Set the terms for climbing anchors in refuge wilderness
Wilderness Administration and Resource Stewardship; Managing Climbing Activities in Wilderness
Fish and Wildlife Service· National Wildlife Refuge System, National Fish Hatchery SystemFederal Register 2026-11970 ↗
Congress said climbing belongs in wilderness on appropriate terms. This docket is where the terms get written.
What’s at risk
The Service is writing the rules for fixed climbing anchors (bolts and pitons, permanent installations) in every wilderness area in the National Wildlife Refuge System. Congress directed that climbing be recognized as an appropriate use, but the terms and conditions, the part that decides what wilderness character survives, are set in exactly this comment period.
If this goes through
If the final guidance requires minimum-requirements review and real monitoring for permanent anchors, climbing and wilderness character can coexist. If anchors are categorically exempted, the first permanent-installation exception to refuge wilderness policy gets written with no analysis behind it.
Our plain-English read of the official notice ↗. Check it against the agency’s own words below.
3 holes in the agency’s own analysis
What the public could have raised, from the agency’s own document
- I oppose this action as proposed, and I ask the agency to weigh the specific harms below.
- Section 122 of the EXPLORE Act (Protecting America’s Rock Climbing) directs that guidance "shall recognize that recreational climbing (including the use, placement, and maintenance of fixed anchors) is an appropriate use" in wilderness "if undertaken in accordance with the Wilderness Act and other applicable laws... and subject to appropriate terms and conditions to be determined by the Secretary." The terms and conditions are what this comment period decides. Ask the Service to require a minimum-requirements analysis for new permanent fixed anchors rather than any categorical exemption, so the guidance implements the Act within the Wilderness Act rather than around it.
- The draft does not create a standalone climbing chapter. It amends the foundations of refuge wilderness policy itself: Service Manual chapter 610 FW 1, General Overview of Wilderness Stewardship Policy, and 610 FW 2, Wilderness Administration and Resource Stewardship. Ask the Service to confirm on the record that no change made for climbing weakens the general stewardship standards those chapters set for every other use in refuge wilderness.
- Ask the Service to analyze the cumulative effects of fixed-anchor placement and maintenance across refuge wilderness areas over time, and to commit to monitoring with a stated baseline, so that any allowance for occasional placement has a measurable meaning an area manager can enforce.
- Say something only you can say. The law requires the agency to consider and respond to substantive comments, and specifics are what make a comment substantive.
In the agency’s own words
The U.S. Fish and Wildlife Service (Service) announces the availability of a draft national guidance memorandum and proposed revisions for two Service Manual chapters to fulfill the direction in Section 122 of the Expanding Public Lands Outdoor Recreation Experiences (EXPLORE) Act governing the management of climbing activities in wilderness areas in the National Wildlife Refuge System (NWRS) and, where applicable, the National Fish Hatchery System (NFHS). The draft guidance memorandum and Service Manual chapter amendments clarify our wilderness policy by adding explicit policy elements related to climbing routes…
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