The U.S. Forest Service is proposing to revise its directives to provide guidance on recreational rock climbing on our National Forests, including guidance required by the EXPLORE Act for climbing in Wilderness. Wilderness and wildlife are under relentless pressures at this moment in history, including from exploding demand for outdoor recreation. Recreational rock climbing in Wilderness should be free of permanent alterations. Rather than hammer a wilderness rock face into submission, a climber may have to accept that a route that cannot be climbed, or descended, without anchors should not or cannot be climbed at all. Natural limits are essential to protecting Wilderness. We need you to speak up to defend the Wilderness Act and America’s National Wilderness Preservation System! But first, some background information: The PARC Act, incorporated into the EXPLORE Act—which was signed into law on January 4, 2025—is a messy piece of legislation that attempted a de facto amendment of the Wilderness Act to benefit the recreational climbing industry. The Wilderness Act is straight-forward—installations, including permanent fixed climbing anchors, are prohibited unless absolutely necessary to meet the minimum requirements for administering Wilderness. The Forest Service’s formal legal position has aligned with this proper statutory reading for decades. But the PARC Act/EXPLORE Act says that permanent recreational bolting is an appropriate use in Wilderness when undertaken in compliance with the Wilderness Act—a wild exercise in circular reasoning—and now the agencies are tasked with making sense of the absurd in their new climbing directives. While some of the language in the proposed Forest Service guidance is good, the guidance is undermined by a few serious flaws. First, the guidance attributes the Forest Service’s strained legal interpretation of fixed anchors to the Wilderness Act when it should be attributed to the PARC Act/EXPLORE Act. The guidance also casts the Forest Service’s obligations under the Wilderness Act as discretionary rather than required. Furthermore, the guidance notes that only certain fixed anchors are allowable, but provides little to no mandatory guidance on the scope, function, and placement of such allowable anchors. The Forest Service punts administration to climbers themselves and references climbing management plans that are discretionary and wholly dependent on funding (not to mention political will). And finally, while the guidance provides room for local line officers and district rangers to restrict the use of permanent fixed anchors to protect wilderness character, these agency staff are already trying to do their jobs with limited resources and without political support. Any implication that the Wilderness Act’s prohibitions can be overcome by the desire to enhance recreation is not only flawed, but also ushers wilderness administration to the precarious edge of a slippery slope. Wilderness administering agencies are facing a crossroads. The outdoor recreation industry, and its influence on public land management, is booming, and outdoor recreation pressures that were once front-country issues are pushing steadily into our most protected places. Meanwhile, agency wilderness programs are underfunded and deprioritized, wilderness-trained staff are stretched thin, and wilderness departments are increasingly subsumed by recreation departments. Combine these issues with decades of agency equivocation over permanent fixed climbing anchors in Wilderness, and you have the untenable situation at hand: exploding demand for developed recreational climbing, proposed agency guidance that confuses statutory language on prohibitions in Wilderness, and wilderness staff lacking resources to effectively protect Wilderness. In this context, we need defenders of the Wilderness Act and America’s National Wilderness Preservation System to take action!
The U.S. Forest Service is accepting public comments through Monday, July 20 at this link: https://cara.fs2c.usda.gov/Public/CommentInput?project=Directives-4622 Please speak in your own words, but make the following points: | 
