Ten Sleep Canyon, located in Wyoming in Bighorn National Forest, is a recently developed limestone climbing area, with over one thousand established climbing routes in the canyon. Due to its large quantity of moderate routes, Ten Sleep is a popular destination for newer climbers transitioning from indoor (gym) climbing to outdoor climbing.
 Charlie Kardaleff, Aaron Huey, & JB Haab, Chipping and Manufacturing Climbs in Ten Sleep Needs to Stop, Rock and Ice Magazine. (Feb.18, 2019), https://rockandice.com/climbing-news/open-letter-chipping-and-manufacturing-climbs-in-ten-sleep-canyon-needs-to-stop.
 “Manufactured” climbing routes are those where the rock is “intentionally altered by gluing or chipping for the purpose of creating or enhancing holds.” Id. Most of the manufactured routes were at a difficulty level intended for newer climbers becoming acclimated to outdoor climbing, with the alterations done in order to make the climbs “feasible and enjoyable,” and to “help create more moderate routes.” See Ben Ramsey, Battle For Ten Sleep, Rock and Ice Magazine (Nov. 12, 2019), https://rockandice.com/features/battle-for-ten-sleep.
 Given climbing’s growth in popularity as a recreational sport, climbing-related tourism has become an increasingly sought-after revenue stream. See Battle for Ten Sleep, supra note 34.
 Leyla Brittan, Vigilante Climbers Remove Manufactured Routes, Rock and Ice Magazine (July 15, 2019), https://rockandice.com/climbing-news/ten-sleep-update-vigilante-climbers-remove-manufactured-routes.
 U.S. Forest Service, Letter to Bighorn Climbers Coalition (July 19, 2019), https://gripped.com/news/u-s-forest-service-stops-bolting-in-ten-sleep/. The Forest Service subsequently hired a seasonal climbing ranger to engage in outreach to the climbing community and facilitate in the drafting of the management plan. See Carrie Haderlie, Climbing ranger hired to address concerns in Ten Sleep Canyon, Casper Star Tribune (Aug. 6, 2019), https://trib.com/news/state-and-regional/climbing-ranger-hired-to-address-concerns-in-ten-sleep-canyon/article_365e3f9c-da13-5808-8561-b172502e63b5.html.
 See, e.g., Eli Francovich, Bitterroot bolting ban puts Spokane climbers on edge, spurs national backlash, The Spokesman-Review (Feb. 23, 2020), https://www.spokesman.com/stories/2020/feb/23/bitterroot-bolting-ban-puts-spokane-climbers-on-ed/; Access Fund, What We Can Learn from the Ten Seep Controversy (Aug. 09, 2019), https://www.accessfund.org/open-gate-blog/what-we-can-learn-from-the-ten-sleep-controversy?fbclid=IwAR363zv5slMYfwa317ZmIp5bvKPk0t6CSyvAvnGxNKT36W3_P4-yozd_oAk (“The environment has suffered at the hands of climbers on both sides, and the reputation of the climbing community as a whole is at stake.”).
 “Programmatic regulations” refer to nationally applicable regulations governing a specific resource management program.
 See Yvon Chouinard, Modern Yosemite Climbing, 13 Am. Alpine J. 319, 322–23 (1963) (describing pre-1950s European equipment).
 Id. at 323–24 (describing advancement in gear which allowed for the first ascent of Half Dome).
 Michael Kennedy, Access and the Politics of Climbing: A Long Simmering Stew, 41 Am. Alpine. J. 73 (1999).
 See id., at 13 (“Climbing was something you did when you were young and restless. You learned the ropes from other climbers, much as an apprentice learns from a master, and toiled in obscurity at your craft. It was a harmless enough diversion that would eventually give way to the adult pursuit of work, marriage, mortgages, and children.”).
 See infra Section I.A.
 See Access and the Politics of Climbing, supra note 12, at 13.
 See Bureau of Economic Analysis, Outdoor Recreation Satellite Account, 2012-2017 (2019), https://www.bea.gov/data/special-topics/outdoor-recreation (“The U.S. outdoor recreation economy accounted for 2.2 percent ($427.2 billion) of current-dollar gross domestic product (GDP) in 2017. The Outdoor Recreation Satellite Account (ORSA) also shows that inflation-adjusted (real) GDP for the outdoor recreation economy grew by 3.9 percent in 2017, faster than the 2.4 percent growth of the overall U.S. economy.”); USDA, Federal Outdoor Recreation Trends: Effects on Economic Opportunities 7 (2016), https://www.fs.fed.us/pnw/pubs/pnw_gtr945.pdf (projecting 3.6% growth in “challenging backcountry activities” from 2008–2030”).
 See Erik Daniel Murdoch, Perspectives on Rock Climbing Through the Lens of the Wilderness Act: Social, Legal, and Environmental Implications at Joshua Tree Nat’l Park (April 26, 2010) (unpublished Ph.D. dissertation, University of Arizona). Slings are typically made of tubular nylon and secured around natural features such as trees, or large rocks wedged in cracks. Runners, Freedom of the Hills 8th ed. ch. 9 (2010). Bolts are “steel shafts typically three-eighths of an inch wide and one-half inch long” placed into similar sized holes in the rock drilled by a climber using a hand or power drill. Timothy Dolan, Fixed Anchors and the Wilderness Act, 34 U.S.F.L.R. 355, 358 (2000). Pitons are “metal spikes” with a hole in one end for a carabiner hammered into cracks or fissures in the rock. Id.
 “Belaying” refers to climbing techniques where a leading climber’s partner manages rope tension to limit the length of a fall.
 See Fixed Anchors and the Wilderness Act, supra note 20, at 359 (“[T]he climbing population as a whole depends on existing fixed anchors to climb safely.”).
 See Perspectives on Rock Climbing, supra note 20, at 14.
 This paper’s scope is limited specifically to sport and traditional climbing. Bouldering provides its own unique regulatory challenges better addressed independently.
 Bouldering involves climbing smaller rock formations, typically shorter than twenty feet, without the use of any protection. The style emphasizes practicing and training for individual, difficult moves rather than the completion of longer routes.
 See Craig Leubben, Rock Climbing: Mastering Basic Skills, 12 (2004) (describing principles of “traditional” climbing) (hereinafter Climbing Skills).
 “Clean climbing is climbing the rock without changing it.” Doug Robinson, The Whole Art of Natural Protection, Chouinard Equipment Catalogue, 12–13 (1972), http://climbaz.com/chouinard72/chouinard.html.
 See id. at 2–3.
 See Climbing Skills, supra note 26, at 12.
 “Route development” refers to the process by which sport climbing and traditional climbing routes are identified and established. See generally British Columbia Parks Dep’t, Best Practices Guide for Rock Climbing Route Development (Oct. 2012), https://access-society.ca/resources/Documents/Best%20Practises%20rock-route-dev.pdf (describing techniques and considerations for rock climbing route development).
 This process is generally referred to as “comfortizing.”
 See Best Practices for Route Development, supra note 31.
 See Aram Attarian, An Investigation of the Ecological and Social Impacts Caused by Rock Climbing in Proceedings of the 1991 Int’l Conference on Outdoor Recreation (hereinafter Ecological and Social Impacts), 10 (1992); Access Fund, Climbing Management: A Guide to Climbing Issues and the Development of a Climbing Management Plan, 8 (2008) (hereinafter Climbing Management).
 Id. at 13–14.
 See Richard L. Knight & David N. Cole, Wildlife Responses to Recreationists in Wildlife and Recreationists: Coexistence Through Management and Research, 57 (1995).
 Climbers use gymnastics chalk to reduce the moisture on their hands to better grip the rock. See Climbing Skills, supra note 26, at 65.
 Brightly colored ropes and webbing, shiny metal hardware, and white chalk contrast against the natural color of the rockface. See Ecological and Social Impacts, supra note 35, at 11; see also National Park Service, Advanced Notice of Proposed Rulemaking and Management Statement for Rock Climbing Regulations, 58 Fed. Reg. 32,878, 32, 879 (June 14, 1993); Climbing Management, supra note 35, at 25, 27–28.
 See Climbing Management, supra note 35, at 9 (“The type of climbing that occurs in an area may also have an effect on the amount of impact an area receives. . . Trail quality, the number of similarly rated climbs in the area, and the presence of overhanging rock were found to contribute to staging area impacts for sport climbs.”).
 Id.; see also Ecological and Social Impacts, supra note 35, at 10.
 See Ecological and Social Impacts, supra note 35, at 10–11.
 See id. at 8; Access Fund, Climbing and Cultural Resources: A Tough Balance, A Tougher Conversation (June 18, 2012), https://www.accessfund.org/open-gate-blog/climbing-and-cultural-resources-a-tough-balance-a-tougher-conversation.
 See Access and the Politics of Climbing, supra note 12, at 13 (“In large measure, too, climbers were paid scant attention by land managers and others concerned with the stewardship of our public lands.”).
 Id. The removal of fixed anchors is one such enforcement mechanism that has long been in practice. See, e.g., Peter Beumant, Climbers anger Italians by removing bolt ‘ladder’ from Cerro Torre peak, The Guardian (Feb. 16, 2012), https://www.theguardian.com/world/2012/feb/16/climbers-italians-bolt-ladder-cerro-torre; T.M. Herbert, Comment on Two Ascents of the Wall of Morning Light, 17. Am. Alpine. J. 361 (1971) (discussing Royal Robbins’ removal of fixed anchors placed by Warren Harding during the first ascent of the Dawn Wall).
 See infra notes 57–60 and accompanying text.
 See, e.g., U.S. Forest Service, Sawtooth Wilderness Occupancy and Use Guidelines, Order No. 0414-04-102 (June 19, 2013).
 Pub. L. 88-517, 74 Stat. 215, (June 12, 1960), 16 U.S.C. § 583 et seq.
 16 U.S.C. § 531(a)–(b) (2020); see George Cameron Coggins & Parthenia Blessing Evens, Multiple Use, Sustained Yield Planning on the Public Lands, 53 U. Colo. L. Rev. 411, 422–23 (“Multiple use is the management of national forest resources in the combination that will best meet the needs of the American people, making periodic adjustments for changing needs and conditions, without impairment of land productivity.”).
 Pub. L. 93-378, § 6, formerly § 5, 88 Stat. 477, (Aug. 17, 1974), 16 U.S.C. §§ 1600 et seq., The RPA focused on national planning and charged the Forest Service with developing resource management plans aimed to facilitate better coordination of the forest system’s multiple uses, including outdoor recreation. See Charles F. Wilkinson & Michael H. Anderson, Land and Resource Planning in the National Forests, 64 Or. L. Rev. 1, 37 (1985) (describing the RPA’s purpose as “to improve funding ‘to achieve long- and short-term goals for national forest use’”).
 Pub. Law. 94-588 §§ 2–12, (Oct. 22, 1976), 16 U.S.C. § 1600 et seq.
 16 U.S.C. § 1601(g)(3)(A) (2020); see Land and Resource Planning, supra note 51, at 40–45.
 36 C.F.R. § 219.1 et seq. (2020).
 36 C.F.R. § 219.8 (2020).
 Forest Service regulations mandate consideration of “recreation settings and opportunities” and include standards and guidelines for “sustainable recreation.” Id. § 219.10(b) (2020).
 Jeff Achey, Fixed Anchors in the Wilderness, Climbing Magazine (Dec. 18, 2015), https://www.climbing.com/people/fixed-anchors-in-the-wilderness/.
 See Perspectives on Rock Climbing Fixed Anchors, supra note 20, at 52.
 When establishing specific regulations for the Sawtooth Wilderness in 1997, the Forest Service decided to categorically prohibit any placement of fixed anchors upon the recommendation of the only climber involved in reviewing the proposed management plan. Climbing advocates intervened, seeking application of the guidelines recommended by the 1990 task force. In 1998, the Forest Service responded by expanding the fixed anchors prohibition to all Forest Service managed wilderness. See Fixed Anchors in the Wilderness, supra note 57.
 See 64 Fed. Reg. 53,368 (Oct. 29, 1999). Unlike BLM and the NPS, the notice of intent does not expressly recognize climbing as a legitimate recreational use of wilderness.