Comment from Ryan Young

Leavenworth Mountain Association: Comments on Proposed FSM 2355 The Leavenworth Mountain Association (LMA) is the local climbing access and stewardship organization for Leavenworth, Washington. Our members climb and volunteer across the Okanogan-Wenatchee National Forest, from Icicle Creek and Tumwater Canyon to the Alpine Lakes Wilderness, and we work closely with the Wenatchee River Ranger District on trails, anchors, and climber education. We appreciate the work behind this directive and offer the following comments. 1. Don't make a climbing management plan a prerequisite for routine activity. The directive should be clear that routine anchor maintenance, one-for-one replacement, and ordinary new route authorization can happen without a completed CMP. CMPs take years and often lack funding. The National Forest System has just three forest-wide or district-level CMPs today, yet it manages roughly 30 percent of America's climbing. Requiring a CMP first would amount to a moratorium, which is at odds with the EXPLORE Act's protection of legacy routes and anchors. Keep CMPs as a tool for areas that need them, not a gate on ordinary stewardship. 2. Strengthen protection for legacy routes and anchors. Routes and anchors in place before January 4, 2025 should be presumed eligible for continued use and maintenance. Removal should be a last resort, used only after site-specific review shows a measurable impact to sensitive resources and less restrictive options (education, seasonal restrictions, rerouting) have been considered. A minimum requirements analysis is the wrong process here: the directive rightly distinguishes fixed anchors from Wilderness Act "installations," and legacy review shouldn't bring MRA back in through the side door. 3. Clarify "limited in size, scope, and function." Ordinary bolts, pitons, and rappel anchors generally meet this standard when they are small, low-visibility, safety-related, and hand-placed. Please avoid rigid numeric caps like bolts per pitch. Real terrain doesn't follow formulas, and caps push climbers toward less safe choices. 4. Recognize that anchors outside wilderness are mainly about safety. Section 2355.31 frames anchor placement mostly around resource protection. Fixed anchors are appropriate outside wilderness, and their main job is keeping climbers safe: preventing falls and allowing safe rappel or retreat. Resource protection is a real benefit, but the directive should say the safety part plainly. Thank you for considering these comments. We'd welcome the chance to keep partnering with the Forest Service on climbing stewardship in the Leavenworth area.