Comment from Skyeler Congdon

To Whom It May Concern, I appreciate the National Park Service's efforts to implement the EXPLORE Act and to recognize recreational climbing as an appropriate wilderness activity. I support the goal of protecting wilderness character while providing clear guidance for climbers and park managers. I respectfully offer the following recommendations. As a professional climbing guide and an experienced traditional climber who has established and maintained routes on public lands, I have firsthand experience with fixed-anchor stewardship. Responsible climbers invest substantial time and personal resources into replacing aging hardware, removing unsafe or abandoned equipment, and preserving existing routes for future visitors. Clear, practical guidance will strengthen these stewardship efforts while protecting both public safety and wilderness character. First, I am concerned that allowing each park to develop its own authorization process for fixed-anchor replacement could lead to inconsistent policies across the National Park System. In some parks, routine replacement may remain straightforward, while in others it could become administratively difficult or delayed. Existing management practices should remain in place until a Climbing Management Plan or Special Use Permit process has been completed, rather than allowing uncertainty to interrupt routine maintenance of existing routes. Second, the proposal should clearly define what constitutes "replacement." Limiting replacement to a literal "one-for-one" interpretation does not reflect modern climbing safety practices. Responsible replacement often includes upgrading obsolete hardware to current standards, replacing aging expansion bolts with longer-lasting hardware such as adhesive anchors where appropriate, making modest relocations into sound rock when the original placement has deteriorated, or improving outdated anchor configurations. These actions do not expand climbing development; they preserve existing routes while ensuring they remain safe and sustainable. The final guidance should explicitly recognize modernization consistent with accepted engineering and stewardship practices. Third, I encourage the National Park Service to broadly preauthorize routine replacement of existing fixed anchors rather than requiring communication or approval for each individual maintenance project. Most anchor replacement is performed proactively before hardware becomes hazardous. Requiring repeated communication for routine maintenance creates unnecessary administrative work for both park staff and volunteer stewards and may discourage timely replacement of aging hardware. The climbing community has demonstrated decades of responsible stewardship, often replacing deteriorated anchors at its own expense and in coordination with local climbing organizations. Finally, well-maintained fixed anchors often reduce environmental impacts. Durable rappel anchors can prevent repeated damage to trees from slings, reduce the proliferation of informal descent routes, and concentrate use on durable surfaces. Thoughtful maintenance is therefore consistent with the National Park Service's conservation mission and the preservation of wilderness character. Thank you for the opportunity to comment. I encourage the National Park Service to revise the final guidance by: * Maintaining current replacement practices until park-specific management plans are completed. * Defining replacement to include modernization using current safety and engineering best practices. * Broadly preauthorizing routine replacement of existing fixed anchors without requiring project-by-project communication or approval. * Continuing to recognize the climbing community as an important partner in the long-term stewardship of wilderness climbing resources. Thank you for your consideration. Skyeler Congdon PCGI Certified Lead Guide Cliffhanger Guides, Joshua Tree CA