CALL TO ACTION
CALL TO ACTION
Comment on draft federal climbing policies
Why These Draft Climbing Policies Matter
In January 2025, Congress passed the EXPLORE Act, which included the Protecting America's Rock Climbing (PARC) Act. Among other things, the law directed the Forest Service, National Park Service, Bureau of Land Management, and U.S. Fish & Wildlife Service to develop national guidance for recreational climbing on federal lands, including designated wilderness.
For decades, fixed anchors have existed in a gray area of federal policy. While millions of climbers have relied on fixed anchors for safe access to public lands, agency policies have often been inconsistent, unclear, or developed independently by individual land managers. The EXPLORE Act was intended to provide greater clarity by recognizing that recreational climbing - including the placement, use, and maintenance of fixed anchors - is an appropriate use of public lands when conducted in accordance with the Wilderness Act and other applicable laws.
Each of the four federal land management agencies has now released draft guidance for public review.
Overall, these proposals represent a significant step forward. All four agencies recognize recreational climbing as an appropriate use of public lands, and all acknowledge that existing climbing routes and fixed anchors have an important place in climbing management. Several agencies also explicitly recognize that fixed anchors are not considered "installations" under the Wilderness Act, an important clarification that resolves years of uncertainty.
However, the draft guidance also contains language that could unintentionally create barriers to climbers replacing aging climbing hardware or safely protecting a new route, and create inconsistent management from one forest, park, or field office to another.
Several drafts condition replacement of existing anchors on future Climbing Management Plans (CMPs) or other local planning documents. While management plans can be valuable tools, many climbing areas do not currently have CMPs, and some may not receive them for many years. Without clearer language, these provisions could be interpreted as preventing routine replacement of aging bolts or reasonably protecting new routes until a plan is completed, creating a de facto moratorium on hardware replacement despite Congress's clear intent to recognize continued maintenance of existing climbing routes.
Other provisions leave important terms undefined, and contain language that is hard to understand and highly interpretive. Modern hardware replacement often involves replacing obsolete or deteriorated equipment with safer, longer-lasting hardware, modestly relocating anchors into sound rock, or upgrading outdated anchor systems. Without clear definitions, these routine safety improvements could receive inconsistent treatment across federal lands.
These drafts are still proposals, and this public comment period is the opportunity for climbers, climbing organizations, land managers, and other stakeholders to help improve them before they become final agency policy. Each federal agency has individual proposals and comment forms.
Constructive comments can help ensure that the final guidance:
clearly allows for routine maintenance work;
recognizes proactive replacement of aging hardware before failures occur;
allows modernization using current engineering and safety best practices;
allows reasonable fixed protection when climbers establish new routes;
provides consistent authorization for replacement across federal lands;
avoids unintended barriers to maintaining the safety of existing climbing routes.
The agencies have already taken an important step by recognizing recreational climbing and fixed-anchor maintenance within national policy. Thoughtful public comments can help ensure that the final guidance fulfills the intent of the EXPLORE Act while providing the clarity needed for climbers and land managers alike.
Agencies are required to review and consider substantive comments, and well-reasoned feedback often results in clearer language, corrections, or changes that improve implementation. While form letters can demonstrate broad interest, personalized comments generally carry more weight because they explain how a proposal would affect real people and real climbing areas. The most effective comments are respectful, specific, and solution-oriented. Rather than simply expressing support or opposition, identify the exact provision that concerns you, explain why it could create unintended consequences, and suggest language or an approach that would better achieve the agency's goals.
If you have firsthand experience replacing aging hardware, stewarding climbing areas, or working with land managers, include those experiences - they help demonstrate why clarity matters. Thoughtful comments that acknowledge the many positive aspects of these drafts while offering constructive recommendations are far more likely to influence the final guidance than comments that simply criticize the proposals.
Summary of major concerns:
Any and all restrictions on climbing and fixed anchor use should NOT be implemented until a CMP (or other management plan) is finalized. Climbing and fixed anchor use should continue as has been historically practiced in each land management unit until a CMP for the area is finalized.
Forest Service: Clarify that routine replacement of existing hardware is broadly authorized, independent of Climbing Management Plans, and define replacement to include modernization (one-for-one does not mean replacing a 1/4" buttonhead gets another 1/4" bolt etc.). Power (motorized) drills should be broadly authorized for bolt placement/replacement and should not be dependent on the existence of a CMP for the district.
BLM: Remove the numerical "5 bolts within 100 feet" threshold and replace it with a more holistic assessment of wilderness impacts. Something like: "fixed anchors are essential pieces of a climbers safety system that allow them to safely and sustainably access vertical terrain, but they should be used sparingly in wilderness climbing areas. Avoid placement when natural protection is available and do not create high density "sport" style routes in order to preserve wilderness character. Travel on durable surfaces whenever possible during approaches to avoid resource degradation"
National Park Service: Clarify that "one-for-one replacement" includes modernization and encourage parks to preauthorize routine replacement rather than requiring permits.
Fish & Wildlife Service: Streamline the planning and authorization process for maintenance of existing routes, including specifying that routine replacement of existing hardware is broadly authorized, while providing greater clarity on replacement and stewardship.
Detailed concerns and links to documents/comment forms:
U.S. Forest Service (FSM 2355 CLIMBING OPPORTUNITIES)
If you only have time to write a comment for one draft policy, please comment on this one as it has potential to impact all Forest Service climbing, not just Wilderness areas.
Wilderness
1. Replacement is heavily dependent on Climbing Management Plans.
The directive repeatedly ties the placement, replacement, and retention of fixed anchors to Climbing Management Plans and states that climbers may place or replace fixed anchors when allowed by a land management plan or CMP.
Routine replacement of deteriorated hardware should not depend on whether a forest has completed a CMP. This creates unnecessary uncertainty/potential for a de-facto ban and could delay maintenance in forests that lack climbing-specific plans. Very few CMP's currently exist and can take a very long time to create, replacement should be broadly authorized to allow timely replacement of dangerous hardware.
2. Preventive maintenance is not clearly recognized
Emergency replacement is allowed when there is an imminent threat to human safety. However, most replacement occurs long before hardware becomes an emergency.
The directive should explicitly recognize proactive replacement of aging hardware as an appropriate stewardship activity.
3. Replacement is undefined
The directive never clarifies whether replacement includes: upgraded hardware, glue-ins, modest relocation due to poor rock quality, improved anchor configurations, etc.
Language should be modified to allow for current best practices in anchor replacement.
5. Glue restrictions
The prohibition on adhesives absent additional approval may discourage replacing deteriorated expansion bolts with longer-lasting glue-ins where appropriate.
Language should be modified to recognize adhesive anchors (glue ins) as a standard type of fixed anchor.
6. Confusing Language
Section 2355.32 states “and allowing placement of fixed anchors and fixed equipment in areas where impacts on the rock face are occurring due to the use of rock hammers to chip handholds or footholds into the rock.”
This language is confusing and should be removed. If it is referring to blank sections of wall on aid routes to allow for bolt ladders to bypass these sections that should be clarified.
Non-Wilderness
1. The primary concern remains the lack of a definition for replacement and the continued reliance on local planning documents for authorization. Power (motorized) drills should be broadly authorized for bolt placement/replacement and should not be dependent on the existence of a CMP for the district.
The language regarding not allowing redundant or otherwise unnecessary placement or replacement of fixed anchors and fixed equipment is confusing and impractical as climbers count on redundancy at anchor stations, rappel stations, etc. This should be clarified or removed.
Comment period closes on
july 20, 2026
national park service (NPS-2026-0101-0002 Managing Climbing Activities in Wilderness)
Wilderness
1. Park-by-park authorization
Individual parks determine whether replacement requires: no permit, preauthorization, Special Use Permit.
This could produce inconsistent replacement policies nationwide and lead to unsafe anchors not being replaced in a timely manner.
Modern replacement often requires improved hardware rather than identical hardware. The language should recognize modernization consistent with accepted best practices. See ASCA guidance.
2. Replacement remains undefined
Like the other agencies, NPS never explains what replacement could include, just specifies "one-for-one". This should allow for upgraded hardware, glue-ins (adhesive anchors), modest relocation due to poor rock quality, improved anchor configurations, etc.
3. Communication requirements
The expectation that replacement proposals be communicated to the park will become burdensome for routine maintenance. Parks should broadly preauthorize replacement.
Non-Wilderness
NPS guidance doc applies only to wilderness.
Comment period closes on
august 14, 2026
bureau of land management (BLM Manual 6340—Management of BLM Wilderness)
Wilderness
1. Numerical definition of "bolt-intensive"
The proposed threshold of more than five bolts within 100 feet is one of the more concerning provisions.
Potential unintended consequences include: discouraging appropriate protection spacing, discouraging modern redundant anchors, and treating bolt count as a proxy for wilderness impacts when in reality it is the approach route and terrain the route uses that have a far bigger impact.
For example you could have a route that uses no bolts at all, approaches through a riparian zone, and climbs heavily vegetated crack systems, leading to a huge impact on plant and animal life. Whereas you could have a face climb protected primarily with bolts and an approach on durable surfaces, that has a very minimal impact on plant life/animals/wilderness character.
Bolt density alone is a poor indicator of wilderness character and this language should be removed.
2. Replacement remains undefined
The guidance does not clarify whether replacement includes modernization.
This should allow for upgraded hardware, glue-ins (adhesive anchors), modest relocation due to poor rock quality, improved anchor configurations, etc.
3. Little operational guidance
Compared with the Forest Service and NPS drafts, BLM provides relatively little direction regarding: replacement authorization, preventive maintenance, volunteer stewardship, modernization, etc.
Language should be added to explicitly allow for anchor maintenance and replacement.
Non-Wilderness
The draft focuses almost entirely on wilderness policy.
Comment period closes on
August 14, 2026
US Fish and Wildlife service (083672-DIR_MEMO_EXPLORE_Act_Implementation)
Wilderness
1. Administrative process
Hardware replacement depends upon: appropriateness determinations, compatibility determinations, refuge planning, possible permits.
These requirements may delay otherwise routine maintenance. Replacement work should be broadly authorized.
2. Replacement is undefined
The guidance never defines replacement or modernization.
This should allow for upgraded hardware, glue-ins (adhesive anchors), modest relocation due to poor rock quality, improved anchor configurations, etc.
Non-Wilderness
Outside wilderness, climbing first requires: appropriateness determination, compatibility determination.
Once climbing is authorized, replacement is handled through individual refuge planning.
While understandable that climbing access will be different given the Refuge System's statutory framework, the process is likely to remain more administratively burdensome than on other federal lands. Bolt replacement work should be broadly authorized.
Comment period closes on