ATTACHMENT 2

SYNTHESIS OF PUBLIC COMMENTS AND RESPONSES TO SPECIFIC PUBLIC COMMENTS ON THE DCMP SYNTHESIS OF PUBLIC COMMENTS ON THE DCMP

New Route Development

Most reviewers felt new route development and fixed protection were not problems in ANP, and that the recommended action was an overreaction. These practices would be better managed or controlled through education, camouflage, committee review, zoning, and prohibiting power drills. Regulation would not work. Adventure climbing with these practices should be preserved. Fixed protection for resource preservation (belay or rappel stations) is a good idea. Climbing impacts are small compared with carriage roads, paved roads, and the drilled holes and iron on several hiking trails. It should be noted that there was some support for the preferred alternative from climbers and the conservation community, and some call for even stricter regulation of these practices.

Commercial Use

Although there was some support for concessions in the preferred alternative, only four reviewers represented commercial or group interests. Some of those in support of concessions were conservation groups, not commercial operators. Some reviewers did not understand completely the effect a concession would have on their operation. Many reviewers noted that individuals should have priority over commercial interests.

Group Use

Reviewers supported group reservations for Otter Cliffs. There were mixed opinions about group size and the half day reservation format. Group size was the greatest concern, and reviewer recommendations ranged from 10-20, with most above 12. Some felt the recommended size of 12 would preclude their use of the park. Several people suggested limiting group use of Otter Cliffs or other areas to weekdays only. Individual Use. There was strong opposition to a permit/reservation system. Reviewers felt such a system would destroy climbing at ANP. It was not commensurate with existing environmental or social impacts. There was some support for a nonrestrictive climber registration permit as in Alternative B.

Natural Resource Closures

Finding strong support or opposition to the preferred alternative for this issue from the comments is difficult. Several people mentioned education and facility improvements as much needed, and many said climber impacts must be kept in perspective. Cultural Resource Closures. Many reviewers did not understand the park position on this issue. Several said no evidence showed bouldering affected the structure of bridges or other visitor experiences, or why other measures would not be effective. Some support for the prohibition came from general support for the preferred alternative. No consensus was evident.

RESPONSES TO SPECIFIC PUBLIC COMMENTS

1. The DCMP should incorporate and conform to NPS 77 guidelines for backcountry recreation management. Planning objectives should be measurable. Indirect controls should be used first. NPS 77 is the NPS Natural Resource Guideline. It was used in the preparation of the DCMP and the format of the DCMP was drawn directly from it. Protection of the only truly unique climbing experience at Acadia, sea cliff climbing, comes directly from NPS 77. The NPS agrees that planning objectives should be measurable. The DCMP, with its broad scope, and the lack of information about climbing and climbing impacts, makes defining specific measurable objectives difficult. If problems develop at specific climbing areas, specific measurable objectives will be developed based on the more general objectives of the plan. Climber input will be an important component of this. The use of direct or indirect controls related to fixed protection and climber use levels will be addressed later in responses to those issues. NPS 77 provides guidance on recreation issues. NPS Management Policies (1988) are a stronger source of direction for planning, and were used as the basis for management decisions outlined in this document.
2. The DCMP's emphasis on restrictions for fixed protection is based on philosophy rather than evidence of significant resource impacts or conflict with other management objectives. The climbing plan treatment of fixed protection is based on philosophy (policy) and resource impacts. The policy comes from NPS Management Policies (1988). Resource preservation is the primary goal, followed by protecting visitor experiences. Using fixed protection and route cleaning are activities that would be considered violations of park regulations for other visitors because they have been determined to have unacceptable impacts to natural resources or natural processes. The use of fixed protection is largely irreversible. By their very nature, these resource impacts are significant. ANP proposes to manage these impacts by restricting them to certain areas, and by closely reviewing their use in these areas.
3. The text of the plan is resource protection driven but the preferred alternative is more climber driven. All route cleaning should be prohibited and fixed protection should be limited to replacement only. NPS policies are aimed at providing "natural environments evolving through natural processes minimally influenced by human actions (NPS 77)." The plan tries to balance resource protection with visitor use, but not equally. The plan emphasizes protection while accommodating some needs of climbers. While there will always be some impact or influence from use, limits established in this plan are reasonable based on existing conditions.
4. The placement of fixed anchors should be allowed by hand drill only under specified conditions. Fixed anchors should be allowed by hand drill without a permit, with options for more intrusive management control in the future. Over time, allowing the installation of fixed protection with a hand drill would result in additional climbing areas being developed with fixed protection. The effects of fixed protection are largely irreversible. The extent of fixed protection now in the park is such that managers feel it should not be allowed in new areas.
5. New route exploration should be allowed without a permit in all areas of the park where there are no known or probable conflicts with sensitive resources or specific management objectives. Climbers should have the freedom to explore new routes consistent with the resource and visitor experience objectives described in the plan. The NPS believes areas now significantly free of fixed protection and route cleaning should remain so. The permit requirement for individuals is for climbing, not new route exploration, and is designed to be easy to obtain.
6. There is little evidence that present levels of climbing use are diminishing the "wild and natural character" of the park. Additional detail about the increase in fixed protection in recent years is provided in this document. However, any development reduces the wild and natural character of the park. Development of climbing routes with fixed protection and route cleaning is no exception. The NPS believes these activities must be managed, and this includes the exclusion of them from parts of the park for resource protection and preservation of visitor experiences. Allowance is made for some exceptions where fixed protection may be needed to protect soils and vegetation at belay areas.
7. Every activity in a national park causes some level of natural resource damage. The question is: How much damage does this use cause? The damage to the rock resource is so minimal as to be insignificant. The NPS agrees with the first statement and would add to the question about how much damage. The question is: How much damage is acceptable? We disagree with the last statement. The damage is significant. The size of the holes is not the major issue here. It is the presence of them and the potential for their further proliferation. We believe that the damage caused by fixed protection and route cleaning is acceptable to a point - the point of current impacts and not much more.
8. Restricting fixed protection and route cleaning to "already affected areas" creates sacrifice areas. The park's objective is to keep climbers out of pristine areas. Zoning for levels of recreational use or for "no new bolts" as at Pinnacles National Monument could be done instead. The park has proposed a "no new bolts" zone defined as the area of the park not already affected by fixed protection. This decision is based on concerns about the number of climbing areas already affected and the level of development at these areas (we believe we have adequate though incomplete knowledge). It is also based on the potential for proliferation of fixed protection to many new and small areas. As at Pinnacles National Monument, most of the existing climbing areas will probably not be in the "no new bolts" zone. The park does not intend at all for "already affected areas" to be sacrifice areas. Any proposals for new route development in these areas will be carefully considered, especially for cumulative effects. The park does not intend to keep climbers out of pristine areas. It intends to keep those areas as pristine as possible by requiring climbers to follow certain practices in those areas, namely refraining from using fixed protection and cleaning routes.
9. Permits for the placement of fixed protection will have negative consequences. Fixed protection is a consumptive resource use. Scientists wishing to conduct consumptive research must apply for a permit that is carefully reviewed. Fishing and campfires also require permits in most circumstances. Given the park's selected alternative for fixed protection, this requirement is entirely appropriate. We do not think that administering it will be difficult as the park prepares to commit to more active management of climbing, although there are concerns about the administrative workload associated with climbing management. Climbers make decisions related to safety based on many of constraints and conditions. We do not believe another constraint will be a problem, especially because climbers should know of it before climbing activity. The placement of fixed protection must be thought out in advance and a permit obtained. Adventure climbing with the option of fixed protection will no longer be possible. This kind of climbing experience must be sought elsewhere. This park is too small to provide for all kinds of climbing opportunities.
10. Climbers cannot replace fixed anchors in the middle of a climb for safety. Climbers always have the option of backing off. None of Acadia's climbs are so long that a climber is truly committed to finishing a route. Because routes are so short, we doubt many climbers are routinely going to climb any of Acadia's routes carrying the necessary equipment to replace fixed anchors.
11. Climbers using pitons may be reluctant to leave them in place when leading a new route in the traditional adventure climbing style. This practice developed as an aspect of clean climbing because removal of pitons causes more damage. For the purposes of the climbing plan, pitons are considered as fixed protection. Their installation damages rock and if left in place they are really, fixed protection. The use of pitons, even if removed, will be prohibited in climbing areas not already affected by fixed protection. Climbing should be truly clean in these areas.
12. New routes with bolts and significant cleaning are being developed in small out-of-the-way places. Easier routes will not be done. These areas will become the sole domain of a few climbers. Plenty of rock exists outside Acadia for new routes. All new routes using fixed gear or cleaning should be reviewed by committee. The NPS agrees.
13. Some areas should be added to the nine listed cliffs. The NPS is prepared to discuss what is included in the "already affected areas" and what is not included. The listed areas are a starting point. The NPS does not think any unaffected areas should be included however.
14. Fixed protection should not be allowed in sea caves based on the Federal Resource Protection Act and the Regulations on Cave Management (CFR Part 37). We are very concerned about the use of fixed protection anywhere along the seashore because it is a high visitor use area and may contain unique formations such as caves. Most of the seashore falls within areas not already affected by fixed protection and the plan will keep them there. Limited further fixed protection may be considered for the Great Head area however, with the cave act and regulations in mind.
15. There is no conflict between traditional and sport climbers at Acadia, no bolting wars. Climbers have managed themselves well. There is no need for a committee to regulate bolts. We are thankful that this has generally been the case. Still, the incremental effects are beginning to be felt and the time has come to manage the climbing and fixed protection in the park proactively before we have to manage reactively. The committee will recommend and the superintendent will decide.
16. New route development is not occurring at Acadia with sufficient intensity to warrant the cumbersome committee process recommended. The NPS disagrees. We think new route development has occurred with sufficient intensity based on the limited information described in Attachment 6.
17. A permit system for new route development gives locals a monopoly on new route development that is not appropriate for a national park. It is not our intent to give locals a monopoly on new route development, only to manage climbing. We will try to involve nonlocals in the decision-making process and accommodate proposals from them as quickly and efficiently as possible. However, a site visit will be required for every proposal.
18. Development of new cliffs should not be restricted. It alleviates pressure at more popular areas. It depends what is meant by development. If development means fixed protection and route cleaning, we believe it should be restricted. Whether it is climbing, hiking, biking or any other recreation, the NPS is not enthusiastic about developing new areas to alleviate pressure in popular ones. The NPS has a long history of development to accommodate visitors. This development contributed greatly to the overwhelming numbers of visitors causing many problems today. Creating more facilities and opportunities in the parks may create more problems than it solves. Managing what exists more intensively may be a better option. None of these decisions are easy.
19. Your biggest concern seems to be finding a solution for the diversity of styles and resulting controversy internal to the climbing community. You cannot legislate a solution. The philosophical arguments of climbing style should be decided by climbers; government agencies should not become involved. Our concern is with the protection of park resources and visitor experiences, not climbing styles. We have no interest in legislating a solution about styles. As the responsible land manager we must manage the park as directed by Congress and all of the American people. Noninvolvement in climbing issues at Acadia National Park would be abdicating these management responsibilities.
20. Climbing impacts are nothing compared with other uses such as automobiles. Concern over fixed protection and route cleaning seems senseless in ANP with its history of manufacturing hiking trails and carriage roads in the wilderness. Development takes many forms. Roads, carriage roads, and trails, including trails in ANP with iron rungs, are all developments to accommodate park use. Climbing routes with fixed protection and route cleaning are also developments. Leaving existing fixed protection intact is consistent with leaving other major developments (roads, trails etc.) intact. Restricting further development of climbing routes with fixed protection is consistent with the General Management Plan (GMP) for ANP (National Park Service 1992). The GMP states that the park is close to or at its limits for major developments. Future developments will be carefully considered, especially to gauge the cumulative impacts. This philosophy also applies to climbing.
21. Restricting new route development to nine areas stops the advancement of climbing at ANP. With little potential for new routes, new route development would cease. If climbing population grows there will be more congestion and problems. The advancement of climbing or the full development of climbing areas is not a goal of the NPS or the climbing management plan. Without a climbing plan, new route development at ANP will eventually cease because all routes are developed. With a climbing plan, this development will cease sooner. New routes can still be established if they do not include fixed protection. Establishment will be more challenging. If the climbing population and climbing use of ANP grows, we will manage climbing to control climbing problems, including congestion, and the public will be involved in the process.
22. The "adventure" climbing experience will be changed dramatically for the worse with the implementation of the climbing plan. The spirit of adventure must be preserved. The spirit of adventure climbing is an important aspect of the climbing experience that must be preserved. We believe however that it is secondary to the protection of park resources. "Clean" adventure climbing opportunities will be preserved. Other kinds of adventure climbing must be found elsewhere. ANP is too small in area and climbing resources to try to manage for a great diversity of climbing experiences.
23. New route development at Acadia is limited but the opportunity should remain for adventure climbing. We believe new routes at Acadia outside the "already affected areas" should be free of fixed protection and significant route cleaning. Within these constraints the opportunity for adventure climbing should remain available.
24. Bouldering should be allowed on carriage road and Park Loop Road bridges. There is no evidence of damage to the bridges or effects on the experiences of other visitors. Climbing is allowed on other National Register Sites including Devils Tower. The bridges are protected by federal laws to protect their structural and historic integrity. The Code of Federal Regulations prohibits "Walking on or climbing . . . an archeological or cultural resource . . . " (see Attachment 2, DCMP, page 3). Comparison of ANP bridges (climbing not permitted) to Devils Tower (climbing permitted), both National Register Historic Sites, is inappropriate. One is a natural rock formation and the others are manmade structures. We doubt climbing is permitted on any manmade structures on the National Register. The State Historic Preservation Officer has expressed concerns about the possibility of structural damage and preserving the visitor's visual experience of the bridges (Earl Shettleworth, letter of February 10, 1997).
25. Prohibiting the use of chalk would reduce impacts of climbers on bridges. Chalk use is not the issue for bridges. See the rationale above.
26. Group use only causes problems on a few weekends a year. Education and development of additional climbing areas in and near the park are a better solution. Our experience and that of frequent users is that group use problems occur more often, including weekdays. Encouraging use of additional climbing areas is an option, although there are not many good beginner areas. South Bubble is perhaps the next best option to Otter Cliffs.
27. The definition of a group is a potential problem. The NPS agrees that the definition of a group can be difficult. It is our intent to manage organized groups, not groups of friends.
28. Educational groups should be willing to undergo peer review and quality assurance. Accreditation or certification should be required. This is an issue of concern to the NPS as well for safety reasons. We would like to see some standards with which to judge the qualifications of climbing leaders. We are ready to work with the "group " community to do this.
29. Union of International Alpine Guides of the Mountains and American Mountain Guides Association guides should be allowed access with limited bureaucratic impositions. The NPS agrees and is ready to work to determine what those impositions are.
30. Incidental business permit fees should be charged to all commercial groups. Insurance requirements should be the same for all. The NPS agrees all groups should be charged and will try to reach all such commercial groups. We are in fact required to do this. Insurance requirements are the same for all.
31. Group use size should be 10 people (or 15, 16, or 20) or should be higher in the off season. Some leaders can control larger groups well. A group size of twelve eliminates our use of Otter Cliffs. Whatever the group size limit is, it will affect some groups more than others. Larger groups do have greater impact on resources and other visitors. We think a size of 12 is reasonable, and because of potential impacts to resources should be the same year round. No doubt some leaders are better than others at managing groups, but managing climbing based on leadership capabilities is difficult. With the reservation system proposed for Otter Cliffs, larger groups can split the day between climbing and another activity.
32. Use permits and reservations should not be required for individuals at this time. The NPS agrees that reservations are not needed now, except for groups at Otter Cliffs, but recognizes they may be needed at some future date. Use permits were a part of Alternative B in the DCMP and were recommended by several reviewers. We would like to institute an easy-to-use system for this to help educate climbers and monitor use levels.
33. Formation of a climbing advisory committee is a good idea. The NPS believes continued climber participation is very important to the successful implementation of the climbing plan. There are many unresolved issues to be worked out.
34. The advisory committee will have no credibility if its recommendations are not approved by the park. Participation by climbers and credibility with climbers are very important, however the superintendent's concurrence with committee decisions is not automatic. Climbers must be willing to respect the superintendent's decisions. The advisory group may not be able to reach a consensus on all proposals, and its membership and attitudes may vary over time. The park is committed to considering all proposals fairly, respecting the opinions of the committee. Time and experience will tell if the committee system works.
35. Comparison of Acadia to several other major climbing areas is not a useful one in terms of guiding management response. These other areas are fully mature (little opportunity for new routes). Acadia is more usefully compared to other areas like Pinnacles National Monument and Mount Rushmore National Memorial. These other areas were the only ones to have taken climbing management to some kind of conclusion. The fact that they are developed, or fully mature, is important. The NPS however, does not feel that every climbing area must be developed.
36. The climbing plan fails to use indirect controls or explain why indirect controls will not be undertaken before direct controls to address climbing issues. Education should be tried first. It has worked in other areas. Indirect controls such as education or trail improvements are less restrictive to visitors than direct controls such as use limits or area closures. With fixed protection, the park position is clear and policy based. Fixed protection will not be acceptable in some parts of the park. Resource protection takes precedence. The effects of fixed protection are largely irreversible, and the time for trying indirect controls is past, given existing conditions. If a climbing management plan had been implemented in 1985, perhaps indirect controls would then have been more appropriate to start managing fixed protection. For individual permits, the climbing plan now recommends a more indirect approach with a free, user-friendly, self-registration system without limits. This will make education easier and help monitor use levels. For group management, existing conditions at Otter Cliffs warrant a reservation system now, a direct approach. Group size limits, another direct approach, are necessary also (based on recreation research) to continue to provide high quality climbing experiences and climbing opportunities for individuals. For Park Loop Road bridges, a direct approach of closure is required by law to protect the historic and structural integrity of the bridges. An indirect approach using education will continue to be used to encourage climbers to use existing trails, dispose of human waste properly, camouflage fixed protection and slings, avoid using belay trees that are suffering from loss of soils, and, overall, use low impact techniques.
37. Climbing issues at Acadia are inseparable from the larger issue of high visitation in general at the park. The NPS agrees and will try to manage climbing with this in mind. However, some effects of climbing, such as fixed protection, are quite specific to climbing and must be managed accordingly.
38. Acadia has a good relationship with climbers to date and it should not be squandered by heavy handed management. Until the past few years, Acadia has had almost no relationship with climbers. Climbers were free to conduct their activities in almost any manner. ANP concern with climbing issues and the development of the climbing management plan has changed the situation. We to intend to continue to develop a good relationship with climbers as it is very important to achieving the objectives of the climbing plan, but we cannot ignore our stewardship responsibilities.
39. Fickle weather makes it difficult to plan climbing trips in advance, making permit and permit and reservation systems difficult to implement, especially for individual climbers. Permit and reservation systems for individuals have been deferred to a future date pending the need for them. Coastal Maine weather is something all visitors have to deal with, and is not a reason for failing to implement a needed reservation system.
40. Acadia should support the development of a good guidebook. The NPS recognizes guidebooks can be a blessing or a curse. While the park cannot support the development of a guidebook, we believe over time the education benefits associated with a guidebook will contribute to the protection of park resources and visitor experiences. As with other publications, the NPS is anxious to work with authors to communicate accurate information about climbing in Acadia.
41. The park should consider opening the Central Slabs to climbing during the peregrine falcon nesting season. Decisions regarding closures to protect peregrine falcons and other listed species will continue to be made on the best available scientific information, and will be based on the requirements of the Endangered Species Act.
42. To close down hiking and climbing areas for two birds, especially the Precipice Trail, seems a little unbalanced. There was a time when these birds did not nest there. What if they had been shooed away from there when they first approached it? They would nest elsewhere. Hundreds more people would have access to the Precipice Trail. The NPS disagrees strongly. Our mandate is to protect and preserve natural resources and the Endangered Species Act requires us to do so. Closures are necessary. Research shows that human disturbance affects nesting success of peregrines. Climbing and hiking resume each year around mid-August in the closed areas.
43. There should be no rock climbing at Otter Cliffs. Prime scenic areas are not gymnasiums. The NPS believes climbing is a legitimate use of the park and entirely appropriate at Otter Cliffs if managed well. It provides unique sea cliff climbing opportunities not commonly available in the lower 48 States. Otter Cliffs is a prominent landmark, but in most respects is little different from other areas along Ocean Drive with many visitors exploring the rocks.
44. NPS should elaborate on its capabilities for enforcement of climbing policies set forth in the plan. Enforcement will be an important component of achieving the objectives of the plan. It will occur based on staffing and budget constraints. Low key enforcement will be the goal.
45. Problems with human waste, erosion, and belay tree damage can be solved by installing toilets, hardening trails, and installing fixed anchors. The park recognizes and is trying to mitigate various problems caused by all users. Hardening of sites is one option of many that may be appropriate in some circumstances. Under other circumstances hardening, while reducing impacts, accommodates more users and increases maintenance responsibilities. Just as building more parking lots or repaving roads makes auto use easier, climbing infrastructure improvements will make climbing easier and could increase the numbers of climbers. Hardening is not always the appropriate solution, but it is under consideration for some climbing issues.
46. Overcrowding is self-regulating. Climbers do not come to Acadia for a wilderness experience. The NPS does not think overcrowding is self-regulating. Overcrowding displaces people to other locations or times or out of the area entirely. We want to assure that if displacement of climbers occurs, it occurs by design (climbing management with climber input), not default. Acadia is surely not a wilderness, but it is a place where we hope that some wildness always remains, and visitors can encounter the park to the greatest extent possible on its terms and not those of a developed civilization.
47. Climbing in ANP does not need to be managed. Increases in use, the use of fixed protection, resource damage, and changes to the climbing experience all point to the need to manage climbing.