Comment from Madsen, Thue

I appreciate that the Fish & Wildlife Service is implementing the EXPLORE Act and PARC Act within the Refuge System’s framework, but I oppose guidance that makes routine hardware replacement excessively administrative and undefined. Tying replacement to multi‑step appropriateness and compatibility determinations, refuge planning, and possible permits for even standard maintenance is likely to delay otherwise straightforward safety work. At the same time, the guidance does not explain what “replacement” can include, leaving modern practices in a gray area. I respectfully request that FWS: Streamline planning and authorization for maintenance of existing routes so that routine replacement of aging hardware is broadly authorized once climbing is deemed appropriate, both in and outside wilderness. Define replacement to include modernization: upgraded hardware, glue‑ins (adhesive anchors), modest anchor relocation into better rock, and improved anchor configurations that reflect current engineering and safety best practices. Clarify that bolt replacement work, particularly preventive maintenance before failures occur, is recognized as compatible stewardship work where climbing is allowed, rather than an exceptional use. This approach would better align Refuge System goals with the PARC Act’s mandate to protect existing climbing routes and standard safety practices while conserving wildlife and habitat.