review criteria and an analyzed cap on cumulative new development into the EA itself so the public can comment on the actual scope of future impacts.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThroughout the soil, wildlife, scenic, and safety sections, the EA analyzes effects of a parking lot on up to 2 acres of sagebrush/shrubland and soil, while repeatedly noting the exact site has not be
Throughout the soil, wildlife, scenic, and safety sections, the EA analyzes effects of a parking lot on up to 2 acres of sagebrush/shrubland and soil, while repeatedly noting the exact site has not been chosen. The agency is drawing conclusions about erosion potential, scenic screening, and wildlife impact for a facility whose location is still undetermined. The Forest Service should identify the parking lot site, or at minimum a defined set of candidate sites, and analyze site-specific effects before relying on this analysis to support a finding of no significant impact.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe No Action discussion documents that dispersed camping within 100 feet of Tensleep Creek is currently out of compliance with the forest plan's Water Influence Zone standard.
The No Action discussion documents that dispersed camping within 100 feet of Tensleep Creek is currently out of compliance with the forest plan's Water Influence Zone standard. Commenters asked for designated dispersed camping sites along Road 18 to fix this, but the responsible official pushed that idea out of this project as a separate future project, while the Proposed Action only prohibits camping on 1.5 of the road's 8 miles and relies on informal expectation that new sites will simply appear more than 100 feet from the creek. The Forest Service should explain how it will actually prevent new streamside camping without the designated-site tool it removed from this decision, or fold designated dispersed camping into this plan.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe botany section admits that species abundance for Watson's prickly phlox at the forest level is not known, yet the same section assigns this species an effect determination that the project 'may co
The botany section admits that species abundance for Watson's prickly phlox at the forest level is not known, yet the same section assigns this species an effect determination that the project 'may contribute to a trend towards federal listing.' Making a significance-level call about a species whose population size the agency admits it cannot quantify undercuts confidence in the conclusion. The Forest Service should conduct or cite a forest-level abundance survey for Watson's prickly phlox before relying on this effect determination to support the decision.
A hole PLAN found in the agency’s own analysis, quote verified against the document
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