Comment from Friends of Joshua Tree

Friends of Joshua Tree, a 501(c)(3) organization and Joshua Tree National Park partner, represents the voice of climbers. Since 2009, we’ve partnered with NPS to protect park resources and preserve appropriate recreation access. We believe that the PARC act is a major milestone facilitating our mission, and we commend the NPS for issuing the draft climbing management guidance through proposed revisions to Director’s Order 41 and the corresponding Reference Manual. We also commend the current management of Joshua Tree National Park, who have dedicated significant time and resources to reinforce education, stewardship, and partnership with the climbing community so that climbers are treated as partners in stewarding the park and protecting its exceptional natural and cultural resources. As representatives of the climbing community with decades of experience working with Joshua Tree National Park staff on effective solutions, we recommend the following revisions and clarifications to the NPS draft guidance. ·Strongly encourage all parks with climbing to preauthorize routine maintenance or replacement of existing anchors, including one-for-one replacement of unsafe anchors, so that climbers can address safety issues without unnecessary delays. The draft guidance establishes the potential for too many unnecessary bureaucratic obstacles in the way of standard maintenance of established climbing routes. Current practice in Joshua Tree National Park of subjecting anchor maintenance to the special use permit application process on a case-by-case basis, subject to permit expiration, is onerous and out of step with other climbing parks that have successful and safe climbing practices. Yosemite National Park is a relevant example, where a programmatic authorization for fixed anchor replacement allows local climbing organizations and volunteers to keep visiting climbers safe without compromising the protection of cultural and natural resources. ·Strengthen the presumption that climbing routes and anchors existing before January 4, 2025 are eligible for continued use and maintenance, and make removal a last resort only after transparent, site-specific analyses provide quantitative indicators that continued use would harm wilderness character or sensitive resources. ·Replace the default requirement that new fixed anchors obtain a Special Use Permit (SUP) with a more flexible “programmatic” or compendium-based approval system that allows parks to preauthorize low-impact anchors (e.g., occasional fixed anchors on traditional routes or rappel anchors to protect cliff top resources) without individual permit applications. This revision would align the NPS guidance with existing and successful climbing management models common to several park units (e.g., Yosemite and Rocky Mountain national parks). ·Clarify that a superintendent’s compendium-based waiver of the SUP requirement functions as programmatic authorization and is not just a discretionary waiver, so climbers and parks understand when permits are needed. ·Provide clear timelines, cost limits, and other guardrails for the SUP process so that permit review does not become prohibitively slow, inconsistent, or costly for climbers and local organizations. ·Clarify that fixed anchors outside wilderness primarily serve climber safety—not only resource protection—and should not be subject to the same permit requirements and standards as within wilderness. ·Encourage parks to develop climbing management plans in consultation with local climbing groups, resource specialists, and other stakeholders. It would be helpful to provide national templates and standards to reduce variability in how parks manage climbing. ·Add an emergency or exigent-circumstances provision similar to the emergency provision found in the draft BLM guidance, allowing climbers to place or replace anchors without prior authorization when delay would compromise safety, and ensure that removal of anchors placed during an emergency is required only when it is safe and beneficial to wilderness character. ·Reinforce education, stewardship, and partnership with the climbing community so that climbers function as partners in protecting wilderness and cultural resources. ·Maintain climbing as a primitive, self-reliant, low-development activity and avoid imposing developed-recreation standards or services on climbing areas except where necessary for site-specific resource protection or visitor safety.