Sonnie Trotter climbs Iconoclast in Joshua Tree National Park. PC: Andrew Burr
Four federal land management agencies have released draft guidance implementing the EXPLORE Act, legislation passed in 2025 that directed agencies to recognize recreational climbing (including the use of fixed anchors) as an appropriate wilderness activity. This draft guidance will revise existing policy and regulation.
These proposals will influence how climbing is managed on public lands for years to come, and climbers have an opportunity to help shape the outcome through the public comment process:
Public Comment Deadline for National Park Service, Bureau of Land Management, and U.S. Fish & Wildlife Service: August 14, 2026
Public Comment Deadline for United States Forest Service: July 17, 2026 (extension pending)
Here’s what you need to know.
National Park Service
Comment Deadline: August 14, 2026
The National Park Service (NPS) has issued two complementary draft documents: revisions to climbing-related provisions in Director's Order 41 (policy) and to climbing-related provisions in Reference Manual 41 (implementation guidance). Together they establish a framework for wilderness climbing across all national park units, recognizing rock climbing, mountaineering, canyoneering, snow and ice climbing, and caving as legitimate wilderness uses. Via ferrata, slacklining, and highlining are explicitly excluded and governed separately.
WHAT'S POSITIVE FOR CLIMBERS
Fixed anchors — bolts, bolt hangers, rappel rings, and removable gear left in place — are not treated as prohibited "installations" under Section 4(c) of the Wilderness Act.
Authorization for new or replacement anchors does NOT require a Minimum Requirements Analysis (MRA), a significant departure from prior practice that should streamline approvals.
Continued use and one-for-one maintenance of routes existing before January 4, 2025 is presumed compatible with wilderness character without additional analysis.
Park superintendents retain case-by-case authority in parks without a completed Wilderness Stewardship Plan, preventing an authorization vacuum while plans are developed.
THINGS TO CONSIDER
New fixed anchors require a Special Use Permit (SUP) submitted in writing to each park — a permit-by-permit process with no guaranteed review timeline.
The guidance characterizes "bolt-intensive face climbs" as incompatible with wilderness preservation, a standard that is not precisely defined and may be applied inconsistently across parks.
Fixed equipment — fixed lines, crevasse ladders, and similar items left in place — remains a Section 4(c) installation requiring a Minimum Requirements Analysis (MRA), a distinction the NPS holds firm. Emergency placements are allowed without prior authorization but require post-incident reporting to the park.
Bureau of Land Management
Comment Deadline: August 14, 2026
The Bureau of Land Management (BLM) has incorporated its climbing guidance directly into BLM Manual 6340 (Management of BLM Wilderness) as new Section 1.6.C.13.f, covering bouldering, rock climbing, mountaineering, canyoneering, caving, and ice climbing. The guidance establishes a "casual use" framework that determines when fixed anchor placement requires no prior BLM authorization, making it structurally distinct from both the NPS and Forest Service approaches.
WHAT'S POSITIVE FOR CLIMBERS
The casual use framework offers meaningful day-to-day flexibility: anchor activities meeting the criteria proceed without formal approval.
Notification (10 days advance, by email or letter) is strongly encouraged but not required, reducing process burden for routine placements.
Fixed anchors meeting the casual use criteria are not treated as Section 4(c) installations.
Pre-existing routes (pre-January 4, 2025) are generally compatible with one-for-one maintenance or replacement without power tools.
Commercial SRP holders may maintain existing anchors, though new placement by commercial outfitters is not permitted.
THINGS TO CONSIDER
To qualify as casual use, a placement must involve five or fewer anchors with no less than 100 feet of separation (in any direction) from other human-placed objects.
Routes with more than five anchors, or those in areas with existing infrastructure closer than 100 feet, fall outside casual use and require formal BLM authorization — potentially including a Minimum Requirements Analysis (MRA) and NEPA review.
This threshold may be workable for single-pitch crags but could effectively prohibit new route development on multi-pitch climbs, technical faces, or dense areas without going through an authorization process.
Fixed equipment (fixed ropes, ladders, slacklines, cables) requires MRA and NEPA. Field Offices are encouraged but not required to develop Climbing Management Plans.
United States Forest Service
Comment Deadline: July 17, 2026 (extension pending)
The Forest Service issued a single, comprehensive new directive — FSM 2355 ("Climbing Opportunities on National Forest System Lands") — covering both wilderness and non-wilderness National Forest System lands. It is the broadest of the four guidances in geographic scope, applying to the entire NFS land base. The 30-day comment period opened June 17, 2026; an extension request is pending, but as of now the deadline is approximately July 17, 2026.
WHAT'S POSITIVE FOR CLIMBERS
FSM 2355 creates a clear two-track structure distinguishing wilderness from non-wilderness lands, with less restrictive requirements outside wilderness.
Fixed anchors are generally not treated as Section 4(c) installations when limited in scope and function and consistent with an approved Climbing Management Plan (CMP).
The directive has notably stronger Tribal consultation and cultural resource provisions than any other agency's guidance, including required Section 106 NHPA review and Tribal consultation before CMP finalization.
THINGS TO CONSIDER
Via ferrata is explicitly excluded and separately authorized, providing a clean delineation from standard climbing.
The Forest Service places CMPs at the center of nearly every authorization decision in wilderness, but the directive does not specify what happens where no CMP exists — likely the majority of Forest Service wilderness at the time of issuance.
The directive states that fixed anchor retention and replacement in wilderness "must be consistent with the applicable climbing management plan," which could be read to prohibit maintenance of existing anchors where no CMP is yet in place.
Unlike the BLM (casual use framework) or the NPS (superintendent interim authority), FSM 2355 leaves a procedural gap with no default authorization pathway.
The directive does not establish an individual permit or notification process analogous to the NPS SUP or BLM notification system.
U.S. Fish & Wildlife Service
Comment Deadline: August 14, 2026
The U.S. Fish & Wildlife Service (FWS) issued its guidance as a memorandum from the Director to Regional Directors 1–8, covering the National Wildlife Refuge System (NWRS) and, secondarily, National Fish Hatchery System (NFHS) lands. This guidance is structurally different from the others: climbing on refuges is not presumed appropriate and must earn its place through a sequential evaluation process rooted in the FWS's wildlife-first mission. Rock climbing is not known to occur on any NFHS lands, and any such use there would be discretionary.
WHAT'S POSITIVE FOR CLIMBERS
The FWS guidance provides, for the first time, a defined pathway for climbing to be authorized on refuge lands — prior to the EXPLORE Act, no formal process existed.
Fixed anchors — where climbing is determined compatible — are not treated as Section 4(c) installations and will not require a Minimum Requirements Analysis (MRA), consistent with the EXPLORE Act.
Pre-existing routes (pre-January 4, 2025) are explicitly preserved under the EXPLORE Act's protection.
Incompatibility determinations must be elevated to the Regional Director and ultimately the Director's office for review, providing an administrative backstop against arbitrary closures.
THINGS TO CONSIDER
Climbing must pass two sequential gatekeeping steps before any anchor placement can be addressed: first an "appropriateness determination" under the Refuge Administration Act, then a separate "compatibility determination" with public comment.
On any refuge without existing climbing, the process to begin authorization is lengthy and uncertain.
FWS and wildlife advocates will note that this framework appropriately puts wildlife and habitat protection first, which is the statutory mandate of the refuge system.
Commercial guiding requires a Special Use Permit (SUP) with stipulations addressing wildlife protection, group size, seasonal closures, and regulatory compliance. Fixed equipment and motorized equipment for anchor installation remain Section 4(c) installations requiring an MRA in wilderness. Managers may modify, restrict, or discontinue climbing use based on monitoring.
How to Submit Your Comment
While the four agencies have taken different approaches, each proposal will influence how climbing is managed in wilderness areas for years to come. Whether you support or oppose specific provisions, thoughtful comments from climbers can help ensure agency decision-makers understand how these policies affect recreation, stewardship, and access. Visit regulations.gov to find each agency's docket and submit feedback before the applicable deadline.
