Public comment on wilderness area fixed hardware

I believe that the concern is that under the propose rules, each point of fixed pro in Wilderness areas would require that the Parks or the USFS go through the NEPA process, which is both time consuming and laborious. 

Bill Lawry wrote:

I’d like to see that relationship grow, to see climbing individuals and climbing groups working with environmental groups and land managers to minimize impact that, yes, could include decisions to not develop further in areas.

Another way to ask the question:   If the PARC Act passed, will MP users see these things end …

Those types of things will never end.  Climbing is often done by individuals wanting to be mostly free of typical government rules.

There will always be some rule violators.  For example, do we close the roads when people break traffic laws?  No, we don't let the marginal voices dominate the decision process.  Instead most of us work to find reasonable and worthwhile rules to limit significant unsustainable impacts of climbing.  That does not mean restricting climbing whenever there is minor impact from a couple of bolts, which seems to be the direction the government is heading for.  Instead we need limits only when there is a cumulative large detrimental impact.

I think people misunderstand some things. The Wilderness Act isn't directly about protecting the environment. It's about restricting pretty specific activities in Wilderness areas. 

It doesn't matter if bolts have less impact than people, or hikers, or horses, or whatever. It's simply that bolts are "installations" and are restricted in Wilderness by the Wilderness Act. 

The NPS and USFS are just finally waking up to the fact that The Wilderness Act probably requires them to manage bolts in Wilderness, and they are moving forward with doing it. 

Climbers might even be losing out to Wilderness groups that would prefer a total ban on all fixed anchors in designated Wilderness. 

J E wrote:

I think people misunderstand some things. The Wilderness Act isn't directly about protecting the environment. It's about restricting pretty specific activities in Wilderness areas. 

It doesn't matter if bolts have less impact than people, or hikers, or horses, or whatever. It's simply that bolts are "installations" and are restricted in Wilderness by the Wilderness Act. 

The NPS and USFS are just finally waking up to the fact that The Wilderness Act probably requires them to manage bolts in Wilderness, and they are moving forward with doing it. 

Climbers might even be losing out to Wilderness groups that would prefer a total ban on all fixed anchors in designated Wilderness. 

There it is.

tom donnelly wrote:

There will always be some rule violators.  For example, do we close the roads when people break traffic laws?  No, we don't let the marginal voices dominate the decision process.

A reasoned decision process is necessary. And the marginalized voices can be kept out of that. But this is not sufficient.

We also spend a lot on traffic-law enforcement in order to not let marginal voices dominate our streets and highways.  Because we decided money spent on enforcement is ultimately worthwhile in terms of lives and profits.

While I / we value the wild places, the same traffic-law motivators seem not there. 

TJ Bindseil wrote:

Do you happen to have a link to where to make a comment?

nvm: here it is: https://gcc02.safelinks.protection.outlook.com/?url=https%3A%2F%2Fcara.fs2c.usda.gov%2FPublic%2FCommentInput%3Fproject%3DORMS-3524&data=05%7C01%7Ccynthia_hernandez%40nps.gov%7C8a676c25d7c84baede4b08dbe6256693%7C0693b5ba4b184d7b9341f32f400a5494%7C0%7C0%7C638356820529649851%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C&sdata=klaLYQGduUna58XQAWXtVExfeewB0mi5BkvRP8HgRgM%3D&reserved=0 

Ok I wrote one to this link.  Here it is:

Hello,

I am writing in favor of the Protect Americas Rock Climbing act. Specifically, I would like to state that I think fixed anchors should not be banned outright as installations. I believe rock climbing in its current form is not possible without the occasional fixed anchor, and I believe rock climbing to be a positive for our nation.  

I have been climbing for about 6 years now, and I can say without a doubt that rock climbing is an incredible pursuit. It brings me joy, helps me hone my discipline, and has increased my mental and physical health.  I hope this can remain available to future generations. 

More specifically in regards to the proposed ban on fixed anchors, I know climbing has taught me the importance of respecting the land and being self sufficient.  Typically, a climber making the first ascent of a new route will attempt to leave as little fixed gear as possible. I’m other words, where fixed gear is left, the climber simply had no other option for safe passage. A climber will sometimes even risk a large fall by moving over a large piece of unprotectable rock without placing a bolt, simply to avoid extra fixed gear.  These fixed anchors are paramount to these particular routes, and the consequences are very minimal.  We are allowed to recreate and travel in the wilderness, why not be allowed to do so safely? I think if number of people is the issue, a permit system would be more effective. 

Another point I would like to make is that a blanket ban would leave out the possibility of nuance at the local level.  Climbing is a highly localized activity, with deep traditions that govern how climbers use the rock.  Coordination with the local climbing coalition will yield positive results towards whatever goals the local land managers have prioritized.  One great example that comes to mind is the flatirons climbing coalition in boulder colorado.  Here, the coalition works with the open space mountain parks organization to determine what routes will be bolted.  In addition, the flatirons climbing coalition organizes trail days and cleanup days, making the whole of the flatirons better.  This creates a channel of coordination between the climbers and the government.  A blanket ban would jeopardize this symbiosis.  

Please consider working with the access fund to protect America’s climbing.  We have a rich tradition here, and I personally am so excited to get out and see our beautiful wilderness from the awe inspiring positions that a few bolts and a whole lot of knowledge, training, skill, perseverance and tenacity will allow

Thank you for reading this,

TJ

Thanks to any and all who have taken the time to submit comments on the draft plans put forth by the NPS and USFS. This is the good fight. If you’re still on the fence, or unsure what’s at stake, please read John Steiger’s comment towards the end of this forum. 

https://www.mountainproject.com/forum/topic/125381797/fixed-anchors-wilderness

I’m no lawyer or policy analyst, so it’s a good thing that folks like John speak up! But here’s the thing, if you read the NPS and USFS proposals, it’s all there to see in pretty clear language. Don’t let this go. Don’t give up! Apathy on our part is what they are counting on. This is a big deal, and it needs to be respectfully challenged at every level and every turn. Our way of life is under threat. Make no mistake about it. We are at the crossroads of land management and unprecedented growth in adventure sports. We stand our ground or that ground will be taken away. Simple as that. 

John Steiger’s comment:

I’ve been following this thread and the corresponding thread under “General Climbing” for some time, but a bout with covid and time put into the comments I plan to submit to NPS & FS have kept me from adding my two cents.  But time is running out to comment and I’m dismayed that the climbing community still seems to be largely sleeping on this issue, so:

Again, the deadline is January 16 at midnight.  As of this morning, the FS web log shows only 949 comments submitted.  I assume many of these are from fixed-anchor-ban advocates.  Those of us who want to preserve our and other’s opportunities to use fixed anchors in Wilderness, as we have been doing for now 60 years — and specifically for decades in Southern Arizona, must step up.  If the proposed guidance stands as written, every sport route and possibly many trad routes reliant on fixed anchors in the Pusch Ridge Wilderness will effectively be erased in a matter of years, and new route development in Wilderness will largely end (more on this in a sec).  Maybe Andy, EFR, or others can offer a better guess, but I suspect this means the loss of several hundred routes, some of which have existed for years and are some of the best in the Catalinas if not the desert southwest.

You can comment more than once, so don’t hesitate.  If you’ve commented, and another aspect of the issue comes to mind or you see something someone else has said that rings true, comment again.  Comments work.  The climbing community faced this threat — i.e., a handful of agency personnel attempting to create national policy based on their own belief that fixed anchors are prohibited “installations” under the Wilderness Act — in 1999-2000 and the outcry from individual climbers was crucial in stopping it. 

Facts matter.  If you‘ve used fixed anchors in Wilderness, repeating a route or putting one up, whether before Wilderness designation or after, say so in your comments and provide some personal examples.  Say why the fixed anchors were critical to your experience and enjoyment of the area and that the route would not be safely possible without them (but only if true in your opinion; there is no need to varnish the facts).   Except for a very few Wilderness areas, such as the Superstition Wilderness, placing fixed anchors has never been and is not currently prohibited.  (Motorized drills, though, have always been prohibited).  If you wish to verify the legal status of fixed anchors in a particular Wilderness area before explaining your experience, usually the agency website can help — but realize that almost all of the current fixed anchor restrictions were recently adopted, typically in the form of an order or (for NPS) a change to the Superintendent’s Compendium within the last several years.  (In case you‘re wondering, to my knowledge none of the current fixed anchor restrictions are based on the legal position that fixed anchors are prohibited “installations” under the Wilderness Act).

Some have argued that the threat of the proposed guidance is overblown because of agency budgetary limits and because the proposed guidance provides an authorization mechanism to place or replace fixed anchors (the so-called MRA process).  As most of my Arizona buds know, I worked for Interior for decades advising BLM and NPS and often engaging with FS (which I also worked for during three summers before law school) and I’m confident in my understanding of the bureaucracy and the consequences laid out above should the proposed guidance stand.  It is not expensive to remove fixed anchors, and if there is sufficient pressure to do so, agencies will find the money.  If the agency does not have the funding, and the fixed anchors become a safety concern or their continued use is deemed a factor in further “illegal” bolting, the agency likely will close the area to climbing until the anchors can be removed.  The MRA process will be laborious and expensive (there will be many procedural steps under NEPA, NHPA, ESA, etc.), and the process begins with the premise that fixed anchors are illegal and can only be authorized if the agency finds the fixed anchor to be “the minimum necessary for administration of the area for Wilderness Act purposes.“  That is going to be a tough sell, even if the deciding official is climber friendly.  Take note that some fixed-anchor-ban advocates argue that the Wilderness Act does not provide a “minimum” tool exception to the prohibition on “installations,” and even if it does, that a fixed anchor can never meet the “minimum necessary” standard and therefore the MRA process should not even be afforded.

The issue here is not Wilderness protection.  Most climbers I know are strong Wilderness advocates (including me).  No one is arguing that the agencies cannot or should not regulate fixed anchor use, even remove fixed anchors, to protect wilderness character.  The agencies have full authority to do so under their organic and related statutes, and in fact have relied on this authority both to prohibit and remove fixed anchors from entire crags in the past.  But for some reason, starting around 1997, seemingly every few years a handful of agency personnel seize on the prohibited “installation“ language of the Wilderness Act to try to force an agency to take a legal stand making all fixed anchors in Wilderness illegal.  This despite the fact that climbers have been placing fixed anchors (bolts, pins, slings, etc.) in numerous Wilderness areas throughout the country with agency acquiescence if not support for literally generations.  Es una locura. 

A problem with many arguments here is that they are against ideas that the NPS/USFS aren't proposing. Those comments will just be ignored. Comments that suggest bans on bolts will just be dismissed as not well informed. This is probably why the Access Fund went with attacking the idea that bolts are installations (even though everything similar to a bolt is managed as an installation) because every other thing the agencies are proposing is compatible with the ideas most people seem to support on this forum.

 It's potentially reasonable to think that the agencies shouldn't manage bolts at all, but if you think the agencies should be managing bolts, the proposal put forward is the logical way for a bureaucracy to do it.

Climbers might need to accept that the Wilderness Act is annoying when it finally comes after your favorite activity. 

J E wrote:

Climbers might need to accept that the Wilderness Act is annoying when it finally comes after your favorite activity. 

Some activities such as climbing are a bit less impactful than others such as golf, OHV, mining, oil exploration, drilling, popping a 24” pipe through Native Reservations when the alternative would cost only 50M more for a line that delivers that much oil per quarter… the Wilderness Act covers all activities.

Some politicians want to equate drilling bolts for safe climbing with everything from the list above and more.

That’s the real reason why we’re struggling to be able to use bolts and ice screws.

It is more fair to compare climbers to hikers, skiers, mountain bikers, horseback riders, hunters, etc. None of those groups get to leave behind fixed anything without talking to the land manager, and anything they do leave permanently is treated as an installation and subject to MRAs. I can't really come up with anything like fixed anchors that other groups get to take advantage of. Just worth noting that climbers are probably fighting an uphill battle. 

J E wrote:

It is more fair to compare climbers to hikers, skiers, mountain bikers, horseback riders, hunters, etc. None of those groups get to leave behind fixed anything without talking to the land manager, and anything they do leave permanently is treated as an installation and subject to MRAs. I can't really come up with anything like fixed anchors that other groups get to take advantage of. Just worth noting that climbers are probably fighting an uphill battle. 

Trail markers.

John Steiger wrote: "Facts matter.  If you‘ve used fixed anchors in Wilderness, repeating a route or putting one up, whether before Wilderness designation or after, say so in your comments and provide some personal examples"  Lol that way it'll be easier to find and remove the offensive "installations".  

Li Hu wrote:

Trail markers.

Those are treated at installations, subject to MRAs, carefully regulated. They are also used by every group. 

Listen to this at least twice:

https://open.spotify.com/episode/5YwbHRh0YPaGP6D4hDqgY5?si=bFipg2xQTK2AOba6IT1kvg

Use the Access Fund’s talking points to submit comments.

Whatever time is spent ranting here in this forum should be at least matched with taking action with well-aimed commentary.

J E wrote:

It is more fair to compare climbers to hikers, skiers, mountain bikers, horseback riders, hunters, etc. None of those groups get to leave behind fixed anything without talking to the land manager, and anything they do leave permanently is treated as an installation and subject to MRAs. I can't really come up with anything like fixed anchors that other groups get to take advantage of. Just worth noting that climbers are probably fighting an uphill battle. 

let me help out a little with an example (there are many others): half dome in yosemite

on two sides you have climbing routes involving bolts (for climbers) and on one side you have cables (for 'hikers').  on the climbing routes with bolts you have maybe ten parties on a busy day, most of them on snake dike.  that's twenty or so people.  the bolts are so small and invisible that even climbers 'on' a route sometimes miss them (occasionally resulting in severe falls with serious consequences).  bitd, there were no permits required for half dome and there were hundreds of people going up and down the cables and a big pile of gloves at the base.  these days a permit quota ('to preserve the wilderness character') exists to hike up the cables - it is capped at three hundred people/day...

old5ten wrote:

let me help out a little with an example (there are many others): half dome in yosemite

on two sides you have climbing routes involving bolts (for climbers) and on one side you have cables (for 'hikers').  on the climbing routes with bolts you have maybe ten parties on a busy day, most of them on snake dike.  that's twenty or so people.  the bolts are so small and invisible that even climbers 'on' a route sometimes miss them (occasionally resulting in severe falls with serious consequences).  bitd, there were no permits required for half dome and there were hundreds of people going up and down the cables and a big pile of gloves at the base.  these days a permit quota ('to preserve the wilderness character') exists to hike up the cables - it is capped at three hundred people/day...

Sure, the Half Dome cables are a good example of some fixed stuff for hikers. They are also basically unique, unlike rock climbs. Of course, they predate the Wilderness Act, but ate still considered an "installation" and have been reviewed extensively by the NPS, and they decided that they installation is necessary. 

Exactly what the NPS now says it needs to do for the other routes on half dome. The size of the impact is considered in the MRA process, so it's probably easier to justify the bolts on the rnwf than the cables, but they still need to be reviewed per the Wilderness Act. 

So what are you frustrated by? You don't want any review? 

Re fixed stuff for other user groups: trails and parking are the big ones. Parking lots, foot bridges, trail markers, rock steps, cairns, painted blazes, erosion control, just to name a few, used by hikers, fishermen, climbers, horseback riders…just about everyone.

All these are allowed because they are “in the plan”, and as such are managed. Seems not a huge step to have anchors added to that list, no?

In Sequoia Wilderness we would be fined if we left a cairn with note for the following party (removed same day, not permanent) or had our sleeping pad on so much as a blade of grass. However we did lots of service projects rebuilding the backcountry ranger’s horse corrals.

The wilderness Act does NOT consider each bolt to be an installation of significance.

Some of the primary backers of the Wilderness Act placed bolts in wilderness and they meant for the Wilderness Act to NOT apply to minor amounts of bolts.

For 50 years this remained the meaning and interpretation of the Act.  

So it is a brand new revisionist interpretation to claim that minor bolting is a prohibited installation requiring analysis by the bureaucrats.

Only larger amounts of bolts at a crag or sport routes should require permits.