Access alert at Red Rocks. We are not the ony ones!

Issues related to climbing access and safety.

Access alert at Red Rocks. We are not the ony ones!

Postby rimfounder » Wed Jul 04, 2007 6:43 am

By the way it is never too late to offer input to those that govern. Even after the comment period.
It alway feels good to make a difference too.

Attached is a response letter by Andy Carson to BLM, which expresses the sentiment of many Red Rock climbers, and also that of the Access Fund, to the Proposed Wilderness Management Plan's strategies for controlling climbing at Red Rock. The Plan, itself, may be viewed at .

If you'd like to express comments to BLM, please email a letter (even a short one will be fine) to the BLM director James Sippel ( by Tuesday, June 12 at midnight, stating your views. I'd like to see less bureaucracy for rock climbers at Red Rock, and this letter-writing campaign will give us a chance to influence what rules we must abide by during the next decade.

Feel free to forward this email to other climbers.

Many thanks!
Joanne Urioste

----- Original Message -----
From: Andrew Carson
To: Joanne Urioste

Hi Joanne -- I pasted my letter at the end, and I think it'll go in that way, more or less as you see it. Probably not till tomorrow, though, so I can look it over one more time. Thanks alot for your feedback and input, andI hope there are many responses for the BLM to absorb. If we don't beat on the door they definitely aren't going to change anything, so here's to trying.
And of course use it any way you might want (true for anyone). The more the merrier. AC

June 7, 2007

To: BLM, Las Vegas Field Office

Re: La Madre Mtn Wilderness & Rainbow Mtn Wilderness Management Plan

Greetings, BLM;

While we are disappointed in your response to our request for an extended comment period for the above-mentioned plan, we are taking this opportunity to share with you some observations and ideas regarding the proposed action outlined in your May 11, 2007 document.
First and foremost, we are very gratified that the BLM has at last taken steps to resolve the roadblock that has forestalled so many recreational opportunities on the lands in question. We are most concerned with rock climbing and the part of the management plan addressing that activity, as we have been regular visitors to the Red Rocks and Spring Mountains for many years. The future of hiking and technical climbing is therefore especially important to us.
It might be best to work through the pertinent section on rock climbing and to address areas of concern as we come to them. In some instances, we might only be raising questions to clarify direction or intent. As well, in other instances we'd like to point out sections that we believe need further thought, analysis, and input from the climbing public. Then, in conclusion, we can make some general comments that will put a wrap on our overall reaction.
In the second paragraph of the Rock Climbing section it is stated that a climbing inventory of routes will be maintained by the agencies. We have real concerns with this idea. Even the many guidebooks available to climbers are incomplete, as some climbers only share their new route development by word of mouth. Other climbers are quite low key and tend not to share much information on their activities at all, and these are only two examples of how a worthy route might not be well known enough to appear in a guide. Guides are also only the best effort of the author to cover a vast amount of information in an extremely complex and diverse climbing environment. Do the agencies feel they actually have the staff and funds available to maintain an accurate and complete "inventory" for these lands? It seems doubtful. With the elimination of the complete ban on fixed anchor placement, we can be sure that new route development will accelerate. Can the agencies keep up with this anticipated activity? And how will you address a situation in which a route is brought to the attention of those responsible for the inventory, a route put up years ago, but not previously "registered"? This will happen with some frequency, in our estimation. The fear is that a route will be deemed a "rogue" or illegal route if it isn't included in the inventory. Such an outcome would likely result in any fixed anchors being removed, thus destroying a valuable climbing resource. That outcome would be unfortunate, and it is one we'd like to avoid. That kind of agency action also serves to undermine trust and communication between the public and land managers, as it is viewed as unilateral, arbitrary, and unwarranted, especially if it is solely based on whether or not a route is included in such a list. "Buy-in", then, by climbers, is undermined, leading to conflict and further management problems.
We are in general agreement with the method outlined for replacing fixed anchors. Many older placements were installed before climbers had the knowledge and equipment available now. In addition, sandstone is an ever-changing medium, and climbers should be able to replace anchors to maintain an acceptable margin of safety in all circumstances. This section will help in that regard.
In terms of New Fixed Anchors, the proposal becomes unduly complicated, but at least we are moving in a direction where route development can take place and where climbers can make decisions regarding safety. So, in terms of Permit 1, we cannot support the proposal that no fixed anchors be placed within the first 100 feet of the base of the cliff system. What is the point, really, in such a stance? We can round up countless highly regarded Red Rocks routes that include bolts or fixed gear in that first 100 feet, placements that are critical to the route's use and enjoyment. This is an arbitrary and irrational proposal that is divorced from the real world of climbing, and as such it has no place in a climbing management plan. It's nit-picky and interferes with a climber's ability to develop quality climbs, and serves no purpose that we can identify.
It also raises troubling safety issues stemming from the plain facts of the physical nature of rock climbs and the equipment used to ascend them. Anchors depend on natural features and stances. Climbers depend on ropes. A quick review of past issues of Accidents in North American Mountaineering will highlight the many injuries and deaths caused by lowering off of the ends of ropes that tend not to be any longer than 200'. By using a 100' limit you are encouraging anchors to be set at inconvenient and dangerous locations.
The same observations apply to the second bullet point about "three or fewer fixed anchors on a climbing pitch above 100 ft from the base of the cliff system". It is an idea that does not address real-life climbing pitches as they exist in the real world. Again, what is the point here, in getting into such detail, when every specific pitch has its own problems and needs in terms of protection? Not only is it an unnecessary intrusion into the climber's decision-making process, it is also an added management burden for those charged with that task. As we noted earlier, we wonder about the ability of agencies to fully implement this proposal, partly because of details like this one.
We also believe there are problems with the phrase "base of the cliff system", which we'll address later, under Definitions.
The final point about anchors for rappel descents is unclear. How would agencies address fixed anchors placed for descent of a route that exists right now, such as Crimson Chrysalis? It begs for a different way to get down so parties are not rapping over climbers on the route, and it doesn't seem fair or sensible to put these new anchors supporting a longstanding and extremely popular route into the 'count', should that particular (and peculiar) idea end up in the plan.
As to Permit 2, we would again point out that the "100 ft from the base" concept has no value or utility for either category, and we think it should be dropped from the proposal in both instances. While we cannot read people's minds here, it does seem apparent that there's some attempt in this proposal to identify and separate "sport" routes, and generally short ones, from longer "trad" climbs, with these two types of permits. It is a distinction that serves no purpose for the management goals specified in the document, and this "100 ft" concept ought to be omitted. As before, we also find the specific number of fixed anchors on a pitch to be intrusive and counterproductive, given the stated management goals of the agencies.
We find the application and approval process very confusing, complicated, and difficult to understand. With no paragraph breaks, it is hard to know what prescriptions apply to which permit. For example, does the sentence "Only one permit application maybe made per person" pertain solely to type 2 permits? That's our 'take', but it is really unclear. But in any event, we then come to the step in which "five permit applications will be drawn at random for evaluation". In this process, someone might never see their application come up for review, and another might have their routes approved several times, even consecutively. It is simply unfair and something of a crap shoot, and what is achieved in terms of addressing applications? Efficiency? Timeliness? Equality between applications? We see no value at all and wonder why applications wouldn't be addressed in the order that they are received. This also seems to preclude any sort of quality control or even the potential for good judgment.
Other parts of the criteria have a considerable number of subjective factors, the importance or understanding of which vary greatly from individual to individual. For example, one bullet point says "Routes that follow an obvious feature or a direct line on the path of least resistance on a wall would be favored compared to indirect routes or routes that end in the middle of a face". Indirect, direct, path of least resistance, obvious ---- all are totally subjective notions that really should be beyond the purview of management and left up to the climbers themselves. Time and later parties who try the route will determine the its enduring value. Then, in terms of public input, how would that be solicited and included? The Red Rocks attract national, indeed international, attention, and we would all like to be part of the process. Practically speaking, how would the agencies achieve such a wide participation? Not doing so would result in a less than objective, fully public review of a proposed route, and it would undermine the goals of this proposal.
We have no problem with the list of rules that apply for all new fixed anchor placements or replacements, though we wonder why #1, "If placing traditional gear is possible, etc." is included. This would seem self-evident and is generally accepted by all climbers. This is also a case were "good intentions" could lead to the worst possible outcome. By placing such rigid guide lines you are opening up the potential for unintended abuse. As we know there are some people that we would characterize as extremists who will climb something with inadequate "protection" out of some warped sense of "traditional" morality. Do 2 "rp's" on a 100' climb preclude the use of bolts?
As a general observation, it would seem true that the simplest formula for a climbing management plan would have the most utility and flexibility for both land managers and the climbing public. As a plan descends into more and more detail, it only generates questions about specific applications of the rules from one climb to the next. It will bound to be unsatisfactory in this regard, generating confusion and misunderstanding, and again, undermining climber 'buy-in'.
In the final section of the proposal there is a list of canyons with an exact, specific number of fixed anchors that can be added and that presently exist. We find this a curious section and question both the accuracy of the number of fixed anchors now in place as well as the method by which a projected number of new additional anchors came about. We do know that the BLM spent many thousands of dollars under a contract with an outside entity to make a survey of existing anchors, but we have no way of knowing how accurate these figures are. It will be difficult for the climbing community to accept restrictive numbers of fixed anchors if some of the reasoning behind the restrictions comes from a somewhat obscure study.
But, we do question the specific numbers allotted to each canyon. Why, for example, can First Creek have 417 new anchors, while Mud Springs can have only 164? There is no criteria or objective manner for coming up with these numbers, and they serve no purpose for achieving the management goals of the agencies. We can probably live with the "Total of 1,680 potential additional fixed anchors", if the strictures for each specific canyon are dropped and if it is definitely stated that the number applies only during the life of the plan, which is ten years. Otherwise, we would strenuously object to any such number, as it would severely limit climbers of the future, sooner or later, just as is the case now. Here we would like to bring up a point about the longevity of cliffs vs. climbs vs. management plans. Anchors of all varieties have a finite life span. This may be longer or shorter than that of the climb they are on. It is almost certain that they will last longer than any management plan. A few what ifs to consider are these: what if a natural anchor disappears? Can it be replaced? What if a natural feature of the rock falls down or breaks, thereby eliminating a climb? Is that number of anchors allowed to be replaced elsewhere? What if a climb is abandoned or forgotten about or overgrown with cacti or inhabited by endangered toads? Can those anchors be used elsewhere?
We're in agreement with the "rules that apply for all climbing activity", except for #3, "prying rock out of place is not allowed", because it is vague and subject to individual interpretation. As a practical matter, any rock that has a likelihood of becoming a lethal falling object should be removed from a climb, whether it involves prying, rolling, lifting, setting aside, carrying off, levitation, legerdermain, or magic. This is often impossible for many reasons, so rockfall will always be one of the serious objective hazards that climbers must accept. Still, a loose chockstone that, with a little prying, can be dislodged and then disposed of should be dealt with by the first ascent party, or subsequent parties, taking all necessary care and recognizing all possible consequences when doing so. Not to act in this manner is irresponsible and dangerous.
Earlier we noted problems with the phrase "Base of the Cliff System" and felt it was best addressed here, in Definitions. We find this particular wording too vague and subjective, and not easily applied in a practical situation. Where one or another party might start belaying could vary by hundreds of feet. As well, it can change from place to place along the bottom of the same cliff. The need for this definition is incorporated in the proposed permit types, but we think it could be eliminated through a simplification of the proposed permit system.
We have the sense that, viewed from the same perspective as this document, a possibly simpler method of fixed anchor management can be achieved by calling "Permit 1" routes "Traditional" (trad) routes, and "Permit 2" routes "Sport" routes. Trad routes can and do utilize fixed anchors but primarily depend upon clean protection systems, well understood and recognized by the climbing community. Thus, fixed anchors are "incidental" to other methods of safety on such climbs, regardless of the length of the climb and regardless of whether or not a placement is within 100 feet of the "base" of the cliff. In addition, the number of fixed anchors depends upon the nature of each particular pitch and avoids the awkward notion that only a certain specified number can be placed per pitch. Then, "Permit 2", or "Sport" routes, will rely substantially or wholly on fixed anchors, and the relationship to the "Base of the cliff system" is moot. Length of a climb will have no bearing on which permit is appropriate.
If this approach were taken, the whole climbing management issue would be streamlined and simplified, a great advantage both for agencies and climbers.
In summation then, we would like to underline the following points:
1. A climbing inventory, to be useful, must be complete. We think this goal is difficult if not impossible to attain on a timely basis. We do believe new climbs can be incorporated, and existing climbs can be included as identified through guidebooks, reports of first ascensionists, and other methods, and, over time, perhaps when the next management plan is addressed in ten years, we'll have a valid and comprehensive inventory. It is a document that will develop over time and is unlikely to be useful if it is created in a hasty way.
2. The details of the permit system, is complex, subjective, and hard to apply to the many practical route proposals for which it must function. We would suggest the simplified definitions we describe above.
3. The total number of fixed anchors might be acceptable, but only if it applies specifically to the life of the present proposal, ten years. If it were dropped entirely, we might find that we are creating a plan that, with minor adjustments, will be useful for many future revisions.
4. Overly rigid guidelines lead to unintended consequences and preclude the adoption of the superior technology and management practices of future climbers and land managers. Such a detailed approach may also place the agencies in a position of liability, in that the rules as they are proposed will inevitably set up unsafe situations. Injured parties may choose to bring actions based on the fact that the 'rules' provided insufficient safety margins.

We appreciate the opportunity to share our thoughts with the agencies charged with managing these wilderness areas, and we look forward to continuing participation to refine this proposal so that we can achieve the most practical, simple, and useful document for climbers now and in the future. We also recognize the fact that it is a groundbreaking effort that will be examined by other land management agencies that are facing many of the same questions when it comes to climbing activities in their areas. Thus, we hope our efforts result in a thoughtful plan serving both the management goals of the agencies involved as well as the needs of the climbing public whose lands these ultimately are.


Andrew & Nancy Carson
Box 709
Wilson, WY 83014
307 733-4442
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