Comment from Porter, Gavin

I support the release of a national framework for recreational climbing and recognize the effort to provide consistency in how climbing is managed across public lands. This is a meaningful step forward. That said, the plan needs stronger direction and tools around how climbing access is administered in practice—particularly when it comes to commercial use. Climbing has evolved. It is no longer solely an individual, informal activity. Professional guiding plays a legitimate and increasingly important role in how the public accesses climbing safely and responsibly. The current approach to commercial use permitting often creates unnecessary barriers. Inconsistent policies between land managers, limited permit availability, unclear allocation criteria, and slow administrative processes all restrict access—not just for guiding companies, but for the broader public that relies on those services. This is especially relevant for youth programs, first-time climbers, and individuals without the experience or resources to engage independently. We believe the plan should include directly addressing the following: Establishing clear, consistent guidance across agencies for commercial climbing permits Ensuring permit systems are scalable and reflective of actual demand and use patterns Recognizing guiding as a public access tool, not just a commercial activity to be constrained. Reducing administrative friction so outfitters can operate predictably and in compliance Aligning capacity limits with resource protection goals based on data, not default conservatism Done right, commercial guiding supports stewardship, education, and safe recreation. Guides are often the front line for teaching Leave No Trace principles, managing user behavior, and reducing resource impacts. Treating this sector as a partner—rather than a burden on the system—will lead to better outcomes across the board. I support a plan that protects resources and expands access at the same time. Strengthening the framework around commercial climbing use is a necessary piece of that equation. I support the recognition that climbing is an appropriate Wilderness activity and that fixed anchors, critical pieces of the climbing safety system, are allowable in Wilderness. I also support provisions to allow climbers to place or replace fixed anchors without authorization in the event of an emergency. I appreciate that the policy protects existing climbing routes that were developed before the PARC Act was passed into law. Legacy Wilderness climbs should remain available in order to preserve America’s rich climbing legacy. Please improve policies to expedite timely replacement of fixed anchors in order to avoid unnecessary barriers to climber safety. The authorization process for new climbing routes that require fixed anchors should be easier to navigate. Please provide a clear path for programmatic authorization, or preauthorization, at climbing areas that do not necessitate case-by-case special use permits.