Comment from Patricia Degner

I am a climber writing in support of climbing in wilderness. I support the recognition that fixed anchors are not installations under Section 4(c) of the Wilderness Act (lines 94 to 99), the protection of routes established before January 4, 2025 (lines 176 to 181), the exigent circumstances allowance (lines 182 to 194), and the prohibition on power drills (lines 46 to 47 and 196 to 205). I agree that dense, convenience oriented sport climbing development does not belong in wilderness. What does belong is adventurous, ground up climbing established with restraint, whether protected by removable gear, occasional hand drilled bolts, or bolts alone where the rock offers no cracks. My concerns are about provisions that would prohibit that style while aiming at the other. My primary concern is line 251, which requires a Special Use Permit application for all new fixed anchors, with Table 1 (line 302) showing preauthorization as not available. A mandatory case by case permit for every new placement functions as a prohibition on new routes. Parks lack the staff to review individual anchor applications on any reasonable timeline, the draft requires only estimated timelines with no binding deadline (lines 268 to 269), and an application that sits unanswered is a denial. The PARC Act at 16 USC 8422(d) expressly contemplates that authorization requirements, if any, may be issued programmatically, but the draft forecloses that option for new anchors. Please revise Section 4 and Table 1 to allow parks to preauthorize new fixed anchors through the Wilderness Stewardship Plan or compendium, with criteria set in advance, reserving case by case review for locations with documented resource concerns. Second, the definition of bolt intensive face climb (lines 334 to 338) targets the wrong characteristic. Whether protection is removable has nothing to do with wilderness character. Wilderness contains vast crackless rock where removable protection is physically impossible, and the boldest routes in the National Wilderness Preservation System are face climbs protected only by widely spaced, hand drilled bolts placed from stances on the lead. Take the Bachar-Yerian in Yosemite; routes like that see little traffic precisely because they demand skill and commitment, and they embody the primitive and unconfined recreation the Wilderness Act protects. Under the current definition they would be prohibited while a crack climb of equal traffic and impact would be allowed. What actually concentrates human activity (the stated concern in lines 20 to 24) is density: closely spaced bolts that remove risk and invite crowds, typically installed on rappel. Please redefine bolt intensive face climb by bolt density and establishment style, for example routes with closely and regularly spaced bolts installed to eliminate the need for judgment and commitment, rather than by whether protection is removable. Third, the permit requirement interacts badly with the definition of fixed anchor (lines 86 to 90), which includes webbing, slings, or cord left behind. Under this draft, a climber who leaves a single sling around a tree to descend from a route with no bolts has created a new fixed anchor requiring a permit application with maps, dates, and a post climb report. This includes routine retreat from a route beyond the party's ability, which involves no imminent danger and so is not covered by the exigent circumstances allowance. A permit for a sling is unenforceable, will be universally ignored, and will teach climbers to disregard the rest of the framework. Please exclude slings and cord on natural features from the new anchor permit requirement or preauthorize removable soft goods used for descent. Fourth, lines 31 to 32 and Table 1 allow parks to require permits for replacement of existing anchors, even though line 177 recognizes that one for one replacement of pre 2025 anchors is generally compatible with wilderness character. A corroded bolt is a safety hazard, and permitting like for like maintenance adds delay without adding protection. Please make one for one replacement preauthorized servicewide rather than park determined. Finally, please do not translate any of this into numeric bolt caps. A fixed number cannot account for rock quality, route length, or natural protection. Bolting in wilderness is already naturally limited by the time consuming nature of hand drilling and long approaches. Nobody hand drilling in remote terrain places more bolts than necessary. The physics of the hand drill is a more honest regulator than any number in a management plan. Thank you for the improvements over the 2023 proposals. With a programmatic path for new routes, a density based definition of bolt intensive, sensible treatment of slings, and unpermitted maintenance, this guidance can protect wilderness character and the future of wilderness climbing rather than only its past. Your work is appreciated!