Comment from Carter, PAMELA

To the U.S. Fish and Wildlife Service: I am submitting this comment in opposition to the proposed amendment to Service Manual Chapter 610 FW 1, which would add a definition of "fixed anchor" and state that fixed anchors "will not be considered installations, and therefore not subject to" review under the Wilderness Act. I am not opposed to such things, but I oppose them being done arbitrarily without a complete review process. It would be odd to me that doing this without the process is much like me walking into one of these place and digging up plants or stealing artificats. The Wilderness Act's Section 4(c) prohibits "structures or installations" in designated wilderness. A fixed anchor — a bolt or piton drilled and left permanently in rock — is, in plain terms, a structure permanently installed in wilderness. The proposed amendment does not argue that fixed anchors should be an explicit, reviewable exception to that prohibition. It instead defines them out of the category the prohibition covers, so that the review the Wilderness Act requires never applies to them in the first place. That is a substantive change to what the Act prohibits, accomplished through a manual definition rather than through the review process a change of that significance should receive. I am also concerned about the provision stating that any fixed anchor placed before January 2025 stays in place with no review at all. That provision retroactively legalizes existing installations without ever asking whether they are appropriate in the wilderness areas where they sit, and it does so by the same definitional mechanism — removing the object from review rather than reviewing it and deciding in the object's favor. I request that the Service: 1. Withdraw the definition stating that fixed anchors are not "installations" under the Wilderness Act. 2. If the Service concludes that some fixed anchors are appropriate in some wilderness areas, create that as an explicit, narrow, and reviewable exception — subject to the Minimum Requirements Analysis on a case-by-case basis — rather than removing an entire category of permanent hardware from the definition of "installation." 3. Remove or substantially narrow the blanket grandfather provision for pre-2025 anchors, and instead require the same case-by-case review for existing anchors that would apply to new ones. 4. Explain how this proposed definition is consistent with, rather than a narrowing of, Section 4(c) of the Wilderness Act. Thank you for considering this comment.