Comment on FR Doc # N/A

I am writing to comment on the new Section 1.6.C.13.f in BLM Manual 6340. I appreciate that this document recognizes climbing as a legitimate wilderness use. I am a climber, but it is more apt to say that climbing is who I am. It is the most fundamental, pure thing I know how to do. Going to the mountains is going home, to put it in words used by so many. I, therefore, want to protect my privilege to express my creativity and life in these mountains I love so much. As such, I am providing feedback on the aforementioned documents, and I hope you will use it constructively, knowing that my words are written with my soul at the keyboard. The current distinction for a route to qualify as casual use is unclear, unreasonable, and unsafe. On a safe and efficient multipitch climb, there are at least two bolts per pitch for the anchor. The anchor must have two bolts because, for a significant portion of the climb, the climbers are attached to the wall only by the anchor. Should the anchor fail, the climbers will fall and likely die. Therefore, the anchor must have at least two bolts. Under 1.6.C.13.f, to be considered a casual route, a multipitch climb can be a maximum of five pitches long, simply to have safe and effective anchor bolts. This is unreasonable. A typical pitch is 100 feet, and our beautiful public lands have many rock faces that are much taller than 500 feet. Climbers will climb, come what may. If this regulation is instituted, however, they will be hesitant to install safe and efficient rappel anchors. This will almost certainly lead to accidents from unsafe rappels and descents. Whatever goes up must come down, and downclimbing is much harder than up-climbing. Climbers typically get down by walking off or rappelling. Rappels require the two bolt anchors, as mentioned above. Walking off is not always possible, as some summits have no easy way down. If a climber needs to rappel and there is no two bolt anchor, there are a couple of options. The climber can wrap their rope around a tree and rappel down, then pull the rope. This can damage the tree, particularly when a tree is repeatedly used for rappels, so it is not a good option. Alternatively, the climber can leave gear such as slings or cord behind. This is unsightly, since the material is often brightly colored and will become tattered after being exposed to the elements. Worse, it is unsafe, since this gear is not meant to be used after being exposed to sun and rain for extended periods of time. If later climbers need to rappel, which they will, they may use this material (dubbed “tat”) and fall to their deaths. This is unfortunately a relatively common accident; here is one example: https://americanalpineclub.org/news/2025/6/25/the-prescriptionrappel-fatalities. Further, bolts are used to protect face climbing. There are two ways to protect climbing: fixed protection and removable protection. Removable protection is safe and should be used whenever possible. However, sometimes the rock does not allow for removable protection. Climbs become unsafe when there is insufficient protection. The new regulation increases the likelihood of these dangerous, run-out climbs. I truly appreciate the effort that is going into protecting climbing in our wild areas. I believe North America, particularly the American West, is unique and magical in its vast, untouched landscapes. I want it to remain so. Allowing climbers, who care so much about this land, to continue climbing in the way they must, is vital to the protecting of our lands. Thank you.