Comment on FR Doc # N/A

I am a climber who regularly climbs on BLM managed lands in the West, including the Sierra Nevada in California, the Gore Range in Colorado, Canyonlands National Park in Utah, the Wind River Range in Wyoming, and many other areas in these states. I have read the full draft text. I support the recognition in sections 1.6.B.2.j and 1.6.C.13.f that recreational climbing and fixed anchors are appropriate wilderness uses, the exclusion of fixed anchors from the definition of installation, the presumption in f.ii of continued use and one for one replacement on routes existing as of January 4, 2025, and the allowance in f.iii for new anchors without prior authorization, including protection anchors linking terrain protectable by temporary gear. This framework is a major improvement over the 2023 proposals. I ask for the following revisions. First, revise casual use criterion i(c). The standard of five or fewer anchors with not less than 100 feet separation from other human placed objects is ambiguous and unworkable as written. It does not specify whether the count applies per pitch, per route, or per area, and human placed object is undefined, so a two bolt rappel station placed within 100 feet of an existing station, a cairn, or the route's own anchors would arguably fail the criterion and trigger a 43 CFR 2920 authorization for routine safety infrastructure. Numeric caps have no basis in resource protection, and the Wilderness Act's prohibition on motorized equipment already limits anchor density far more effectively: hand drilling a single bolt takes half an hour or more of strenuous work after a long approach, which has kept wilderness bolt density low for sixty years. Please remove the numeric standard, or at minimum clarify that the count applies per pitch, exclude belay and rappel stations from the count, exclude the anchors of the route itself from the separation trigger, and define human placed object. Second, revise criterion i(d). No climber can certify that an anchor will have no effect on three qualities of wilderness character; every human act in wilderness has some effect. Please replace no effect with a negligible effect or de minimis standard consistent with the treatment of fixed anchors as casual use elsewhere in the draft. Third, strike or narrow the final sentence of f.iii stating that routes dependent on intensive fixed anchor use or attracting concentrated human activity are generally incompatible with wilderness preservation. Intensive and concentrated are undefined and invite arbitrary, inconsistent application across field offices. If the intent is to discourage convenience bolting where clean protection is available, criterion i(e) already accomplishes that. If a general compatibility statement is retained, please define the terms and clarify that the sentence does not create a separate prohibition beyond the casual use criteria. Fourth, define the authorization process in f.v. An authorization process appropriately tailored to the proposal is unbounded and, combined with the ambiguities above, functions as a de facto ban on new route development, since field offices without climbing capacity will default to denial or delay. Please specify a preferred pathway ranging from programmatic authorization through Climbing Management Plans developed with local climbing organizations to case by case review for genuinely novel situations, and set timelines and cost limits. Fifth, in f.iv, confirm the 10 day notification is truly voluntary, that failure to notify cannot convert otherwise compliant casual use into unauthorized use, and that requests for additional information will not operate as a de facto permit requirement. Sixth, revise f.vii so that anchors placed in emergencies may remain when they serve ongoing safety functions, rather than defaulting to mandatory removal. An anchor placed to retreat safely from a storm will serve the next party facing the same conditions, and its removal creates new rock scarring for no wilderness benefit. Seventh, I support the glossary's definition of fixed anchor to include slings and its clean separation from fixed equipment. Please harmonize these definitions with the NPS, FWS, and USFS drafts so climbers face one consistent standard across agency boundaries. Thank you for producing a substantially workable framework and for treating climbers as partners in stewardship. Your work to support recreation and climbing is much appreciated!