Comment from PAMELA Carter

To the National Park Service: I am submitting this comment in opposition to any revision of the wilderness climbing guidance currently found at lines 593–618 of Director's Order #41 that would redefine fixed climbing anchors so they fall outside the Wilderness Act's prohibition on structures and installations, rather than being evaluated as an explicit, reviewable exception to it. As a child, there was a state park near me that we would walk nearly every weekend. As an adult, this park was extremely popular with bike riders, mountain bikes, dirt bikes, regular bikes too. But the mountain bikes and the dirt bikes (not motorized) ruined the trails, they made their own in many places. You could no longer walk the trails peacefully without having to move regularly to let a bike or several pass. Growing up and living in an urban area, the idea of getting into the woods for a walk slowly disappeared and the land degenerated. I fear that redefining climbing anchors could result in the same thing. The current guidance states plainly 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 understand this docket is developing new text for that section under the same EXPLORE Act provision that FWS is implementing in its parallel climbing docket, FWS-HQ-NWRS-2026-1618, where the proposed approach is to define fixed anchors as not "installations" at all, removing them from Wilderness Act review entirely rather than creating a bounded exception for them. I ask NPS to take a different approach than FWS has proposed. Fixed anchors are permanent hardware drilled into rock in wilderness. Whatever view NPS takes on how climbing should be managed, that management should happen through the review the Wilderness Act requires — the Minimum Requirements Analysis applied case by case — not through a definition that exempts fixed anchors from review altogether. The same is true for any provision that would exempt anchors placed before a certain date from review: existing hardware in wilderness deserves the same scrutiny as new hardware, not a blanket pass. I request that NPS: 1. Maintain that fixed anchors are "installations" or "structures" under the Wilderness Act, subject to the same Section 4(c) analysis as any other permanent structure. 2. Reject any date-based grandfather clause exempting existing anchors from review. 3. Retain the current standard that bolt-intensive climbing is generally incompatible with wilderness character and that power drills remain prohibited. 4. If new climbing-specific guidance is adopted, ensure it operates as a narrow, case-by-case exception evaluated through the Minimum Requirements Analysis, consistent with how NPS treats other proposed uses in wilderness — not as a redefinition that removes an entire category of installation from the Act's reach. Thank you for considering this comment.