Black Canyon Wilderness and Backcountry Management Plan

Colorado climbers (and anyone else who enjoys this place!) should consider voicing their opinion/ desires about the proposed management plan in the Black Canyon. Comment form closes at midnight on Thursday, Aug 4.

Access Fund Notice

NPS Comment Form

Dylan Cousinswrote:

Colorado climbers (and anyone else who enjoys this place!) should consider voicing there opinion/ desires about the proposed management plan in the Black Canyon. Comment form closes at midnight on Thursday, Aug 4.

Access Fund Notice

NPS Comment Form

Yup yup! Post away folks, let them know how important the Black is to us!!

Super important. Thanks for the heads up Dylan!

Commented.

Those who have done GWW, remember this delightful belay anchor after the .10+ thin hands roofs pitch?

I found the Access Fund description of the proposed changes to be a little unclear. What exactly is being proposed that poses a problem? How is it different from what are the current regulations and enforcement? One point of emphasis is the Minimum Requirements Analysis (MRA), but that phrase by itself seems reasonable (see MP threads on over-bolting as counter examples). AF makes it sound like MRA is associated with normally prohibited activities, but what is the source of that information? What is an example of how MRA is used for another activity?

BTW, I am on the side of _fewer_ regulations. But I think it is important to make cogent and reasonable arguments when making comments to a proposed management plan, and I think some answers to my questions will help us do this. I do see that the comment period closes tomorrow night.

Completely inaccurate statements like the following (found on pg 41 of the draft management plan) show just how out of touch some wilderness managers are when it comes to climbing in the Black Canyon:

“Of the known 145 climbs [in the Black Canyon] eight are rated at 5.8, and of these eight only four have good information available and see regular ascents. Twenty-one climbs have a rating of 5.9; five of these are aid routes, and only six of them see any significant climbing activity. The other 117 climbs have ratings between 5.10 and 5.13 (the highest grade being 5.15), and many require aid.”

Pre-approval for any bolt placement, or bolt replacement, in the Black sounds like trying to fix a problem that simply isn’t there to begin with. Historically speaking, many of the routes in the Black have been onsight, ground-up FAs with minimal bolts hand drilled on lead. Not really sure how pre-approval is going to work when one doesn’t know the terrain they’re entering, or the exact line they’re wanting to take. I guess rappel an 1800’ wall and figure out where you might want to place bolts like you’re developing a sport route? Then go ask for permission?

Edit: Also, I don’t mean to sound like I’m preaching a ground-up ethic that everyone should abide by with route development in the Black. Top-down inspection has yielded some of the best hard routes in the canyon by climbers way more talented than myself. I’ve done the same thing at times on far easier and more mediocre routes. However, I question how feasible it is for someone planning a FA to get approval for every single bolt placement… and what is the review process for that? Who is ultimately deciding to give permission?

I am 100% in support of policies that help maintain the pristine aspect of wilderness below the rim in the Black Canyon, but some of these proposals seem to be a knee jerk reaction to climbing and bolting that fall in line with other National Parks’ policies (or policies they want to implement). For example, comparing the Black Canyon to Joshua Tree when it comes to bolting policies is not apples to apples.

Jonathan Swrote:

I found the Access Fund description of the proposed changes to be a little unclear. What exactly is being proposed that poses a problem? How is it different from what are the current regulations and enforcement? One point of emphasis is the Minimum Requirements Analysis (MRA), but that phrase by itself seems reasonable (see MP threads on over-bolting as counter examples). AF makes it sound like MRA is associated with normally prohibited activities, but what is the source of that information? What is an example of how MRA is used for another activity?

BTW, I am on the side of _fewer_ regulations. But I think it is important to make cogent and reasonable arguments when making comments to a proposed management plan, and I think some answers to my questions will help us do this. I do see that the comment period closes tomorrow night.

I am the advocacy chair of the Boulder Climbing Community and have been working on our submission as well as the AF’s submission.  Under section 4(c) of the Wilderness Act, certain activities, such as motorized equipment, are prohibited.  To get an exception to that prohibition, you need to show that the exception is needed “to meet the minimum requirements for the administration of the area.”  So, for example, since power drills are prohibited as motorized equipment, if you wanted to use a power drill you would need to meet the MRA standard.  Because it is for things that are normally prohibited, the MRA imposes a tough standard to justify giving you an exception to that prohibition.

So, because fixed anchors are not generally prohibited and, indeed, have been widely accepted in appropriate situations, the MRA standard should not apply.  The Black Canyon plan proposes to require that all fixed anchors, whether new or replacements, have both prior authorization from the Park and that such authorization requires that the applicant meet the MRA standard.

There is a lot more to the Plan, including banning commercial guides, limiting the total number of climbers per day by area, requiring prior approval for new routes, and banning climbing in the “Pristine” zone.  Too much to cover in an MP post.  But, I hope that helps explain the MRA issue.

Tom Isaacson

I submitted comment, focused mostly on the inappropriate/unnecessary MRA process that will derail what's already working, as everyone else has described.

But I also noted how this plan would disrupt what has, in my opinion, been a model relationship between the Park Service and climbers. In stark contrast to places like Yosemite where there has been historical enmity, a beauty of the Black has always been the amicable nature. Climbers and the Park have created a wonderful structure that is mutually supported on both sides and operated as allies. This plan would mark a turn in the other direction. When rules are untenable or unreasonable, people ignore them and try to find ways around them, climbers most of all. I predict a rift would form as climbers vacate their support of the Park Service and instead view them as antagonizers, resorting to clandestine bolting tactics etc, which all leads down a road where nobody wins.

perhaps my argument is sketchy, but this is the comment I left:

My comments are directed towards the Climbing Management Plan. 

Opinion: my opinion is that the Park Service DOES NOT NEED to regulate fixed anchors, and should maintain the status-quo policy of advising on the placement and maintenance of, but not explicitly regulating, fixed anchors. 

Reason: By introducing regulation around fixed anchors, the Park Service may be implicitly assuming new legal responsibility for the integrity (safety) of ALL fixed anchors within the Park. This is a dangerous and unwarranted precedent.  Since the Park Service has not installed these fixed anchors, they should not assume responsibility for the integrity of these anchors. If an authorized anchor fails, is the Park service now legally responsible for the consequences? 

If introducing new regulations around fixed anchors will be accompanied with new legal responsibilities for the integrity of those anchors, this is a dangerous precedent that should not be pursued. The Black Canyon already has a strong anti-bolting tradition that places the responsibility on individuals, and not the Park Service. There is no evidence to suggest that the existing policy is leading to excessive environmental damage, and in light of the additional legal risk imposed by the new policy, I recommend against it. 

Scotty Nelson

Does anyone know when the management plan will be available?

Side note: I hear they are installing stocks in the campground or all the violators. 

Tom Isaacsonwrote:

I am the advocacy chair of the Boulder Climbing Community and have been working on our submission as well as the AF’s submission.  Under section 4(c) of the Wilderness Act, certain activities, such as motorized equipment, are prohibited.  To get an exception to that prohibition, you need to show that the exception is needed “to meet the minimum requirements for the administration of the area.”  So, for example, since power drills are prohibited as motorized equipment, if you wanted to use a power drill you would need to meet the MRA standard.  Because it is for things that are normally prohibited, the MRA imposes a tough standard to justify giving you an exception to that prohibition.

So, because fixed anchors are not generally prohibited and, indeed, have been widely accepted in appropriate situations, the MRA standard should not apply.  The Black Canyon plan proposes to require that all fixed anchors, whether new or replacements, have both prior authorization from the Park and that such authorization requires that the applicant meet the MRA standard.

There is a lot more to the Plan, including banning commercial guides, limiting the total number of climbers per day by area, requiring prior approval for new routes, and banning climbing in the “Pristine” zone.  Too much to cover in an MP post.  But, I hope that helps explain the MRA issue.

Tom Isaacson

What, exactly, did you explain here? I must have missed it. At no point did I get a whiff of why this is such a pressing concern.

Trad Manwrote:

What, exactly, did you explain here? I must have missed it. At no point did I get a whiff of why this is such a pressing concern.

Jonathan S asked whether the AF was correct about the MRA standard and the source of that information.  I answered those questions: the AF is correct and the source is section 4(c) of the Wilderness Act.

Lane Mathiswrote:

Does anyone know when the management plan will be available?

Side note: I hear they are installing stocks in the campground or all the violators. 

The draft management plan is available here: https://parkplanning.nps.gov/document.cfm?parkID=33&projectID=106111&documentID=121570

Scroll down to the bottom. The PDF is linked (file name BLCA CURE_Draft Plan and EA_508.pdf).

a Ballwrote:

The draft management plan is available here: https://parkplanning.nps.gov/document.cfm?parkID=33&projectID=106111&documentID=121570

Scroll down to the bottom. The PDF is linked (file name BLCA CURE_Draft Plan and EA_508.pdf).

Thanks a Ball. I was referring to the finalized plan but failed to clarify.