American Alpine Club response to National Park Service Director’s Order 41 Section 7.2 on Climbing in Wilderness
The American Alpine Club applauds the release of guidance from the National Park Service Director on Wilderness Stewardship. This is long-awaited guidance that can provide much needed clarity across the Parks. [Download the full text of the Director's Order:NPS-Bolting-DO41-external1.pdf]
The guidance on climbing is largely consistent with the dialog the American Alpine Club (AAC) has been having with the National Park Service (NPS) for over a decade.
In general, the AAC agrees that bolts should be rare in designated Wilderness, but the National Park Service should acknowledge that climbing is a legitimate and appropriate activity in Wilderness and that fixed anchors are often a necessary tool for Wilderness climbing.
The AAC believes that Director’s Order #41 (DO #41) needs a few significant amendments. The AAC respectfully requests the following amendments be made to DO #41 so that we can fully support it.
1. Authorization for fixed anchor placement: We believe that individual parks are best suited to determine whether prior authorization is to be required for new fixed anchor placements or not. We believe that climbing management plans (CMPs) created with the specific terrain, use and climbing character of each Wilderness is the best way to deal with potential climbing impacts, including bolts and other fixed anchors. We support policies that allow climbers to replace and maintain fixed anchors for the future safety of other climbers. Requesting that the authorization be considered in a CMP for each Park will allow Parks to address their own unique management challenges on their own schedule, allocate resources to the most pressing Wilderness management needs, and will eliminate the possibility of a de facto ban on new fixed anchors in parks where such a prohibition may be unnecessary.
Any requirement for new fixed anchor authorizations should arise only through and after adoption of a climbing management plan that includes a process for authorizations. We assume that this is the proper reading of the sentence “The requirements for authorization, and the process to be followed, will be effected through an approved climbing management plan.” We support language stating that “authorizations may be required for the placement of new fixed anchors” but we oppose the language that requires prior authorization in every case.
2. No Interim Ban. The NPS should clarify that local parks cannot use a final DO #41 policy to restrict new anchors until a CMP and associated fixed anchor authorization process, if necessary, is finalized, implemented, and resourced (administrative staff available to process authorizations). There have been cases of CMPs taking multiple years (some still unresolved) and the NPS should clarify that authorization requirements will be imposed only through and after a local CMP is established to avoid an interim ban on new fixed anchor placements. If prior authorization is required as of the final adoption of Director’s Order #41, but authorization cannot be obtained until there is a CMP, then this too must be clarified. We oppose the adoption of a final Director’s Order #41 that creates interim fixed anchor bans in all National Park Service Wilderness areas.
3. Climbing Management Plan Details. If fixed anchor authorizations are to be required in a CMP, permission should be granted programmatically for specific park zones or entire parks. We support case-by-case permits in sensitive areas. We believe that most parks developing a CMP and fixed anchor authorization process will conclude that it is unnecessary, burdensome, excessive, and disproportionate to require authorizations for individual routes. Section 7.2 or its associated NPS reference manual should clearly outline the options that authorizations may take.
Local CMPs may distinguish between different forms of fixed anchors, such as authorizations for different types of fixed anchors (e.g., bolts or pitons) or different needs (e.g., belays, rappels, or anchors for ascent). The policy should permit these options in local CMPs. Park planners should consult with local climbing communities on climbing management plans, in particular on boundary determinations for programmatic fixed anchor authorizations, and case-by-case fixed anchor permits for sensitive areas.
4.“Sport Climbing” Language Unhelpful and Ambiguous. The AAC believes that bolts should be rare in Wilderness and we support limits on bolt-intensive climbing in Wilderness areas. However, the draft language is ill-served by the inclusion of the debatable and subjective term “sport climbing.” Most people can agree on and identify bolt-intensive climbs that cause a “concentration of human activity.” However, “sport climbing” is defined in many different ways by different people. The final policy should provide some allowance for “traditional” face climbs (such as are found at Joshua Tree) that rely predominantly on fixed anchors for protection but where those fixed anchors are rare, limited in number and do not lead to high concentrations of human activity or otherwise degrade Wilderness value.