Comment from Western Montana Climbing Coalition

Western Montana Climbing Coalition Comments on the Proposed Federal Climbing Management Guidance To Whom It May Concern, The Western Montana Climbing Coalition (WMTCC) appreciates the opportunity to comment on the proposed climbing management guidance. We support the overall direction of this proposal and commend the agency for recognizing that rock climbing is an appropriate and legitimate use of our public lands while acknowledging the important role that fixed anchors play in climber safety. Western Montana is home to a diverse collection of climbing resources on Forest Service, Bureau of Land Management, and National Park Service lands. Many of these climbing areas have been developed and cared for over decades through volunteer stewardship, close collaboration with local land managers, and partnerships with organizations such as Access Fund. Our experience has shown that the best conservation outcomes occur when agencies work with the climbing community as active stewardship partners. The Bitterroot Valley provides an excellent example of this collaborative approach. At Mill Creek, local volunteers have invested hundreds of hours improving trail sustainability, reducing erosion, restoring damaged staging areas, replacing aging anchors, educating visitors, and working alongside the Bitterroot National Forest to improve long-term recreation management. Similar stewardship efforts occur throughout western Montana and demonstrate that climbers are invested in protecting the landscapes where they recreate. We strongly support the proposal's recognition that limited, safety-based fixed anchors are fundamentally different from larger installations and should not automatically be treated as prohibited developments. Small hand-placed anchors are an essential component of safe climbing and, when thoughtfully placed, have minimal visual or environmental impact while preventing resource damage caused by repeated placement of temporary anchors. We also appreciate the proposal's recognition that existing climbing routes and anchors established before January 4, 2025, should generally remain available for continued use and maintenance. Western Montana contains many long-established routes that are part of the region's climbing history. Routine one-for-one replacement of aging anchors should remain straightforward so volunteers can continue maintaining these routes safely without unnecessary administrative delays. While we support the proposal, we encourage several refinements that will improve implementation. First, the guidance should avoid rigid national numeric standards for fixed anchors or spacing requirements. Montana climbing areas vary tremendously in geology, route length, and terrain. Local conditions, not arbitrary numerical thresholds should guide safe anchor placement. Second, any authorization process for new routes should be efficient, predictable, and scaled appropriately to the proposed activity. Lengthy permitting processes or requirements for comprehensive climbing management plans before routine decisions can be made would unnecessarily burden both agencies and volunteers while discouraging proactive stewardship. Third, the guidance should clearly allow timely replacement of unsafe anchors and emergency anchor installation when necessary to protect human life. Volunteers should not have to choose between following administrative procedures and addressing immediate safety hazards. Finally, we encourage the agency to continue emphasizing partnerships with local climbing organizations. Groups like the Western Montana Climbing Coalition provide volunteer labor, local knowledge, education, monitoring, and long-term stewardship that significantly expands agency capacity. Local organizations should be consulted early when developing climbing management plans, seasonal restrictions, or other management decisions affecting established climbing areas. As our coalition's work at Mill Creek with the U.S. Forest Service demonstrates, collaborative stewardship creates healthier landscapes, safer climbing opportunities, and stronger partnerships between climbers and land managers. We have also worked closely with the Bureau of Land Management at Rattler, organizing trail stewardship days and updating fixed anchors to improve both resource protection and climber safety. These projects demonstrate that when land managers and the climbing community work together, they can achieve lasting conservation and recreation outcomes. We encourage the agency to adopt a final policy that builds on these successful collaborations by supporting sustainable access, promoting shared stewardship, and protecting the natural resources that make our public lands exceptional for current and future generations. Thank you for considering our comments and for your continued commitment to collaborative stewardship of America's public lands. Sincerely, Western Montana Climbing Coalition