Comment from PAMELA Carter

To the National Park Service: I am submitting this comment in support of retaining the current protections in Director's Order #41, Wilderness Stewardship, and in opposition to any revision that would weaken them. Because this review is occurring at the Director's Order level, one step above the reference-manual layer, changes here have unusually wide reach across how NPS manages wilderness-eligible land, and I want to identify the specific provisions I believe are most important to preserve, by line number, since the agency has invited that level of specificity. **Lines 20–23**, which define "wilderness" for purposes of the Order to include land at every stage of the designation pipeline — eligible, proposed, recommended, and designated — not only land Congress has finished protecting. Because that pipeline can take decades and often never concludes, this definition is what prevents NPS from treating unlegislated wild land as available for development simply because Congress has not yet voted. I request that this definition be retained without narrowing. **Lines 161–164, line 198, and lines 210–213**, which extend that same standard stage by stage: eligible lands preserved, proposed lands managed as wilderness, recommended lands managed as wilderness. These provisions are what make the Order's Line 20–23 definition operational rather than aspirational. I request that all three be retained. The lines below benefit a few groups or individuals, these particular items do not benefit wildlife, and would in fact be a deterrent to them, thereby affecting a majority of the visitors to these areas. Have you been to the Grand Canyon and heard the helicopters? It has destroyed the whole ambiance of the place. **Line 325**, which prohibits a Minimum Requirements Analysis from being used to authorize permanent roads or commercial enterprise in wilderness. This is the provision that keeps the analysis a genuine test of necessity rather than a route to approving development the Wilderness Act was written to exclude. I request that it be retained without modification. **Line 641**, which states that commercial air tours are inconsistent with wilderness character. I request that this determination be retained. **Lines 593–618**, which state that bolt-intensive face climbing is incompatible with wilderness character, that fixed anchors should be rare, and that power drills are prohibited under the Wilderness Act and 36 CFR 2.12. I am aware that the companion NPS climbing docket, NPS-2026-0101, is drafting new text for this section, and I address that docket separately below. I request that any revision to this section maintain the current standard rather than loosen it to match the redefinition FWS has proposed for refuge wilderness. Thank you for considering this comment.