Comment from Erik Filsinger

Support for Published Mandated Climbing Guidance for USFS, BLM, Fish & Game National Park Service Plans I strongly support the published plans for each federal jurisdiction and submit the supportive comments below to each management entity. I have been rock and ice climbing on federal lands across North America for over 40 y ears. Rock climbing, especially in some of its current variants, can be a highly intrusive recreation in part due to the intensity of users gathering in small areas as well as the use of intrusive permanent fixtures. The high intensity character of sport climbing, for example, require proper management or there will be a severe and permanent degradation of the natural resources land managers are tasked to preserve. At its heart, recreation management is a land management problem. Although these comments are my own and do not reflect the official positions of entities with whom I may be affiliated, I have been involved in “managing” rock climbing both representing user groups as well as serving on boards and commissions of local, state and federal governments. My years of experience covering both rock climbers and protecting the land where rock climbing takes place has lead me to be firmly convinced in the benefits of Climbing Management Plans (CMP’s). They are tools to help the land manager as well as define the appropriate actions of the recreational user. Therefore, I support the language in the Climbing Guidance of the current plans. I do not believe that it should be weakened to be only used if a land manager can make a case that it is needed. The burden on the land manager would be excessive to have to clear the hurdles of justifying a CMP and then writing one as a change. Instead, I firmly believe that CMP’s should be the default land management tool of the USFS, BLM, Fish & Game, and NPS. I believe that there should be an option for the Land Manager to affirmatively back out of the requirement but it should be a priori the land manager’s choice, not a burden to justify and then implement. At the very minimum I argue that CMP’s should be the default Day 1 tool for land managers if there are any questions of Intensity of use or Cultural and Historic factors come into play. For example, I have been involved with the Apache Leap Special Management Area near Superior, Arizona. Cultural and Historic considerations can only be managed with a CMP in place if climbing is to be allowed at all. A further example of where Intensity of user activity a priori justifies a CMP would be Joshua National Park where grid bolting is destroying the resource. Indeed a fundamental element of CMP’s should be a mapping of the crags where climbing can occur and these maps and lists should mandate future climbing, even if the land manager chose to close certain historic areas because of the damage to the land that is occurring. Having participated in the writing of CMP’s I believe that the burden of creating CMP’s in local jurisdictions of the federal agencies can be simplified by the use of a common template produced at the agency level. The elements of a CMP are well identified and can easily be converted into boiler plate language (e.g., general practices and guidelines) whereas the local specific elements can be referenced in appended attachments (e.g., a list and mapping of the authorized climbing crags).