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ASCA Call to Action on the Proposed NPS/USFS Wilderness Directives
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Dear climbers, The American Safe Climbing Association (ASCA) has released a Call to Action regarding the NPS and USFS proposed directives regarding wilderness climbing. Please read the full Call to Action on the ASCA website. THE NATIONAL PARK SERVICE (DRAFT REFERENCE MANUAL 41: WILDERNESS STEWARDSHIP) AND U.S. FOREST SERVICE (FSM 2355 CLIMBING OPPORTUNITIES) HAVE RELEASED DOCUMENTS THAT WOULD MAKE FIXED ANCHORS PROHIBITED IN WILDERNESS AREAS. These management directives propose to reverse nearly 50 years of policy under the Wilderness Act, and will severely erode a century of cooperation between the climbing community and the National Park and US Forest Services. The new policies would classify fixed anchors as “prohibited installations” in Wilderness areas. This new classification would apply to both new and existing anchors. This would threaten the existence of fixed protection on routes that have been enjoyed by climbers for decades, and obstructs climbers’ ability to replace bolts when they become unsafe. This creates not only safety concerns but also leads to resource degradation as more climbers seek out natural features like trees for anchoring in the absence of reliable anchors that are typically placed well away from vegetation features in clean sections of rock. The ASCA does not oppose guidance on fixed anchor placement in wilderness areas, but these NPS and FS directives are unreasonable. They are unenforceable, will create more problems than they solve, will deeply impact safety for climbers, and will accelerate impacts on wilderness resources, not reduce them. We encourage all climbers to read the documents in their entirety to understand what is being proposed, but we acknowledge that there is a lot of text to sift through and it is time-consuming. The Access Fund has written an excellent summary if you do not have time to read through all the contents of the proposed directives. The ASCA asks all climbers to comment on both documents. This is the only opportunity we get to change the language in these directives, and it is imperative that we make our voice heard, as it will have a major impact on future climbing opportunities and safety throughout climbing areas on our public lands. Use the links provided to access the comment forms and please read through our comments for talking points to address. Here's a link to comment on the USFS draft directive. Here's a link to comment on the NPS draft directive. EDIT: The deadline for public comments has been extended to January 30th. |
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hey! I can't find anywhere that uses the language 'prohibited installations' inside of the NFS proposed policy. are we reading the same document? the language that you use here seems overly sensational. I can't find anywhere that prohibits bolting, just language that specifies that climbers should adhere to local climbing development plans. |
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Done, thanks for everything you do ASCA. |
Todd Bloomwrote: In the NPS document, Section 1 states:
In the USFS proposal, read 2355.32. One of many key phrases is:
Now if you go to that section of the wilderness act, installations are prohibited. |
Todd Bloomwrote: https://parkplanning.nps.gov/document.cfm?parkID=442&projectID=113918&documentID=132387 Page 3, 4th paragraph states that fixed anchors are "a type of installation" and then says that "fixed anchors constitute a prohibited use pursuant to the Wilderness Act §4(c)...." The NPS policy prohibits bolting for new routes or placing any new fixed anchor (including slings) without either individual approval from a park manager (p. 4, last paragraph), or a formal park plan for climbing management (p. 4, second paragraph). Replacing existing fixed anchors can only be done either after an evaluation of all routes in a park--a process which is not funded and has no deadline. (p. 5 first paragraph) In the meantime, only "emergency" replacement is allowed, under a standard that allows park staff to determine after the fact whether the climbers used the "safest and most expeditious manner possible" to exit the climb. (Ibid.) Not sure what you read, but this is a de facto bolt ban (and sling, pin, etc. ban) that can only be lifted if the park service takes discretionary, unfunded action. |
Nkane 1wrote: Thanks for your response. This is exactly the language in the NPS draft directive. This is our only chance to act on it. Let's take unified and decisive action while it counts to protect wilderness climbing in the US. |
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I submitted comments this morning, if you struggle writing letters like I do, you can use Google Docs AI to write a first draft and then add the appropriate language from the Access Fund website. |
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Letters sent. I trust the ASCA the most out of all nationwide climbing orgs. |
Cory Nwrote: Would you mind posting your letters? People are more likely to respond if they can just copy, paste, send. It’s not ideal, but better than nothing. |
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These are largely cut and paste from the Access Fund site, but here are mine: NPS: I am against the bolt prohibition. Fixed anchors are an essential piece of climbers’ safety system and are not prohibited “installations” under the Wilderness Act. Fixed hardware and bolts are no more installations than trail signs. They are less visually obtrusive than trails. Many accidents in other remote areas could have been prevented with minuscule fixed hardware. It is unreasonable for federal agencies to create new guidance policies prohibiting Wilderness climbing anchors across the country when they have allowed, managed, and authorized fixed anchors for decades. Prohibiting fixed anchors will create safety issues by imposing unnecessary obstacles to the regular maintenance of fixed anchors, a responsibility undertaken by the climbing community. Fixed anchor maintenance needs to be managed in a way that incentivizes safe anchor replacement and does not risk the removal of climbing routes. This also impedes SAR’s ability to quickly and safely rig systems on existing anchors in the event of a rescue. Prohibiting fixed anchors obstructs appropriate exploration of Wilderness areas. Land managers need to allow climbers to explore Wilderness in a way that permits in-the-moment decisions that are necessary when navigating complex vertical terrain. Prohibiting fixed anchors will threaten America's rich climbing legacy and could erase some of the world's greatest climbing achievements. Climbing management policy needs to protect existing routes from removal. USFS: Restricting the establishment of new routes to "existing climbing opportunities" on non-Wilderness lands is unenforceable. It will create confusion amongst land managers and climbers. Non-Wilderness climbing management policy should maintain opportunities for new anchors unless and until analyses determine climbing should be restricted to protect cultural and natural resources. Many of these policies have been employed at other locations. They have stifled exploration and progression, leaving many anchors to rust away causing safety issues. |
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As always, there is a lot of nuance in the language of these policies and a lot of emotional, reactionary rhetoric that speaks in broad, generalizing terms without fully understanding the precise questions at hand. I've been following this story for many months, have interviewed a range of people on all sides, on and off the record, read and reread stacks of legal documents, and reviewed the technical wording with experts (and still get it slightly wrong sometimes) in order to help people gain clearer perspectives. I hope more people take the time to read my latest short article that explains the situation in plain terms: alpinist.com/newswire/two-p… I would like to highlight the following points: • "Fixed anchor" is a term that includes ANY gear left behind to facilitate an ascent or descent, so it's not just bolts in question under these proposed policies. • The proposed policies would categorize each fixed anchor as an "installation"; the Wilderness Act explicitly forbids installations, which have traditionally been infrastructure such as bridges and fences. • The policies would mandate a review of all fixed anchors on EXISTING routes in Wilderness (and some not in Wilderness, if the USFS policy is adopted). • Advice for writing comments to the NPS and USPS, presented by American Alpine Club and Access Fund representatives during the webinar last Thursday, Jan. 11, as quoted in my story: American Alpine Club Vice President Nina Williams emphasized that in order to move forward, climbers need to build trust with these government agencies. When sharing our comments, we should be sincere and assume the best intentions, rather than lashing out in anger. “There has historically been friction between climbers and the administration,” she said. “But we are at a point where it’s not so much a battle as much as two groups trying to achieve goals that are similar in value but different in execution and different in the trust that we … are … willing to put in each other. How much can climbers trust the federal administration; how much can the administration trust the climbers to self-regulate?” Keith emphasized that Access Fund’s efforts are not a scheme “to find some exception for a new, novel prohibited use.” “A real fundamental piece here is that we need to reserve in-the-moment safety decisions for climbers,” he said. “We need to make sure that climbers have the authority and are not going to be disincentivized to protect themselves. That doesn’t mean that they can abuse these emergency exceptions or other elements…. We should make sure that climbers are the ones that have the judgment in the moment, and the authorization to place safe anchors or replace existing ones.” When submitting comments to the NPS and USFS portals, Keith recommended that people include their personal stories. “Talk about how these new policies would affect your experience,” he said. That will also bring something unique to your comments that the agencies would give serious consideration to.” ### Thanks for reading, Derek Franz, Alpinist magazine |
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I constructed my own comments for this and am sharing them here for others to use. If you use it anywhere besides the official forest service comment portal, please give me credit. -Dan
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Daniel Shankswrote: Dan - no offense but your comment makes no sense. I can't blame you though, because the bureaucratic nature of Wilderness regulations is confusing.
The proposals don't seek to "ban" installations. Installations are already prohibited under the wilderness act, including bridges and signs. Installations and other prohibited uses of Wilderness CAN be authorized as exemptions through an MRA analysis. These proposals seek to classify bolts as installations, the same as bridges and signs, and thus only "allow" through the same process (MRA) that "allows" prohibited bridges and trail signs.
This is actually justification to not allow fixed anchors in wilderness. It should be pointed out that fixed anchors allow for preservation of wilderness character, but "convenience for less experienced users" is the opposite of wilderness character. Hope that helps clarify what is actually going on with these proposals. Its a good time for climbers to dig into the Wilderness regulations and learn how these laws actually work. |
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Thanks to those who have shared their comments here. Mine are below. There are still a few hours left to comment! Even a short comment opposing these impermissible and ill-conceived regulations is better than nothing! *** I am an avid rock, snow, and ice climber, and I appreciate that the NPS’s (“Agency”) draft regulations regarding fixed anchors in Congressionally designated Wilderness acknowledge climbing as a legitimate use of Wilderness. I’ve certainly found that to be the case. From summiting Pingora in the Bridger Wilderness in early morning alpenglow, to clawing my way to the rim of the Black Canyon of the Gunnison with dry, cracked lips and fingertips, Wilderness has been the venue for some of my most profound life experiences. Common to all of those Wilderness climbing experiences is that each fulfilled the aims of the Wilderness Act. On all of my Wilderness climbing outings, I engaged in primitive and unconfined recreation, I left next to no impact, and experienced the kind of self-reliance that is near impossible to find in other settings. Also common to all of my Wilderness climbing experiences, is that every single one depended on fixed anchors/equipment, whether left by those before me—be it a modern bolt, a fixed sling, or a rusty piton predating the Wilderness Act itself—or those placed by me. The Agency’s draft regulations—which render all of those pieces of fixed equipment prohibited by default—raise the question of whether I will ever be able to (legally) experience anything like those prior outings ever again. Thus, while I strongly support protecting designated Wilderness to ensure that there remain areas relatively untouched by humans for generations to come, I strongly oppose the Agency’s draft regulations. My opposition isn’t just based on my own self-interest. I oppose the Agency’s draft regulations because they are based on an interpretation of the Wilderness Act that is impermissibly broad, and because the draft regulations contemplate a regulatory regime that is unenforceable, hopelessly ambiguous, and unfunded. The Agency’s draft regulations will thus inevitably result in arbitrary and capricious action and should be rejected outright. Short of that, the Agency must revise the regulations to provide those on the ground with clear timelines for the evaluation of existing and future/proposed fixed anchors and to clearly define now-ambiguous phrases like “bolt intensive.” To start, the Agency’s definition of “installation” is impermissibly broad. Fixed climbing equipment is nothing like the other items the Wilderness Act explicitly prohibits, and it is absurd to think that Congress intended the word “installation” to cover fixed climbing equipment. In fact, as former Senator Udall has explained, the record is clear that those who actually voted to create designated Wilderness never intended that designation to prohibit the use of fixed climbing equipment. Plus, countless pieces of fixed equipment existed in countless Wilderness areas pre-designation. It is hard to see how those pre-existing pieces of fixed equipment weren’t an impediment enough to prevent an area’s initial designation, but are now significant enough to detract from wilderness character. The arbitrary overbreadth of the Agency’s definition of installation is further illustrated by the fact that it logically encompasses all manner of other human impacts that the Agency has taken no steps to prohibit. Hiker-created footpaths (i.e. off-trail travel), hiker-created river crossings (via log or stone), windbreaks, heck, even micro-plastics from modern outerwear are all man-made and left behind by the installer after they leave wilderness. Thus, under the Agency’s unlawful definition of installation, each of these should be prohibited unless allowed through the MRA process. Of course, it would be absurd to think that drafters of the Wilderness Act meant to prohibit these items from Wilderness when they decided to prohibit “other installations.” The only conclusion, then, is that the Agency’s definition of installation is itself absurd and should be revised to comply with the actual intent of the Wilderness Act. Properly considered, fixed climbing equipment is not an “other installation.” Now, I understand that the response to at least some of my concerns is that the Agency’s regulations do not outright foreclose the use of fixed equipment. Instead, fixed equipment may be permitted if justified by an MRA. But the reality of the Agency’s regulations is that they leave key terms/concepts undefined, provide no firm deadline for review of existing or proposed fixed anchors, and issue an unfunded mandate to Agency staff that is overworked and underpaid. Once again, the Agency’s regulations seem destined for arbitrary and capricious Agency action. Therefore, the Agency should—at bare minimum—revise its draft regulations to: • Define the concept of “bolt intensive.” The definition could categorize routes/pitches with a certain number of pieces of fixed equipment as bolt intensive. For example, “bolt intensive” could mean pitches with more than 12 pieces of fixed equipment per 100 vertical feet (roughly 1 piece per 10 feet, plus anchors). • Require that land managers approve or deny MRA submissions for existing or proposed fixed equipment within a certain number of days of the submission of the MRA application. If the land manager doesn’t approve or deny the MRA submission in that time frame, the MRA should be deemed approved to ensure that administrative backlogs do not unintentionally stifle the exploration and enjoyment of our public lands. • Establish through a system-wide MRA that in all Wilderness managed by the Agency climbers are permitted to place fixed equipment when necessary for retreat from vertical/technical terrain due to hazardous conditions, at the climber’s sole discretion. • Direct land managers to establish a commission made up of climbers and other Wilderness users to evaluate and approve or deny fixed equipment MRA submissions. The Agency should look to organizations like the Action Committee for Eldorado as a guide for how to manage climbing and the use of fixed equipment in a thoughtful, forward looking way. Although these changes still fall short and will unreasonably and unlawfully restrict exploration of all parts of our wilderness areas—vertical spaces included—these changes will at least ensure that the Agency’s land managers aren’t left dealing with vague, arbitrary, and capricious guidance. I’m grateful for the opportunity to comment on the Agency’s proposed regulations (though it is your obligation), and I appreciate the Agency’s acknowledgement that climbing is a legitimate use of Wilderness. But the Agency’s draft regulations remain overbroad and improper and must be rejected, or I fear that I won’t be able to share the views from the pointiest-peaks and the deepest canyons with my children that I’ve enjoyed in my life. I urge you to reconsider these regulations. Sincerely, Andy Ball Denver, CO |
