Comment on FR Doc # N/A

To Whom It May Concern, I appreciate the Bureau of Land Management's efforts to implement the EXPLORE Act and provide national guidance for climbing in designated wilderness. I support the goal of protecting wilderness character while recognizing recreational climbing as an appropriate use of public lands. I respectfully recommend several revisions to improve the proposed guidance. As a professional climbing guide and an experienced traditional climber who has established and maintained climbing routes on public lands, I have spent years evaluating how climbing interacts with wilderness resources. In my experience, the proposed numerical definition of "bolt-intensive" is one of the most concerning aspects of the draft. A threshold of more than five bolts within one hundred feet assumes that bolt density is a meaningful measure of wilderness impact. In practice, it often is not. Wilderness impacts are far more strongly influenced by where climbers travel, the durability of the approach, vegetation, wildlife habitat, erosion potential, and the character of the terrain than by the number of bolts on a route. For example, a traditional crack climb with no bolts may require repeated travel through fragile riparian vegetation, heavily vegetated crack systems, or unstable slopes, resulting in substantially greater ecological impacts than a face climb protected primarily by bolts that follows durable rock from trail to summit. Likewise, modern redundant rappel anchors may contain more hardware than older systems while actually reducing impacts by preventing damage to trees, minimizing the proliferation of sling anchors, and concentrating descent traffic along a single sustainable route. A numerical bolt threshold may also create unintended safety consequences by discouraging appropriate protection spacing or discouraging modern redundant anchor systems. Climbers should be encouraged to use the minimum hardware necessary while still following accepted safety practices, rather than designing routes to satisfy an arbitrary numerical limit. I also encourage the BLM to clarify that "replacement" includes modernization using current engineering and safety best practices. Responsible anchor replacement often involves replacing obsolete hardware with modern stainless-steel hardware, installing adhesive anchors where appropriate, making modest relocations into sound rock when the original placement has deteriorated, or improving outdated anchor configurations. These actions preserve existing routes—they do not constitute new development. Finally, the draft would benefit from substantially more operational guidance regarding fixed-anchor stewardship. Unlike the Forest Service and National Park Service proposals, the current draft provides relatively little direction regarding routine replacement authorization, preventive maintenance, volunteer stewardship, or modernization. The final guidance should explicitly recognize that routine maintenance and replacement of existing fixed anchors are appropriate stewardship activities and should broadly authorize qualified volunteers to perform this work before hardware becomes hazardous. The climbing community has a long history of partnering with public land managers to maintain safe, sustainable climbing resources while minimizing impacts on wilderness. Clear guidance that recognizes both modern safety practices and volunteer stewardship will better fulfill the intent of the EXPLORE Act than rigid numerical standards that may unintentionally discourage good environmental and safety practices. I respectfully encourage the Bureau of Land Management to: * Remove the proposed numerical definition of "bolt-intensive" and instead evaluate wilderness impacts using a holistic, site-specific assessment. * Clarify that replacement includes modernization using current engineering and safety best practices. * Explicitly authorize routine maintenance and preventive replacement of existing fixed anchors. * Recognize volunteer anchor replacement and stewardship as appropriate management tools that help preserve both public safety and wilderness character. Thank you for your consideration of these comments. Skyeler Congdon