Stop weak climbing rules from harming national park wilderness

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.
• The guidance authorizes superintendents to approve new fixed anchors on a case-by-case basis prior to completing formal Wilderness Stewardship Plans (Section 2, Management of Fixed Anchors and Fixed Equipment Prior to a Formal Plan), yet provides no standards, criteria, or process to guide these ad hoc decisions. The document states parks may rely on 'interim guidance or strategy' but does not define what constitutes adequate interim guidance or how superintendents should evaluate impacts without a comprehensive plan. The agency should establish specific decision criteria and environmental review standards for interim authorizations to ensure consistency and compliance with the Wilderness Act.
• The guidance exempts new fixed anchors from requiring a Minimum Requirements Analysis (Section 3, Minimum Requirements Analysis and Table 1), reasoning that fixed anchors are 'not considered installations' under the Wilderness Act. However, the document elsewhere acknowledges that climbing has 'impacts on wilderness resources and values' and that parks must address 'cumulative impacts' and evaluate 'effects of climbing on wilderness character.' This creates a logical gap: if new anchors contribute to climbing impacts that require evaluation under the Wilderness Act, why do they not require analysis of whether they meet the minimum necessary standard? The agency should justify why new fixed anchor placement does not require MRA documentation of necessity and least-impact analysis.
• The document states that 'bolt-intensive face climbs' are 'considered incompatible with wilderness preservation and management' due to 'concentration of human activity' and 'types and levels of impacts' (Director's Order 41, Section 7.2), yet the guidance provides no mechanism for parks to evaluate whether a proposed new fixed anchor will contribute to bolt-intensive development or prevent it. The authorization procedure (Section 4) requires only specific details about the applicant and location, not analysis of whether the anchor is part of a broader pattern that would create an incompatible bolt-intensive climb. The agency should require applicants and parks to evaluate cumulative bolt density and concentration of activity before authorizing new anchors.
• The guidance allows climbers to place fixed anchors during 'exigent circumstances' without prior authorization, requiring only that they be reported 'as soon as is practicable after the climber exits the wilderness' (Section 2, Exigent Circumstances). The document defines exigent circumstances broadly to include a climber encountering 'a faulty fixed anchor' or 'an objective hazard' (e.g., rock fall, extreme weather). This standard is highly subjective and creates a loophole: climbers have unilateral discretion to determine when their safety requires new anchors, and reporting occurs only after the fact with minimal NPS oversight. The agency should require advance authorization for non-trivial exigent anchor placements or establish objective criteria that distinguish genuine emergencies from discretionary climbing decisions.