Council for Bighorn Range
P.O. Box 2001
Sheridan WY 82801
(307) 210-7745 office
Re: Tensleep Canyon Climbing Management Plan Project 64475 – November 2023
Bighorn National Forest, WY
Powder River Ranger District
November 22, 2023
The Council for the Bighorn Range is pleased to offer comments during this November 2023 scoping comment period for a climbing management plan for the Tensleep Canyon area in the Powder River Ranger District, Bighorn NF.
The Council for the Bighorn Range is a 501 (c ) (3) organization since 2015 to the conservation of the federally public lands in the area with membership drawn from the communities within the Bighorn Mountains region and including citizens who have an active interest in the land, its resources, its present and future.
The Council for the Bighorn Range sees the purpose and needs immediate steps to be taken, but for the Climbing Management Plan, these issues must be addressed as soon as possible before the 2024-2025 climbing seasons. Any decisions made in the EA must be implemented in a Special Order across the CMP project area.
Parking, Highway, Road, and Pedestrian Safety in the Project Area:
The proposed Mondo Creek restroom facility off US 16 in the parking area should not be visible from the highway or signed for general public use.
All facilities must be attended to by the Bighorn Climbing Coalition, its partners, and successors like the Sheridan Community Land Trust and Sheridan County on the Red Grade Trails. Temporary facilities like the movable porta-potties should also go into partner public-private agreements. Washakie County should also be a party to these agreements as they can apply for Federal and State grants. Again, this points to the Sheridan County agreements and responsibilities with the Red Grade Trails.
Wildlife, botany, fisheries, and the health of the riparian corridors.
Tensleep Canyon and the Tensleep CMP project area is an essential breeding and migratory habitat for several bird species, including sensitive species. Invertebrate species in another. An important habitat area is the cliffs west and southeast of the High Park reach. The High Park climbing zone is coursed by both the Teepee and Indian Creek streams. The current map, "Tensleep Climbing Plan Proposal of No Development" in Appendix B Maps, shows only a slim section of no development for wildlife across the project area. We understand a staff botanist is on the BNF for the first time in many years.
Given the area's enormity and available staff resources, a strong wildlife public-private partnership must be forged for wildlife monitoring in this project. Given the demands of other resources like forest health, fire, and other recreation impacts, there is more than one Southern Wildlife biologist to handle. And the fledge season for some of the most sensitive species in the habitat-rich sector is so short.
A strong educational approach for climber and hiker awareness of migrating, nesting and fledgling birds, their habitats, including cliffs, and the potential impacts. Suggested signage entering the trails or at all parking areas. Include educational information on the Bighorn National Forest website.
Encourage the climbing community organizations to include this information on their sites, printed material and social media, including restraining dogs from disturbing birds and nest sites. Emphasize the need for humans and pets to stay on existing trails.
Conduct and record bird surveys before and after new trails are developed and old trails revitalized.
Cooperation with the Wyoming Game and Fish needs to emphasize non-game wildlife, though the Canyon is a winter range for big game species.
Seasonal closures should carry the power to fine under the CFR. Not voluntary.
Dispersed Camping and other recreational impacts and their management.
Special management of the dispersed camping inventory and monitoring is overdue in the High Park Area along FSRs 429, 433, 435, and 434. FSRs 434, 435 and 434 are critical to the sources for High Park and Teepee Creek feeding into Tensleep Creek and its waters. All within the project area.
Dispersed camping sites should be designated as the Forest does in the West Tensleep corridor. Any forest-wide fee system is implemented in the CMP project area and includes tenters, not including tenting in dispersed Camping, which is a glaring loophole, especially occupancy. Even an $800 tent for a full season on one site is cheap rent, though ruined by that many days under a strong UV lamp at altitude.
Leigh Creek Canyon and Research Natural Area.
The Leigh Creek Natural Area has been a focus of the CBR since its origin and the first emergence of a CMP for Tensleep Canyon. BNF Management has failed to achieve the desired condition for the Leigh Creek Research Natural Area under Management Area 2.2 (Forest Plan, 2-30). The desired condition emphasizes retaining a baseline ecological condition by limiting activities threatening the values for which the Leigh Creek Research Natural Area was proposed or established.
How this CMP addresses RNAs is important to the other RNAs across the Bighorn NF.
The manufactured trail in the RNA, as it has appeared in the last two decades, needs to go away. CBR suggests that though the current tread is manufactured, it largely follows a natural trail route for wildlife and human travel. [I have used the route up and down in birding surveys and following elk from the benches and atop the Leigh Creek Vee pers. RD]
To retain the values of the Leigh Creek Research Natural Area and keep a baseline natural resource condition, rock climbing should not be allowed through much of the Leigh Creek Research Natural Area. Existing user created trails could be classified as a 4 in the Trail Matrix (USDA-FS), and existing climbing routes could be removed as needed.
No new route development is allowed within Leigh Creek Research Natural Area.
Removal of existing routes within Leigh Creek Research Natural Area, except for routes on Godfather Boulder and Chem Trails Wall, located within the first one-tenth of a mile in the Leigh Creek Research Natural Area.
Remove 16 routes in the Twomey Town and Haunted Wall climbing areas. See Appendix A.
Rehabilitate existing social trails within Leigh Creek Research Natural Area to access the climbing routes. Minimal trail (4-5) through the Canyon accepted into the system to minimize impact.
CBR supports the closure of routes in Leigh Creek RNA (Appendix A)
Trails for climbing access and other recreational activities.
The current trail system within the project area consists of a network of user-created trails, none of which are currently part of the Forest's official trail system and are not formally maintained. They were established and used without regard to wildlife, cultural values, USFS standards and guidelines for drainage and occupancy.
All trails must be non-motorized, and only specific trails in the project area open to two-wheel vehicles.
Other individuals and groups seek additional system trials and trailheads in the CMP project area (Nowood Trailbreakers or others), emanating from the Meadowlark Ski Area and High Park using historical trails and roadways; we expect they are evaluated for their impacts as the rest of the CMP trail system.
All trails proposed and adopted by the Forest from volunteer organizations outside Bighorn Climbers Coalition in this scoping period must meet USFS standards in planning and review.
Most of the Tensleep CMP project area land is under RCRA; the decision must prohibit new road construction, including the development of motor vehicle parking areas, unless applied for under the 2001 RACR.
Heritage and Cultural Resources:
The Council for the Bighorn Range was heartened by the inclusion of a representative of the North Arapaho Tribe as an opening presenter at the in-person public meeting for this CMP in Tensleep, WY. The nearby lands under the BLM and private holders like the Nature Conservancy hold large-scale evidence of cultural resources marking thousands of years of occupancy before the Euro-American expansion.
CBR seeks public assurances for the management of heritage resources through compliance with the Section 106 of the National Historic Preservation Act of 1966, as amended (NHPA), and specifically, compliance with the USDA Forest Service Region 2 Programmatic Agreement (PA), entitled "Compliance with the National Historic Preservation Act on The National Forests and Grasslands of Wyoming (09-MU-11020000-003) (PA).
CBR does not seek location information except the work is in full consultation with the Tribal consultants across the region.
The Council for the Bighorn Range comments should be within the scope of the proposed action and suggest alternatives. CBR believes they directly relate to the proposed plan and alternatives and have supporting reasons for the responsible official to consider. If there are questions, don't hesitate to contact Rob Davidson with my information in the signature.
Rob Davidson, President – Director
Council for the Bighorn Range