Comment from Harris, Frank
Frank HarrisSupportOther
Summary: The commenter supports broadly authorizing hardware replacement and modernization for climbing in wilderness areas to reduce administrative delays. They argue that the current process is overly burdensome and should be streamlined to allow for upgrades and improvements.
Wilderness
1. Administrative process
Hardware replacement depends upon: appropriateness determinations, compatibility determinations, refuge planning, possible permits.
These requirements may delay otherwise routine maintenance. Replacement work should be broadly authorized.
2. Replacement is undefined
The guidance never defines replacement or modernization.
This should allow for upgraded hardware, glue-ins (adhesive anchors), modest relocation due to poor rock quality, improved anchor configurations, etc.
Non-Wilderness
Outside wilderness, climbing first requires: appropriateness determination, compatibility determination.
Once climbing is authorized, replacement is handled through individual refuge planning.
While understandable that climbing access will be different given the Refuge System's statutory framework, the process is likely to remain more administratively burdensome than on other federal lands. Bolt replacement work should be broadly authorized.