Comment from Henry Carscadden

AnonymousOpposeIndividual
Summary: The commenter argues that the proposed requirement for Special Use Permits and Minimum Requirements Analyses for power drills creates an undue administrative burden and counterproductively harms wilderness resources. They contend that forcing the use of manual hand drills increases the duration of human presence and acoustic disruption, suggesting that the NPS should instead simplify the authorization of power drills to minimize environmental impact.
By requiring a restrictive Special Use Permit (SUP) and a Minimum Requirements Analysis (MRA) for the public use of power drills, the draft guidance creates an undue administrative burden that effectively forces climbers to default to manual hand drills. While intended to protect wilderness character, this mandate ignores the highly labor-intensive nature of hand drilling and the duration of the continuous hammering required not needed for power drilling. This creates a severe, counterproductive impact on wilderness resources. Forcing climbers to use hand drills drastically extends the duration of human presence on the wall and multiplies acoustic disruptions. This directly contradicts the management goals outlined in Page 7, Lines 134–139, which aim to limit "noise and visual intrusions" and preserve "opportunities for solitude." The NPS should simplify the authorization of power drills for necessary safety anchor placements to minimize the time footprint and long-term environmental disruption of climbers in wilderness areas.

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