What NPS and USFS have proposed, and what you can do about it.
On November 17, 2023, the National Park Service and US Forest Service issued draft climbing management guidance for public comment. The public comment period is 60 days. If implemented, the guidance would create significant safety issues, threaten world-class climbing routes (many were established prior to wilderness designations), obstruct appropriate wilderness exploration, and burden land managers and climbers with unnecessary red tape.
As climbers, fixed anchors are essential pieces of our safety system that allow us to safely and sustainably access vertical terrain. Without fixed anchors, many of the wildest and most inspiring places in America would become inaccessible to the public.
What does the proposed NPS and USFS guidance say?
The National Park Service draft guidance for managing wilderness climbing is very similar to the US Forest Service draft guidance. A summary follows:
Fixed anchors are considered prohibited “installations” in wilderness, a new interpretation of the Wilderness Act. The new policy creates a prohibition standard for authorizing existing, new, and replacement wilderness climbing anchors, going against nearly 60 years of policy and practice.
New and replacement fixed anchors may only be allowed after a Minimum Requirements Analysis (MRA) for prohibited uses. This new exception process will clearly limit fixed anchor authorizations and restrict the ability of climbers to make in-the-moment safety decisions. Every MRA decision document will open up the agency to litigation and the process adds an unnecessary bureaucratic step for managing sustainable climbing.
Existing wilderness fixed anchors are de facto prohibited but may be retained if the agency finds funding and resources to conduct MRAs; however, existing wilderness fixed anchors may be removed if they are determined to no longer be “the minimum necessary to facilitate primitive or unconfined recreation or otherwise preserve wilderness character.” Iconic, longstanding climbing routes may be removed at places like Joshua Tree, Rocky Mountain, Zion, and Yosemite National Parks.
The proposed guidance presents a serious safety hazard. The policy to restrict or prohibit the placement or replacement of fixed anchors unless specifically authorized through MRA determinations takes critical personal safety decisions away from climbers. The MRA requirement for fixed anchor replacement is unprecedented and would result in unsafe conditions because timely, routine fixed anchor maintenance would be obstructed or prohibited by unnecessary red tape. Traditionally, land managers do not maintain fixed anchors, whereas climbers are responsible for assessing and replacing fixed anchors during climbing activities.
Land agencies do not have the resources to implement the unfunded mandate. The guidance requires that land managers must develop climbing management plans (CMPs), or other relevant plans, for each federal land unit. There are currently very few CMPs in national parks and forests, and the agencies lack the funding and resources (and often expertise) to complete such plans. Understaffed and underfunded public land managers would be responsible for executing complex and resource-intensive requirements when they already have the authority to effectively manage climbing in wilderness.
The National Park Service draft guidance differs from the US Forest Service’s draft guidance (or provides more specificity) in the following ways:
Park planning documents may make programmatic decisions about fixed anchor authorizations or restrictions at the park-wide level or within designated park management zones or units. Alternatively, the required MRA process may be deferred to individual anchor applications under a plan framework. Programmatic MRAs are only to be done after a park-wide CMP or other planning document is finalized.
NPS MRA process requires elevated standards for what is the “minimum necessary,” such as whether climbing is acknowledged in enabling laws or park planning and policy documents; history and ethics will also be considered as will how recreational climbing preserves the qualities of wilderness character.
The NPS draft guidance states, “It is important to note that recreational climbing is an appropriate activity in NPS wilderness that connects people with the land, builds self-reliance, presents challenge, and requires skill. These experiential values can provide opportunities for primitive and unconfined recreation and therefore be necessary to the administration of the wilderness area.”
In the absence of a formal park plan addressing wilderness climbing, park superintendents may evaluate individual requests to place or replace fixed anchors through an interim process, but individual approvals are still subject to MRAs. Park superintendents may also defer any wilderness climbing anchor decisions until a formal planning process is completed.
Existing fixed anchors may continue to be used but are subject to an MRA and may subsequently be removed. Anchor replacements require an MRA although a park-specific planning process may provide more direction regarding anchor replacements. MRA-approved existing anchors may be replaced without a new MRA, unless wilderness character conditions change.
All new or replacement anchors that are MRA-approved (even for programmatic MRAs) still require a very detailed special-use permit with requirements inconsistent with realistic, in-the-moment backcountry exploration. It is unclear whether permits must be issued where MRAs have determined that specific fixed anchors are the minimum necessary and the minimum tool.
The US Forest Service addresses non-wilderness climbing management (NPS does not):
New fixed anchors and replacement of existing fixed anchors in non-wilderness would be restricted. The policy would restrict the placement and replacement of fixed anchors to established “climbing opportunities” and would limit new anchor approvals only for new climbing opportunities that have been evaluated for natural and cultural resource impacts. “Climbing opportunity” is poorly defined as, “A user-created or primarily user-created dispersed recreation area on NFS lands with no, minimal, or limited Forest Service investment or amenities where climbing may be performed.” This standard is highly subjective and will be nearly impossible to manage and enforce.
Existing non-wilderness fixed anchors and fixed equipment may be used without restriction when consistent with the applicable climbing management plan, except in areas closed to climbing. Nearly 30% of America’s climbing (about 12,000 discrete climbing opportunities) is located on US Forest Lands, but only a few USFS climbing areas have an “applicable climbing management plan.” It is unclear whether this new standard also applies to wilderness anchors as well.
What is Congress doing about the NPS and USFS proposals?
Congress is concerned about the NPS and USFS because our elected lawmakers do not want climbing unnecessarily restricted or prohibited. The House of Representatives and the Senate are moving forward legislation that would protect wilderness climbing and allow for judicious placement and replacement of fixed anchors. The House bill, the Protecting America’s Rock Climbing Act, was packaged with a wide range of recreation and public lands bills to create the EXPLORE Act. Professional rock climber and environmental advocate Sasha DiGiulian testified at a November 30 hearing on the EXPLORE Act. A complementary package of recreation bills on the Senate side, the America’s Outdoor Recreation Act, includes similar climbing provisions that would maintain the status quo for climbing in wilderness. Congressional intent is clear as the Congress has unanimously supported the climbing legislation and intends to stand behind climbers.
Former Senator Udall recently wrote an opinion piece that noted, “As the primary sponsor of the Rocky Mountain National Park Wilderness and Indian Peaks Wilderness Expansion Act, I want to be absolutely clear: Nothing in those bills was intended to restrict sustainable and appropriate Wilderness climbing practices or prohibit the judicious and conditional placement of fixed anchors—many of which existed before the bills’ passage. I used fixed anchors to climb in these areas, and I want future climbers to safely experience profound adventures and thereby become Wilderness advocates themselves.”
Which Wilderness areas would be impacted by these proposals?
We worked with the Outdoor Alliance GIS Lab to highlight Wilderness climbing areas on NPS and USFS land around the country. Our analysis found that the proposals would impact approximately 65,000 climbs across almost 1,000 climbing areas in 28 states. Those states include Alaska, Alabama, Arkansas, Arizona, California, Colorado, Georgia, Idaho, Illinois, Kentucky, Maine, Michigan, Minnesota, Missouri, Montana, North Carolina, New Hampshire, New Mexico, Nevada, Oregon, South Dakota, Utah, Virginia, Vermont, Washington, Wisconsin, West Virginia, and Wyoming.
How can you help protect Wilderness climbing?
We need your help to stop the National Park Service and U.S. Forest Service from implementing a new policy that could erase America’s most iconic climbing routes and put our safety at risk. Submit your comments using the link below.
The second thing you can do is to ask your member of Congress to cosponsor the Protecting America’s Rock Climbing (PARC) Act, which protects sustainable Wilderness climbing access. The bill was recently included in the bipartisan Expanding Public Lands Outdoor Recreation Experiences (EXPLORE) Act, which is moving quickly through the House of Representatives. A strong show of support for the PARC Act will ensure that the bill is included in the final EXPLORE Act recreation package when it heads to the president’s desk.