Comment on FR Doc # N/A

Wilderness 1. Numerical definition of "bolt-intensive" The proposed threshold of more than five bolts within 100 feet is one of the more concerning provisions. Potential unintended consequences include: discouraging appropriate protection spacing, discouraging modern redundant anchors, and treating bolt count as a proxy for wilderness impacts when in reality it is the approach route and terrain the route uses that have a far bigger impact. For example you could have a route that uses no bolts at all, approaches through a riparian zone, and climbs heavily vegetated crack systems, leading to a huge impact on plant and animal life. Whereas you could have a face climb protected primarily with bolts and an approach on durable surfaces, that has a very minimal impact on plant life/animals/wilderness character. Bolt density alone is a poor indicator of wilderness character and this language should be removed. 2. Replacement remains undefined The guidance does not clarify whether replacement includes modernization. This should allow for upgraded hardware, glue-ins (adhesive anchors), modest relocation due to poor rock quality, improved anchor configurations, etc. 3. Little operational guidance Compared with the Forest Service and NPS drafts, BLM provides relatively little direction regarding: replacement authorization, preventive maintenance, volunteer stewardship, modernization, etc. Language should be added to explicitly allow for anchor maintenance and replacement. Non-Wilderness The draft focuses almost entirely on wilderness policy.