Comment on FR Doc # N/A

As a rock climber who depends on well-maintained fixed anchors to climb safely on public lands, I appreciate the opportunity to comment on the proposed revisions to BLM Manual 6340, but I have several concerns. My greatest concern is the numerical definition of "bolt-intensive" as more than five bolts within 100 feet. Bolt density alone is a poor proxy for wilderness impact. In practice, the approach route and terrain a climb travels through matter far more than how many bolts it uses. A route with no bolts at all may approach through a riparian zone and ascend heavily vegetated crack systems, causing significant impact to plant and animal life. Meanwhile, a bolt-protected face climb reached by durable surfaces may have minimal impact on vegetation, wildlife, and wilderness character. A fixed numerical threshold also risks discouraging appropriate protection spacing and modern redundant anchors, penalizing exactly the practices that keep climbers safe. This language should be removed. Second, "replacement" is left undefined, with no indication of whether it includes modernization. Modern anchor replacement rarely means installing identical hardware. The guidance should explicitly allow upgraded hardware, adhesive (glue-in) anchors, modest relocation where rock quality is poor, and improved anchor configurations consistent with accepted best practices. Third, compared with the Forest Service and Park Service drafts, this guidance offers little operational direction on replacement authorization, preventive maintenance, volunteer stewardship, or modernization. Language should be added to explicitly authorize ongoing anchor maintenance and replacement so that qualified climbers can keep hardware safe without ambiguity. I support responsible climbing management in Wilderness, but this guidance should provide clear authorization for the anchor maintenance that keeps climbers safe rather than relying on a bolt-count metric that poorly reflects actual wilderness impact.