RRC Archives

My first area of comment concerns the recreational activity of rock climbing and the management of that activity within the DBNF. Both the Draft Plan and the DEIS need to be corrected or modified in several regards due to factual errors and incomplete information in the text as currently written. My detailed comments and suggestions for text revisions regarding rock climbing follow.

The third paragraph on page 3-243 of the DEIS makes statements about rock climbing as a dispersed recreational activity that are inaccurate and thus misleading. Specifically, the next to the last sentence in the third paragraph on page 3-243 of the DEIS states that, “In 1985, there were an estimated 25 climbing routes; today there are over 1,500.” This information was apparently obtained by the USFS from the rock climbing guidebook “Red River Gorge Climbs, Second Edition” by John H. Bronaugh. According to my own tallying of climbs documented in the Bronaugh guidebook, there were actually 274 climbing routes established prior to 1985, the year in which the original Forest Plan was adopted. The Bronaugh guidebook does mention that an earlier guidebook published in 1975 “…documented about 25 of the early classic cracks.” And may be the source of the misstatement in the DEIS.

The third paragraph on page 3-243 of the DEIS also makes statements about rock climbing that could lead the reader to think that quality rock climbing experiences only exist within the Red River Gorge Geologic Area (RRGGA) when, in fact, these experiences are also found in many other areas of the National Forest surrounding the RRGGA within the Stanton Ranger District. To correct these discrepancies, the last five sentences of the third paragraph on page 3-243 of the DEIS should be separated out from the text as its own separate paragraph and should use the factual information from the Bronaugh guidebook. Also, modifiers used in the last five sentences of the third paragraph on page 3-243 such as “rapid increase of rock climbing” and “major activity” overly exaggerates the statements, making them more misleading. To be as factual and accurate as possible the last five sentences of the third paragraph on page 3-243, after being separated out as a separate paragraph, should read as follows:

“Clifflines in the RRGGA and surrounding portions of the Forest within the Stanton Ranger District are known internationally for their superior rock climbing experiences. The growing popularity of this activity nationwide has been reflected in a significant increase of the number of rock climber visits in the Stanton Ranger District and the RRGGA. Since the current Forest Plan was adopted, rock climbing has changed from an incidental recreational use to a main activity. In 1985, there were an estimated 274 climbing routes within the Stanton Ranger District; by 1998 the estimated number of routes had increased to 1,039. The number of routes continues to increase, mainly on private land within the Forest. However a small number of new routes have been approved within the RRGGA with several climber requests for new routes pending review. The increased use and demand for climbing has required closer management to protect sensitive heritage and biological resources as well as quality rock climbing experiences.”

On page 1-24 in the fourth paragraph down under the heading ISSUE 11 – RECREATION OPPORTUNITIES the DEIS states, “Rock climbing is another type of “trail” use that has grown tremendously since the 1985 Plan went into effect.” The first two paragraphs on page 3-243 of the DEIS present a more detailed discussion of trail based, dispersed recreation activities and there potential effect on the environment. Again the statements made are misleading and exaggerative. Individual rock climbing routes are not trails. However, when a climbing route or a congregation of climbing routes along a continuous portion of cliffline become established, an access trail is needed for climbers to reach the base of the route. Thus the activity of rock climbing as a dispersed recreational activity creates trails like other forms of dispersed recreation such as hiking, mountain biking, and horseback riding.

To correct the above deficiencies in the DEIS the following suggestions are made for text revisions. The referral to rock climbing itself as a type of trail use should be removed from the above referenced statement found on page 1-24 of the DEIS. Also the use of the word tremendously in this statement is exaggerative. Thus the first sentence in the fourth paragraph down under the heading ISSUE 11 – RECREATION OPPORTUNITIES on page 1-24 of the DEIS should be revised to read, “Rock climbing is another use that has grown significantly since the 1985 Plan went into effect.” To further clarify the potential environmental impact of rock climbing in relation to the issue of trails the last two sentences in the second paragraph on page 2-243 should be revised to read, “Rock climbing is another form of dispersed recreation that has caused impacts on a localized basis and places additional demand on the trail system. The effects of this activity have not been addressed on a Forestwide basis and require attention.”

There is a problematic conflict between the Desired Future Condition (DFC) of the 1.C. Cliffline Prescription Area and the Standards for managing this prescription area in the Draft Plan. On page 3-6 of the Draft Plan under the subheading Desired Facilities and Human Activities it is stated that, “Dispersed recreation (e.g. hiking, rock climbing, rappelling, bouldering, and camping) is generally allowed …”. However, on the following page 3-7, Standard 1.C-REC-2, conditions are stated that would require Forest Service approval for most if not all rock climbing, bouldering, or rappelling routes. For example Standard 1.C-REC-2 d) is particularly problematic in this regard. This standard would require that all route development activities would require approval if, “Climbing routes are located within 100 feet of a known archeological site. Adoption of this standard, as written, will create a “Catch-22” situation for climbers wanting to develop new climbing routes. In many cases the Forest Service, in accordance with Section 304 (a) of the National Historic Preservation Act, is required to withhold from disclosure to the public information relating to the location of historic and prehistoric resources. How then can any climber pursuing new route development be expected to know of the existence of such resources?

Standard 1.C-REC-4 on page 3-7 is also problematic for climbing by limiting the management of recreational activities to an ROS spectrum of only semi-primitive non-motorized, semi-primitive motorized, and roaded natural. The problem with this limitation is that mountain climbing, of which rock climbing, rappelling, and bouldering are a subset, is an activity that is characterized as spanning the ROS spectrum from primitive to urban according to the ROS Users Guide. Accordingly the standards for managing the Cliffline Prescription Area, as written in the Draft Plan, do not reflect the climbing opportunities climbers seek.

The standards proposed for the management of rock climbing, rappelling, and bouldering on page 3-7 of the Draft Plan appear to be a furtherance of the current Forest Service practice of reviewing the approval of these activities and climbing routes on a case by case, route by route basis. This “micromanagement” of climbing activities has already proven to be cumbersome for the Forest Service to implement and very frustrating to climbers. Apparently, the Forest Service has considered a climbing route as a “trail” in the DBNF as a convenience that has allowed more options for management of the activity under the framework of the current Plan. As previously stated by this commenter, individual climbing routes are not trails and options for management would be broadened if the Forest Service would abandon this mindset in finalizing the current Plan. The following approach to evaluating rock climbing in the DBNF and the data produced by this evaluation should provide a basis for considering the impact of rock climbing and thus the need for management in a different perspective. The Bronaugh guidebook segregates individual climbing routes by area. Where several climbing routes are found in proximity along a continuous portion of cliffline in a specific location, the book gives this aggregation of routes an area place name (e.g. Military Wall). Where there are more than several routes along a specific area of cliffline, the guidebook provides scaled maps of the cliffline showing the various locations of individual routes along the cliff and where access trails are located. Thus climbers consider their activities by an aggregation of routes into areas that are associated with parking areas and access trails.

To put the impact of climbing on the Cliffline Prescription Area into perspective, I have used the scaled maps in the Bronaugh guidebook to estimate how much cliffline in DBNF is actually affected by climbing. Using the maps, the length of the cliffline was measured from end to end at nineteen different climbing areas within the Stanton Ranger District that have place names given by climbers. It should be kept in mind that while some individual routes may be closely spaced (e.g. only fifteen to thirty feet apart) spacing between individual routes can be exceed one hundred feet. All of the cliffline shown on the maps was measured regardless of the spacing of individual routes, thus it is considered that these measurements provide a fair measurement of the cliffline affected. According to the measurements, the rock climbing documented in the Bronaugh guidebook affects approximately 18,835 linear feet or 3.57 miles of cliffline. In a workshop given by the Forest Service concerning making comments on this Plan, it was indicated that a cliffline width of three-hundred feet was used to estimate the total area of the Cliffline Prescription Area. Without going into the details of the math, it is estimated that rock climbing activities in the DBNF affect only 3.57 miles of cliffline out of a total 3,058 miles of cliffline. Or from a land area perspective, climbing affects only 130 acres or 0.12% out of a total of 111,205 acres of Cliffline Prescription Area in the DBNF. Looked at in this perspective, the management of climbing on a route by route basis hardly seems justified and the management of climbing on an area basis would be more practical.

Another aspect of the conflict between the DFC for the Cliffline Prescription Area and the proposed Standards for the management of climbing is that the Standards do not recognize that the affected cliffline is not always located within a designated Special Area. To create a framework in which climbing is “generally allowed” Standards should be less strict where the cliffline exists outside of a Special Area. To rectify the various conflicts enumerated above between the DFC and proposed Standards for the Cliffline Prescription Area, the Draft Plan text should be revised to provide a framework for the USFS to manage rock climbing, bouldering, and rappelling activities on the basis of climbing “areas” or zones instead of individual routes. To allow more flexibility for the management of these activities that recognizes the variations in conditions affecting the potential impact of climbing, the development of detailed Standards should be deferred to the preparation of a new Climbing Management Plan.

My first area of comment concerns the recreational activity of rock climbing and the management of that activity within the DBNF. Both the Draft Plan and the DEIS need to be corrected or modified in several regards due to factual errors and incomplete information in the text as currently written. My detailed comments and proposed text revisions regarding rock climbing follow.

The third paragraph on page 3-243 of the DEIS makes statements about rock climbing as a dispersed recreational activity that are inaccurate and thus misleading. Specifically, the next to the last sentence in the third paragraph on page 3-243 of the DEIS states that, “In 1985, there were an estimated 25 climbing routes; today there are over 1,500.” This information was apparently obtained by the USFS from the rock climbing guidebook “Red River Gorge Climbs, Second Edition” by John H. Bronaugh. According to my own tallying of climbs documented in the Bronaugh guidebook, there were actually 274 climbing routes established prior to and including 1985, the year in which the original Forest Plan was adopted. The Bronaugh guidebook does mention that an earlier guidebook published in 1975 “…documented about 25 of the early classic cracks.” And may be the source of the misstatement in the DEIS.

The third paragraph on page 3-243 of the DEIS also makes statements about rock climbing that could lead the reader to think that quality rock climbing experiences only exist within the Red River Gorge Geologic Area (RRGGA) when, in fact, these experiences are also found in many other areas of the National Forest surrounding the RRGGA within the Stanton Ranger District. To correct these discrepancies, the last five sentences of the third paragraph on page 3-243 of the DEIS should be separated out from the text as its own separate paragraph and should use the factual information from the Bronaugh guidebook. Also, modifiers used in the last five sentences of the third paragraph on page 3-243 such as “rapid increase of rock climbing” and “major activity” overly exaggerates the statements, making them more misleading. To be as factual and accurate as possible the last five sentences of the third paragraph on page 3-243, after being separated out as a unique paragraph, should read as follows:

“Clifflines in the RRGGA and surrounding portions of the Forest within the Stanton Ranger District are known internationally for their superior rock climbing experiences. The growing popularity of this activity nationwide has been reflected in a significant increase of the number of rock climber visits in the Stanton Ranger District and the RRGGA. Since the current Forest Plan was adopted, rock climbing has changed from an incidental recreational use to a main activity. In 1985, there were an estimated 274 climbing routes within the Stanton Ranger District; by 1998 the estimated number of routes had increased to 1,039. The number of routes continues to increase, mainly on private land within the Forest. However a small number of new routes have been approved within the RRGGA with several climber requests for new routes pending review. The increased use and demand for climbing has required closer management to protect sensitive heritage and biological resources as well as quality rock climbing experiences.”

On page 1-24 in the fourth paragraph down under the heading ISSUE 11 – RECREATION OPPORTUNITIES the DEIS states, “Rock climbing is another type of “trail” use that has grown tremendously since the 1985 Plan went into effect.” The first two paragraphs on page 3-243 of the DEIS present a more detailed discussion of trail based, dispersed recreation activities and there potential effect on the environment. Again the statements made are misleading and exaggerative. Individual rock climbing routes are not trails. However, when a climbing route or a congregation of climbing routes along a continuous portion of cliffline become established, an access trail is needed for climbers to reach the base of the route. Thus the activity of rock climbing as a dispersed recreational activity creates trails like other forms of dispersed recreation such as hiking, mountain biking, and horseback riding.

To correct the above deficiencies in the DEIS the following suggestions are made for text revisions. The referral to rock climbing itself as a type of trail use should be removed from the above referenced statement found on page 1-24 of the DEIS. Also the use of the word tremendously in this statement is exaggerative. Thus the first sentence in the fourth paragraph down under the heading ISSUE 11 – RECREATION OPPORTUNITIES on page 1-24 of the DEIS should be revised to read, “Rock climbing is another use that has grown significantly since the 1985 Plan went into effect.” To further clarify the potential environmental impact of rock climbing in relation to the issue of trails the last two sentences in the second paragraph on page 2-243 should be revised to read, “Rock climbing is another form of dispersed recreation that has caused impacts on a localized basis and places additional demand on the trail system. The effects of this activity have not been addressed on a Forestwide basis and require attention.”

Next, in the Draft Plan there is a problematic conflict between the Desired Future Condition (DFC) of the 1.C. Cliffline Prescription Area and the Standards for managing this prescription area. On page 3-6 of the Draft Plan under the subheading Desired Facilities and Human Activities it is stated that, “Dispersed recreation (e.g. hiking, rock climbing, rappelling, bouldering, and camping) is generally allowed …”. However, on the following page 3-7, Standard 1.C-REC-2, conditions are stated that would require Forest Service approval for most if not all rock climbing, bouldering, or rappelling routes. For example Standard 1.C-REC-2 d) is particularly problematic in this regard. This standard would require that all route development activities be reviewed for approval if, “Climbing routes are located within 100 feet of a known archeological site." Adoption of this standard, as written, will create a “Catch-22” situation for climbers wanting to develop new climbing routes. In many cases the Forest Service, in accordance with Section 304 (a) of the National Historic Preservation Act, is required to withhold from disclosure to the public, information relating to the location of historic and prehistoric resources. How then can any climber pursuing new route development be expected to know of the existence of such resources?

Standard 1.C-REC-4 on page 3-7 is also problematic for climbing by limiting the management of recreational activities to an ROS spectrum of only semi-primitive non-motorized, semi-primitive motorized, and roaded natural. The problem with this limitation is that mountain climbing, of which rock climbing, rappelling, and bouldering are a subset, is an activity that is characterized as spanning the ROS spectrum from primitive to urban according to the ROS Users Guide. Accordingly the standards for managing the Cliffline Prescription Area, as written in the Draft Plan, do not reflect the full spectrum of various climbing opportunities that climbers seek.

The standards proposed for the management of rock climbing, rappelling, and bouldering on page 3-7 of the Draft Plan appear to be a furtherance of the current Forest Service practice of reviewing the approval of these activities and climbing routes on a case by case, route by route basis. This “micromanagement” of climbing activities has already proven to be cumbersome for the Forest Service to implement and very frustrating to climbers. Apparently, the Forest Service has considered a climbing route as a “trail” in the DBNF as a convenience that has allowed more options for management of the activity under the framework of the current Plan. As previously stated by this commenter, individual climbing routes are not trails and options for management would be broadened if the Forest Service would abandon this mindset in finalizing the current Plan. The following approach to evaluating rock climbing in the DBNF and the data produced by this evaluation should provide a basis for considering the impact of rock climbing and thus the need for management in a different perspective. The Bronaugh guidebook segregates individual climbing routes by area. Where several climbing routes are found in proximity along a continuous portion of cliffline in a specific location, the book gives this aggregation of routes an area place name (e.g. Military Wall). Where there are more than several routes along a specific area of cliffline, the guidebook provides scaled maps of the cliffline showing the various locations of individual routes along the cliff and where access trails are located. Thus climbers consider their activities by an aggregation of routes into areas that are associated with parking areas and access trails.

To put the impact of climbing on the Cliffline Prescription Area into perspective, I have used the scaled maps in the Bronaugh guidebook to estimate how much cliffline in DBNF is actually affected by climbing. Using the maps, the length of the cliffline was measured from end to end at nineteen different climbing areas within the Stanton Ranger District that have place names given by climbers. It should be kept in mind that while some individual routes may be closely spaced (e.g. only fifteen to thirty feet apart) spacing between individual routes can exceed one hundred feet. All of the cliffline shown on the maps was measured regardless of the spacing of individual routes, thus it is considered that these measurements provide a fair measurement of the cliffline affected. According to the measurements, the rock climbing documented in the Bronaugh guidebook affects approximately 18,835 linear feet or 3.57 miles of cliffline. In a workshop given by the Forest Service concerning making comments on this Plan, it was indicated that a cliffline width of three hundred feet was used to estimate the total area of the Cliffline Prescription Area. Without going into the details of the math, it is estimated that rock climbing activities in the DBNF affect only 3.57 miles of cliffline out of a total 3,058 miles of cliffline. Or from a land area perspective, climbing affects only 130 acres or 0.12% out of a total of 111,205 acres of Cliffline Prescription Area in the DBNF. Looked at in this perspective, the management of climbing on a route-by-route basis hardly seems justified and the management of climbing on an area basis would be more practical.

Another aspect of the conflict between the DFC for the Cliffline Prescription Area and the proposed Standards for the management of climbing is that the Standards do not recognize that the affected cliffline is not always located within a designated Special Area. To create a framework in which climbing is “generally allowed” Standards should be less restrictive where the cliffline exists outside of a Special Area. To rectify the various conflicts enumerated above between the DFC and proposed Standards for the Cliffline Prescription Area, the Draft Plan text should be revised to provide a framework for the USFS to manage rock climbing, bouldering, and rappelling activities on the basis of climbing “areas” or zones instead of individual routes. To allow more flexibility for the management of these activities that recognizes the variations in conditions affecting the potential impact of climbing, the development of detailed Standards should be deferred to the preparation of a new Climbing Management Plan to replace the current Climbing Management Guide.

To reflect the needed shift in Plan emphasis on developing a Climbing Management Plan as the principal tool for the management of climbing and related activities, 1.C-Objective 1.A. on page 3-6 of the Draft Plan should be expanded to read, “Develop a comprehensive, Forestwide plan for managing cliffline-related recreational activities including a separate Climbing Management Plan to be relied upon for the management of rock climbing, bouldering, and rappelling.” In recognition of the fact that not all climbing occurs within Special Areas and to allow for more flexibility in climbing management options, the current wording of 1.C-REC-2. on page 3-7 of the Draft Plan should be replaced as follows, “Regulation of rock climbing, bouldering, and rappelling, by designating specific areas for these activities, will only be used to control the adverse physical and social impacts of human use. Utilize temporary closure only when Limits of Acceptable Change standards are exceeded and cannot be met through less restrictive techniques. Utilize temporary, seasonal or permanent closure only when necessary to protect sensitive biologic species, significant heritage resources, or when required to ensure public safety.” When these changes are made, the Goals and Objectives and the Standards will be in better correspondence with the DFC for the Cliffline Prescription Area.

The approach of managing climbing and related activities on an area basis instead of a route by route basis will require revision of the Standards in the Draft Plan as currently written for various Special Areas. The first Special Area where Standards related to climbing occur is the Clifty Wilderness Area. First it should be pointed out that the Standard 2.A-REC-5 on page 3-40 of the Draft Plan as currently written could be interpreted to eventually eliminate most existing climbing routes within the Wilderness having fixed anchors. This Standard states that, “… maintenance or replacement of existing approved fixed anchors is allowed.” However, only a few of the existing climbing routes within the Wilderness have gone through a formal review and approval process. To correct this error and to provide a framework for managing climbing within the Wilderness on the basis of climbing areas, Standard 2.A-REC-5 on page 3-40 of the Draft Plan should be revised to read, “ No new rock climbing areas with fixed anchors are allowed. However, maintenance or replacement of fixed anchors within existing climbing areas is allowed.” This same revision needs to be made to Standard 2.B-REC-5 on page 3-43 for the Beaver Creek Wilderness Area.

In addition to the problems with the text in the Draft Plan as previously described, the Draft Plan is also deficient in things that it does not say in relation to climbing. A more thorough analysis of climbing related management issues by the USFS would have revealed that several overall Plan goals could be enhanced if their link to climbing activities were recognized. For example most climbing areas are accessed via user-defined trails. By bringing such trails into compliance with Forest Service Standards, overall goals related to trails can be realized (e.g. on page 2-15 of the Draft Plan, GOAL 12 Provide a road and trail network, buildings and other facilities that support the Forest’s Desired Future Conditions). Another example in this regard, relates to the fact that significant portions of climbing related activities occur on private land located within the Forest Proclamation Boundary. This is possibly one of the most important issues affecting climber related impacts. Climbing access on such private property is tenuous at best. The only private land where climbing access is explicitly allowed is Torrent Falls. The climbing area known as Roadside is one of the most popular sport climbing areas in the Stanton Ranger District. Rumors have been circulating that this property may soon be sold to new owners who would prohibit climbing access. Closure by private landowners of an area such as Roadside could increase impacts at existing climbing areas located on Forest Service land by shifting use from private to public land. Including an Objective of acquiring of climbing areas on private land could mitigate the potential for shifting impacts from public to private land and could additionally serve the overall goal of reducing Forest fragmentation (e.g. on page 2-16 of the Draft Plan, Goal 13 Obtain a National Forest ownership pattern (surface and subsurface) that facilitates management efficiency and supports the Forest’s Desired Future Conditions).

On page 2-14 of the Draft Plan, equestrian and OHV interests are provided with a distinct sub-goal under Goal 7. It is curious that the international renown of superior rock climbing in Red River Gorge is mentioned in the DEIS but not in the Draft Plan. To rectify this and other deficiencies as discussed in the previous paragraph, specific sub-goals and objectives for climbing need to be added under Goal 7 on page 2-14 of the Draft Plan. It is suggested that these climbing specific sub-goals and objectives read as follows:

GOAL 7.5 Maintain and expand world-class rock climbing opportunities.

Objective 7.5.A. Where user defined access trails to existing rock climbing areas occur, upgrade or replace those trails to achieve compliance with Forest Service Standards.

Objective 7.5.B. At sites where conflicts between rock climbing and heritage resources have been identified, conduct additional archeological investigations and/or provide mitigation to resolve the conflicts.

Objective 7.5.C. Identify and develop new rock climbing areas within the Red River Gorge Geologic Area.

Objective 7.5.D. Identify and develop new rock climbing areas outside of the Red River Gorge Geologic Area.

Objective 7.5.E. Identify and evaluate existing rock climbing areas on private property within the DBNF Proclamation Boundary for potential acquisition.

The above completes my comments related to rock climbing.