Black Canyon CMP - Draft Language for Comments to NPS

The following language was developed by the Access Fund to assist advocates in responding to the National Park Service's proposed Climbing Management Provisions within the Wilderness and Backcountry Management Plan/Environmental Assessment for the Black Canyon in Gunnison National Park. We encourage advocates to customize their response with their own thoughts and experiences in the Black.

Bullet Points

  • Reconsider annual limit of 15 new fixed anchors in the Black’s Primitive Zone and instead follow the adaptive management used in other National Parks.
  • Provide better boundary description between the Black’s Primitive and Pristine Zones.
  • Add at least one climber to the Park’s interdisciplinary committee to increase the committee’s effectiveness, communication, and to help foster a working relationship with Black Canyon climbers.
  • Reconsider banning the use of rock climbing guides in the Black

Letter Draft

My name is ___ and I have been climbing in the Black Canyon since ___. The Black Canyon of the Gunnison offers some of the best and most adventurous rock climbing in the country, and attracts climbers internationally. The proposed climbing provisions in this draft Wilderness and Backcountry Management Plan are generally an excellent compromise between resource protection and the unique wilderness climbing found only in the Black Canyon. I applaud your management approach which would closely follows the climbing provisions in the draft NPS Director’s Order #41. However, there are a few specific areas where I think this plan can be improved.

First, the NPS should reconsider its proposed annual limit of 15 new fixed anchors within the Black Canyon’s Primitive Zone. Park planners should instead follow the adaptive management practices used in other National Parks such as Zion and Rocky Mountain for monitoring impacts from fixed anchors, if any. This Plan provides no data to demonstrate impacts from fixed anchors and thus the numerical limit of 15 is unjustified and arbitrary. Unfortunately, the maps provided in the draft Plan are of very low quality so it is also nearly impossible to identify where exactly the boundaries lie between the various zones which would have different fixed anchor policies.

Secondly, the Park should consider adding at least one climber to the interdisciplinary committee (possibly from a local climber organization) to increase the committee’s effectiveness, communication, and to help foster a working relationship with the climbers most concerned with and knowledgeable about climbing in Black Canyon.

Finally, the proposed guiding ban in the Black—justified because it does not support a “visitor experience that is challenging, self-reliant, and adventurous”—is both unnecessary and uninformed. As anyone knows who has climb here, climbing in the Black is always challenging, adventurous, and requires a high degree of self-reliance whether guided or not.

Thank you again for designing a progressive management plan for climbing and wilderness protection that reflects much of the best management practices used in other parks and which are recognized at the national level in the draft Director’s Order #41. With a few minor changes, this plan will be much more effective in providing a unique wilderness experience while also ensuring critical resource protection.