The Canyon at Pond Creek, Bledsoe County, Tennessee
In August 2026 we submitted formal public comments to three federal agencies on their draft climbing guidance. Below is why, and the full text of what we filed.
What happened
In January 2025, Congress passed the EXPLORE Act, which included the Protecting America’s Rock Climbing (PARC) Act. That law directed four federal land management agencies, the Forest Service, the National Park Service, the Bureau of Land Management, and the U.S. Fish and Wildlife Service, to write national guidance for recreational climbing on federal lands, including designated wilderness.
For decades, fixed anchors lived in a policy gray area. Millions of climbers depended on them. Agency policy on them was inconsistent, often unwritten, and decided forest by forest and park by park. Congress passed PARC to end that ambiguity.
All four agencies released draft guidance in 2026. The Forest Service comment window closed July 20. The other three closed August 14. We filed comments in all three of the open dockets, as an individual, under our own name.
What the drafts get right
We led our comments with this, because it matters and because it is true.
All four agencies affirm that recreational climbing is an appropriate use of public lands. All four acknowledge that existing routes and the fixed anchors that protect them have a legitimate place in climbing management. Several go further and state plainly that fixed anchors are not “installations” under the Wilderness Act, a clarification climbers have been waiting on for the better part of thirty years.
That is a durable win, and the agencies deserve credit for it.
The four places we asked for changes
Our concerns were narrow and technical. They are also the difference between guidance that works and guidance that quietly strands a generation of aging hardware on the wall.
1. “Replacement” is never defined.
Multiple drafts authorize one-for-one replacement without saying what replacement means. Read literally, one-for-one could require that a corroded 1/4-inch buttonhead from 1985 be replaced with another 1/4-inch buttonhead, hardware no manufacturer makes and no competent rebolter would place.
Real replacement work can mean upgrading to modern stainless or titanium, converting to adhesive anchors where the rock demands it, moving a bolt out of a hollow flake into sound stone, and rebuilding a two-piece anchor into a redundant one. That is not new development. That is maintenance done correctly.
We asked that: replacement be defined to include modernization consistent with current engineering and stewardship best practices.
2. Replacement should not wait on a Climbing Management Plan.
Several drafts condition anchor replacement on a completed CMP or comparable local planning document. Most climbing areas do not have one. Some will not have one for a decade.
If that language survives, the practical effect is a moratorium on hardware replacement across large stretches of federal land. Not because anyone intended it, but because the plan that authorizes the work does not exist yet. Bolts corrode on their own schedule. They do not wait for a planning cycle.
We asked that: routine replacement be authorized broadly and immediately, independent of CMP status, with existing practice in each unit continuing until a plan or permit is actually finalized.
3. Bolt density is a poor proxy for wilderness impact.
The BLM draft proposed a numerical threshold, more than five bolts within 100 feet, to identify bolt-intensive routes. We understand the impulse. We think the metric measures the wrong thing.
Consider two routes. The first uses no bolts at all. The approach crosses a riparian zone, and the climb follows vegetated cracks that get scrubbed clean over a season of traffic. The second is a face climb protected entirely by bolts, approached on bedrock, on stone that supports nothing living.
By the proposed standard, the first route is fine and the second is flagged. In terms of actual impact on soil, water, plants, and wildlife, that ranking is backwards. Approach corridors and terrain type drive impact. Bolt count mostly measures how steep the rock is.
Worse, a hard numerical cap creates pressure to run protection out to stay under the number, and discourages the redundant anchors that modern practice calls for. A safety standard should not push climbers toward longer falls in the places where rescue is slowest.
We asked that: the numerical threshold be replaced with a holistic assessment oriented to actual effect on wilderness character and resources.
4. Routine maintenance should be preauthorized, not permitted.
Several drafts route ordinary replacement work through permits, appropriateness determinations, compatibility determinations, or case-by-case notification. Applied to a single new route, that is reasonable. Applied to swapping out forty-year-old hardware on an established climb, it converts a two-hour volunteer job into a paperwork exercise that most volunteers will simply decline to undertake.
The people doing this work are unpaid. They buy their own hardware or receive it from nonprofits like the American Safe Climbing Association. Administrative friction does not make that work safer. It makes it not happen.
We asked that: routine replacement on existing routes be preauthorized, with permitting reserved for genuinely new development.
Why a private landowner in Tennessee commented
Pond Creek Crag sits on private ground. Nothing in these directives governs a single bolt on our property.
We commented anyway, for three reasons.
First, federal policy sets the national norm. What the Park Service writes about one-for-one replacement becomes what insurers, attorneys, state park managers, and private landowners cite when they write their own rules. Guidance drafted for wilderness does not stay in wilderness.
Second, the climbers who use our crag also use public land. Access is not a portfolio of separate properties. It is one system, and it degrades from whichever end is weakest.
Third, we have direct experience with the thing these drafts are trying to regulate. Since 2024, more than 150 routes have been established at Pond Creek Crag, 55 of them by our owner, in Cumberland Plateau sandstone that is unforgiving about anchor placement and unforgiving about mistakes. We know what it costs to do this work correctly, and we know what happens when hardware is left in place past its service life. We would rather say so now than read the final rule and wish we had.
The American Safe Climbing Association deliberately declined to publish a form letter for this comment period, because agencies discount duplicate submissions. Every comment filed had to be written from scratch, by someone who cared enough to do it. We wrote three, one per agency, each addressing that agency’s specific provisions.
The comments, in full
These are the complete texts as submitted to regulations.gov in August 2026. They are public record. We are reproducing them here so other climbers can see what a comment on this subject actually looks like.
Bureau of Land Management
Docket BLM-2026-0034 (BLM Manual 6340, Management of BLM Wilderness)
I am a rock climber of more than thirty years and the owner of The Canyon at Pond Creek in Bledsoe County, Tennessee, where I have personally established 55 of the 150-plus routes at Pond Creek Crag since 2024. Crag access is managed under a memorandum of understanding with the Southeastern Climbers Coalition. I am writing as someone who places, replaces, and lives with fixed anchors as a routine matter, and who has spent considerable time thinking about how climbing traffic affects the ground it crosses.
I want to begin by acknowledging what this draft gets right. BLM’s recognition of recreational climbing as an appropriate use of public lands, and its acknowledgment that existing routes and their fixed anchors have a legitimate place in wilderness management, resolve a long-standing ambiguity. That is meaningful, and I appreciate the agency’s work on it.
My concern is with a single provision: the proposed numerical threshold defining a route as “bolt-intensive” at more than five bolts within 100 feet.
I understand the intent, which is to give field staff an administrable standard rather than a subjective one. But bolt density is a poor proxy for wilderness impact, and in my experience it is close to uncorrelated with the impacts that actually matter.
The variables that determine a climbing route’s footprint are the approach corridor and the terrain the route crosses. A route protected entirely by natural gear may require an approach through a riparian zone, a social trail cut into an unstable slope, and the systematic cleaning of vegetated crack systems that support lichen, moss, and nesting habitat. A bolt-protected face route on blank stone, approached on bedrock or an established trail, may disturb almost nothing living. Under the proposed threshold, the first route passes and the second is flagged. That ranking is inverted relative to actual ecological impact.
The threshold also creates a perverse safety incentive. A developer working near the limit has reason to run protection out farther than good practice would suggest, and reason to avoid the redundant anchor configurations that current stewardship standards call for. A five-bolt ceiling in 100 feet is not a generous allowance on steep or featureless terrain. Encouraging longer falls in remote wilderness settings, where rescue is slowest and consequences are highest, is not a result the agency wants.
Finally, a fixed numerical rule will not survive contact with the range of rock types on BLM land. Five bolts in 100 feet means something very different on Utah sandstone than on Sierra granite.
Recommendation: Remove the numerical threshold and replace it with a qualitative standard oriented to actual impact. I would suggest language along these lines:
“Fixed anchors are essential components of a climber’s safety system and allow safe, sustainable access to vertical terrain. In wilderness, they should be used sparingly. Climbers should favor natural protection where it is available and adequate, avoid establishing high-density sport-style routes that diminish wilderness character, and travel on durable surfaces during approaches to avoid resource degradation.”
That standard asks the right question, which is what the actual effect on wilderness character and resources is, rather than counting hardware.
I would also note two gaps relative to the other agencies’ drafts. First, BLM does not define what “replacement” of existing hardware includes. Replacement done properly means upgrading to modern stainless or titanium, converting to adhesive anchors where rock quality requires it, modestly relocating a placement out of compromised stone, and reconfiguring anchors to current redundancy standards. It does not mean reinstalling obsolete equipment identical to what failed. Please state this explicitly.
Second, the draft offers little operational direction on replacement authorization, preventive maintenance, or volunteer stewardship compared with the Forest Service and NPS drafts. I would encourage BLM to add language broadly authorizing anchor maintenance and replacement on existing routes, and to make clear that current practice in each unit continues until a climbing management plan or special use permit is finalized. Aging hardware does not wait for planning cycles.
Thank you for your consideration.
Matt McBride
Owner, The Canyon at Pond Creek
Bledsoe County, Tennessee
National Park Service
Docket NPS-2026-0101 (Managing Climbing Activities in Wilderness)
I have been climbing for over thirty years and have established 55 routes at Pond Creek Crag in Bledsoe County, Tennessee, a private crag I own and manage for public climbing access through an MOU with the Southeastern Climbers Coalition. I have placed, inspected, and replaced a great deal of hardware. I am writing about two provisions in the draft guidance.
First, I want to acknowledge that the draft’s recognition of climbing as an appropriate wilderness use, and its treatment of fixed anchors as something other than prohibited installations, is a genuine and welcome clarification.
On “one-for-one replacement.” The draft authorizes one-for-one replacement without defining it. Read literally, that phrase could require that a corroded 1/4-inch buttonhead placed in 1985 be replaced with another 1/4-inch buttonhead, a piece of hardware that is no longer manufactured, no longer considered adequate, and that no competent rebolter would install.
Competent replacement in 2026 routinely involves upgrading to 3/8-inch or 1/2-inch stainless steel, or to titanium in corrosive environments; converting mechanical bolts to adhesive anchors where rock quality or long-term durability requires it; relocating a placement by a few inches to reach sound rock when the original sits in a hollow flake or a fracture; and reconfiguring anchors to meet current redundancy standards. Every one of those actions improves safety and reduces the frequency of future work in the wilderness. None of them is new development.
I would ask that NPS define replacement to include modernization consistent with accepted best practices, referencing published guidance such as that of the American Safe Climbing Association.
On park-by-park authorization. Allowing each park to independently determine whether replacement requires no permit, preauthorization, or a special use permit will produce inconsistent policy nationwide and, more concretely, will leave unsafe anchors in place while paperwork moves. The people doing this work are volunteers, frequently funding their own hardware. Administrative friction does not make replacement safer. It makes replacement not happen.
I would encourage NPS to direct parks to broadly preauthorize routine replacement on existing routes, reserving individualized review for new route development. Relatedly, the expectation that each replacement proposal be communicated to the park will become burdensome at any crag with meaningful hardware volume. A standing authorization with periodic reporting would accomplish the agency’s tracking objectives at a fraction of the cost to both sides.
Until a climbing management plan or special use permit is finalized for a given unit, existing practice should continue rather than defaulting to a more restrictive posture.
Thank you for the opportunity to comment.
Matt McBride
Owner, The Canyon at Pond Creek
Bledsoe County, Tennessee
U.S. Fish and Wildlife Service
Docket FWS-HQ-NWRS-2026-1618 (EXPLORE Act Implementation)
I am a climber of more than thirty years and the owner and developer of Pond Creek Crag in Bledsoe County, Tennessee, where I have established 55 of the crag’s 150-plus routes since 2024. My comment concerns the administrative process the draft establishes for hardware maintenance.
I recognize that the Refuge System operates under a statutory framework distinct from the other land management agencies, and that appropriateness and compatibility determinations are not discretionary steps FWS can simply set aside. My comment is about sequencing, not about eliminating those requirements.
As drafted, replacement of existing hardware appears to depend on appropriateness determinations, compatibility determinations, refuge-level planning, and potentially individual permits. Applied to the question of whether climbing occurs on a refuge at all, that process is appropriate. Applied to the replacement of a single corroded bolt on a route that has existed for thirty years, it is disproportionate, and the practical consequence is that the replacement does not happen.
Fixed anchor replacement is performed almost entirely by unpaid volunteers who often buy their own hardware or receive it through nonprofits such as the American Safe Climbing Association. These are people fitting stewardship work around jobs and families. Where the administrative cost of doing the work exceeds a few hours, the work is deferred. Deferred replacement means aging hardware stays in the wall, and eventually someone falls on it.
Recommendation: Once climbing has been found appropriate and compatible on a refuge, routine replacement of existing hardware on existing routes should be broadly authorized as an ongoing activity, not re-evaluated placement by placement. Individual review should attach to new route development, not maintenance.
I would also ask that FWS define replacement, which the draft does not. Proper replacement includes upgrading to modern stainless or titanium hardware, converting to adhesive anchors where rock quality warrants, modest relocation out of compromised stone, and reconfiguring anchors to current redundancy standards. Without that clarity, cautious refuge staff may read “replacement” to mean reinstalling identical obsolete equipment, which would leave routes less safe than before the work was done.
Greater clarity on volunteer stewardship, meaning who may do this work, under what qualifications, with what reporting, would also help refuge managers say yes with confidence.
Thank you for your consideration.
Matt McBride
Owner, The Canyon at Pond Creek
Bledsoe County, Tennessee
What happens next
The agencies now review the comment record and issue final guidance. That process takes months. We will update this page when the final directives are published, and we will say plainly whether the concerns above were addressed.
If you climb on federal land, this guidance will govern the hardware you clip for the next generation. It is worth knowing what it says.
Background and detailed analysis: American Safe Climbing Association
The Canyon at Pond Creek is a 447-acre property in Bledsoe County, Tennessee, home to Pond Creek Crag and six geodesic domes. Crag access is managed in partnership with the Southeastern Climbers Coalition.
