Comment from Blake Bolton

Re: NPS-2026-0101, EXPLORE Act Mandated Wilderness Climbing Guidance I am an Idaho climber and mountaineer who has climbed in National Park System units, including Grand Teton and Mount Rainier. I appreciate the NPS recognizing that recreational climbing and limited fixed anchors are legitimate wilderness uses. I also support distinguishing small safety anchors from larger fixed equipment and clarifying that ordinary fixed anchors are not prohibited installations under the Wilderness Act. The final guidance should, however, prevent routine anchor maintenance from becoming delayed or prohibitively burdensome. First, parks should broadly preauthorize routine maintenance and replacement of existing fixed anchors through superintendent compendiums, climbing management plans, or similar programmatic tools. Individual Special Use Permits should not be the default for replacing aging hardware. Until a park adopts a new process, maintenance should continue under existing local policy and practice so the new guidance does not create an unintended moratorium. Second, “one-for-one replacement” should refer to the anchor’s function and approximate number, not require an exact copy of obsolete hardware in the same hole. Replacement should allow modern, longer-lasting hardware, adhesive anchors where appropriate, modest relocation into sound rock, improved belay or rappel configurations, standard redundancy, and replacement of resource-damaging slings around trees or natural features. These are accepted maintenance practices, not new route development. Third, the guidance should allow preventive maintenance before an anchor becomes an imminent threat. Responsible stewards replace aging hardware when corrosion, wear, outdated design, or installation history indicates foreseeable failure. Requiring volunteers to wait until an anchor is nearly unsafe would undermine both public safety and resource protection. Fourth, the NPS should use programmatic authorization for ordinary new safety anchors that meet clear conditions. Individual permits should be reserved for proposals with unusual impacts. Where permits are required, the process should be simple, inexpensive for noncommercial users and volunteer organizations, and subject to clear review criteria and reasonable timelines. Fifth, restrictions should be based on measurable, site-specific impacts rather than route labels or arbitrary anchor counts. The guidance may discourage convenience bolting and high-density sport development while still recognizing that limited bolt-protected climbing can be consistent with wilderness character. Rock type, natural protection, wildlife, cultural resources, visibility, vegetation, and cumulative impacts are more meaningful than whether a route is described as “bolt-intensive.” Sixth, routes and fixed anchors existing before January 4, 2025, should be presumed eligible for continued use, maintenance, and modernization. Removal should be a last resort after site-specific review, consultation, identification of a measurable impact, and consideration of less restrictive alternatives. Seventh, climbers should be allowed to place or replace a limited safety anchor without prior approval when delay would create a substantial safety risk, including retreat during severe weather or replacement of a dangerously compromised rappel anchor. Any reporting requirement should occur after the climbers have safely exited. Finally, ordinary anchor components such as webbing, cord, rappel rings, quick links, and short chains should not be classified as larger fixed equipment requiring a Minimum Requirements Analysis. The final policy should also promote consistent national standards and collaboration with Tribes, local climbers, and stewardship organizations. With these revisions, the NPS can protect wilderness character while allowing safe maintenance of historic routes and responsible, low-impact climbing. Thank you for considering these comments.