Public comment on wilderness area fixed hardware

jake joneswrote:

Same at Tensleep? Did all those holes get repaired? Apologize all you want. The damage is done. Just saying!

I realize that people still have an axe to grind about Ten Sleep, but equating what happened there to fixed gear in the wilderness or vandalization of an archeologically sensitive area is really not helpful or productive, especially when some people are not fully familiar with the details of said incidents.  These incidents are not    the same or even relevant to each other. 

Frank Steinwrote:

I realize that people still have an axe to grind about Ten Sleep, but equating what happened there to fixed gear in the wilderness or vandalization of an archeologically sensitive area is really not helpful or productive, especially when some people are not fully familiar with the details of said incidents.  These incidents are not    the same or even relevant to each other. 

https://www.facebook.com/reel/753881069534223  Do we need another bolt here? Self police this? Wilderness is full of unnecessary shit like this.

jake joneswrote:

https://www.facebook.com/reel/753881069534223  Do we need another bolt here? Self police this? Wilderness is full of unnecessary shit like this.

Your link is broken. I have no idea what you are talking about. 

jake joneswrote:

https://www.facebook.com/reel/753881069534223  Do we need another bolt here? Self police this? Wilderness is full of unnecessary shit like this.

Jake, Deven is an extremely competent climber and this video has no context. I presume he is hand drilling a bolt for an anchor to rappel. I think 99% of climbers would see this as obvious. 

Also, this is a realllllly tired point in this thread- but if he is hand drilling in Indian Creek, there is not "W"ilderness there! 

https://umontana.maps.arcgis.com/apps/webappviewer/index.html?id=a415bca07f0a4bee9f0e894b0db5c3b6

I remember that time the Access Fund advocated restricting access to Bear Ears. Chickens coming home to roost? 

Brian Princewrote:

I'm trying to write one for the NPS and it's pretty tricky because it just references the RM41, which is pretty clear in its definitions (i.e. of installations). I'm not sure how to argue around that. I like Tim Dolan's comment from the previous page that focuses on the historical precedent. But this would basically be saying the already "published" RM41 has to be thrown out as well.

The existing NPS policy does NOT call out individual bolts as "installations."  It clearly is concerned only with cumulative impacts of multiple bolts. nps.gov/subjects/policy/upl…

Director's Order 41  of 2013  Section 7.2 includes the following:  

" The occasional placement of a fixed anchor for belay, rappel, or protection purposes does not necessarily impair the future enjoyment of wilderness or violate the Wilderness Act. However, climbing practices with the least negative impact on wilderness resources and character will always be the preferred choice.
The establishment of bolt-intensive face climbs is considered incompatible with wilderness preservation and management due to the concentration of human activity which they support, and the types and levels of impacts associated with such routes. "

DO41 also says that "climbing management strategies will be included as part of the park's Wilderness Stewardship Plan."    This means that each Wilderness has already had 10 years to make their plan on anchor management.  Yet many places have not yet done so.  There are 2 reasons.  

1. They don't believe they have a significant issue, and therefore no need for a new bureaucracy.  

2. They don't have the resources to formulate a plan.  A better less sweeping plan would be to just list which crags they think are impacted, and require a permit only for those crags.   By the same logic of inadequate resources, they are not prepared to do lots of MRA analysis, which under the new proposal would be required even for a single anchor at a NON-impacted crag.  So their general response will be to DENY all permits, pending receipt of funds to set up the new bureaucracy.

-
reference DO41  -  -  7.2 Climbing 

For the purpose of this Order, climbing is defined to include rock climbing, snow and ice climbing, mountaineering, canyoneering, and caving, where climbing equipment, such as ropes and fixed or removable anchors, is generally used to support an ascent or descent. The NPS recognizes that climbing is a legitimate and appropriate use of wilderness. However, any climbing use or related activity must be restricted or prohibited when its occurrence, continuation, or expansion would result in unacceptable impacts to wilderness resources or character, or interfere significantly with the experience of other park visitors. 

If climbing activities occur in wilderness, climbing management strategies will be included as part of the park's Wilderness Stewardship Plan, or other activity-level plan. Wilderness parks with climbing use will exchange information on best practices, work together on servicewide implementation, and communicate with stakeholders and wilderness users. Wilderness climbing education and impact monitoring will be important components in climbing management programs. It is recognized that the use of removable anchors may reduce, but does not in every case completely eliminate, the need for fixed anchors. The occasional placement of a fixed anchor for belay, rappel, or protection purposes does not necessarily impair the future enjoyment of wilderness or violate the Wilderness Act. However, climbing practices with the least negative impact on wilderness resources and character will always be the preferred choice. 

The establishment of bolt-intensive face climbs is considered incompatible with wilderness preservation and management due to the concentration of human activity which they support, and the types and levels of impacts associated with such routes. Climbing management strategies will address ways to control, and in some cases reduce, the number of fixed anchors to protect the park’s wilderness resources or to preserve the “untrammeled,” “undeveloped,” and “outstanding opportunities for solitude” qualities of the park’s wilderness character. 

Fixed anchors or fixed equipment should be rare in wilderness. Authorization will be required for the placement of new fixed anchors or fixed equipment. Authorization may be required for the replacement or removal of existing fixed anchors or fixed equipment. The authorization process to be followed will be established at the park level and will be based on a consideration of resource issues (including the wilderness resource) and recreation opportunities. Authorization may be issued programmatically within the Wilderness Stewardship Plan or other 15   activity-level plan, or specifically on a case-by-case basis, such as through a permit system. Prior to the completion of the park’s Wilderness Stewardship Plan or other activity-level plan, the park superintendent may approve new fixed anchors or fixed equipment on a case-by-case basis.

...

Yet again, because the park service said fixed anchors are allowed doesn't mean they aren't prohibited installations. 

In fact, since the policy mentions that the Wilderness Act has a lot to say about fixed anchors, it implies that fixed anchors are installations. If fixed anchors weren't installations, then the Wilderness Act would be silent on them. 

And ski bindings are arguably mechanized equipment, similar to bikes, but skis are allowed while bicycles are not.

https://wildernesswatch.salsalabs.org/nps-fs-climbing-regulations

Wilderness Watch is leaning in… If you check out the USFS reading room comment page it’s absolutely inundated with this copy pasta. Really drives home the point to make comments personal! :) 

Yes, but don’t simply copy & paste from anyone’s talking points…that will get your comments tossed. At least try to tweak them so they look somewhat unique and personal.

Holy shit, I'm looking at the USFS reading room... >20 pages of copy-pasta comments from Wilderness Watch, all posted today and the vast majority after 9pm. That's some 400-500 or so people who suddenly decided to post almost identical comments? I'm not one for conspiracy theories, but that's mighty fishy.

Big Redwrote:

Holy shit, I'm looking at the USFS reading room... >20 pages of copy-pasta comments from Wilderness Watch, all posted today and the vast majority after 9pm. That's some 400-500 or so people who suddenly decided to post almost identical comments? I'm not one for conspiracy theories, but that's mighty fishy.

Bots? I wonder if they check/filter those out. 

ErikaNWwrote:

Bots? I wonder if they check/filter those out. 

Sadly the feds don’t have a great record of knowing how to deal with spam/bot comments. Maybe they are getting better these days. They should, 100% be ignored, and only tallied as a last resort.

https://www.wired.com/story/bots-form-letters-humans-fcc-net-neutrality-comments/

I have a strong feeling such obvious bot dupes get dumped when comments are reviewed, but on the other hand, two can play at that game….

Wow, I also just downloaded a page it was nearly all WW copy paste. Over 9 to 1 against climbers. 

Searching their bullet points lead to this page: https://wildernesswatch.salsalabs.org/nps-fs-climbing-regulations

Which is being hosted from this company's platform, that for a fee, will 'help your cause': https://www.bonterratech.com/ 

I have a hard time believing that an organization made up of a bunch of 50+ year old retired water scientists with a very meager social media presence is totally STOMPING climber numbers without bots.

Is it just my imagination or is the WW logo a picture of a bear f@cking a mountain from behind?

J Ewrote:

Yet again, because the park service said fixed anchors are allowed doesn't mean they aren't prohibited installations. 

In fact, since the policy mentions that the Wilderness Act has a lot to say about fixed anchors, it implies that fixed anchors are installations. If fixed anchors weren't installations, then the Wilderness Act would be silent on them. 

I'm not getting your reasoning here. It was my understanding that the history went something like this:

- The Wilderness Act says installations are prohibited. Doesn't define installations.

- 2013 NPS Reference Manual 41 ( AKA Director's Order 41?) defines installations as anything manmade and left behind. Says fixed anchors are ok if limited. 

- Current draft reference manual 41 says, well, fixed anchors are manmade and left behind, so they should actually be prohibited. 

In my mind, there is still room to argue that fixed anchors are not installations, though I'm not sure exactly how. 

tom donnelly wrote: The existing NPS policy does NOT call out individual bolts as "installations."

I know, but the current proposal does. And that's what we are supposed to be commenting on. I like your points on the added bureaucracy, and I'll include similar ones in my comment, but I'm not sure that's enough. 

As far as the WW bots go, can't one person submit multiple comments? Or do you have to have a unique email address each time?

I hope they toss the bot comments.  This bot thought we're trying to pass the Wilderness Act

Brian Princewrote:

I'm not getting your reasoning here. It was my understanding that the history went something like this:

- The Wilderness Act says installations are prohibited. Doesn't define installations.

- 2013 NPS Reference Manual 41 ( AKA Director's Order 41?) defines installations as anything manmade and left behind. Says fixed anchors are ok if limited. 

- Current draft reference manual 41 says, well, fixed anchors are manmade and left behind, so they should actually be prohibited. 

In my mind, there is still room to argue that fixed anchors are not installations, though I'm not sure exactly how. 

Its going to take a lawsuit that challenges the NPS's definition/interpretation of an installation.  Currently, anything that the NPS is going to "approve" being left in wilderness is going to be classified as an installation.  JE argues that we should accept this and hope to shape the way they approve of our leaving of "installations" via MRAs.  Don't be JE.  Oppose these proposals because if we accept classifying anchors as installations then it will be a lot more difficult to undo that.  

Derek Bwrote:

Its going to take a lawsuit that challenges the NPS's definition/interpretation of an installation.  Currently, anything that the NPS is going to "approve" being left in wilderness is going to be classified as an installation.  JE argues that we should accept this and hope to shape the way they approve of our leaving of "installations" via MRAs.  Don't be JE.  Oppose these proposals because if we accept classifying anchors as installations then it will be a lot more difficult to undo that.  

I'm with you, I'm just trying to figure out how to do that, i.e. what to put in my comment. I guess I'm overthinking it and I'll just "oppose." I don't know, a lot of those types of comments I read just seemed a little shallow to me.