Pisgah Nantahala Forest Plan

mreardon

Almost ⅓ of America’s climbing is on National Forest lands. In North Carolina, on Pisgah & Nantahala National Forest alone, there are thousands of boulder problems and climbing routes on many dozens of discrete crags and boulderfields. Popular, historic, and beloved climbing areas like Linville Gorge, Looking Glass Rock, Whitesides, Cedar Rock and others are all found on the more than 1 million acres of Pisgah & Nantahala National Forest. In the Carolinas and across the country, National Forests are a significant and precious climbing resource.

Each National Forest is governed by a management plan. These plans are like the Bible for a particular forest. They guide management of the multiple uses and benefits our national forests provide, including recreation like climbing, water, wilderness and wildlife habitat, healthy and resilient forests, and sustainable management of millions of acres of undeveloped land.

Forest plans are massive documents, and a key place where organizations like Carolina Climbers Coalition and Access Fund advocate for climbing access and conservation. Importantly, forest plans are revised every 20-30 years and when they are, each National Forest is required to get input from the public in shaping a new forest plan. So, when forest plans undergo revision, it’s a critical time for us to take action, update climbing resource information, and make recommendations for improved climbing policy and management.

In 2011, the Pisgah & Nantahala National Forest (the Forest) began their forest plan (the Plan) revision, inviting an unprecedented level of public input. CCC and Access Fund immediately jumped in, working together to participate in the planning process from its first stages all the way through to the Plan’s completion earlier this year–a process that took more than ten years. Outdoor Alliance, a coalition-based outdoor recreation advocacy organization, also supported our work and joined in the planning and advocacy efforts. We also shared a seat on the Pisgah Nantahala Forest Partnership, a group of over thirty stakeholder organizations representing many different interests–timber, water, hunting, fishing, Wilderness designations, old growth forests, trails, kayaking, wildlife protection, tourism, mountain biking–that continue to collaborate on consensus approaches and recommendations for the Forest Plan. This collaboration improved our partnerships, our understanding of the many different and important values on the forest, and created support for our climbing management recommendations in the Plan.

At each stage of the planning process, CCC and Access Fund submitted formal joint comments to Forest planners, to help them update their climbing resource information, consider climbing management policies and topics such as fixed anchors, trail work and stewardship, Wilderness climbing, and natural resource protection; and generally recommend sound climbing management policy that would support balanced and sustainable climbing access for the next 20-30 years. After the Forest shared a final draft of the Plan, we also submitted comments and participated in a formal Objection process. You can review these joint advocacy statements here [link at bottom of the page].


The final plan was completed and released earlier this year. After more than ten years of work advocating for climbing via the forest planning process, we can now review and assess the plan, its climbing management components, strengths and weaknesses, and generally see some positive momentum on future work serving our beloved western N.C. climbing areas. 


Climbing is recognized throughout the newly revised plan as a positive way to connect people to the land. Connecting People to the Land is a stated overarching goal of the Plan, thanks in part to enormously increasing recreational use and our years of on-the-ground climbing conservation and advocacy work with this Forest. Geographically, climbing is more widely acknowledged and accounted for than ever, across the Forest and district by district. This acknowledgement, paired with a baseline climbing resource inventory, is fundamentally important for future management decisions. Collaboration with the climbing community on climbing management components is highlighted throughout the plan, with ‘education’ written as a primary management strategy (see Final Plan page 162, also see REC-O-09). Improving the climbing experience, including the sustainability of climbing access trails and staging areas, is highlighted in objective REC-O-09. Fixed anchors are described as “not prohibited” in the EIS Appendix A, pages A107-109. Although we had advocated for clearer policy that was generally supportive and allowed climbing fixed anchors use across the Forest, this statement that fixed anchors are ‘not prohibited’ is still significant. Our peregrine falcon management collaborations with the Forest and N.C. Wildlife Resources Commission were also positively noted in the Plan, and forest planners updated their management direction to reflect the latest, science-based practices, and our decades of successful partnership in peregrine falcon conservation.


There were several components of climbing management that CCC and Access Fund advocated for that were ultimately not included in the final plan. Clear, forestwide guidance for climbing fixed anchors, and direction for allowing erosion control mitigation and stewardship work on undesignated or non-system access routes (social trails) were not included, despite our recommendations and extensive discussions. The Forest ultimately concluded that these recommendations were not appropriate at the Plan level, and would be more appropriately addressed in a future climbing management planning process, hence their Tier 2 Objective REC-O-09 to undertake a climbing management plan.

While CCC and Access Fund generally support climbing management plans (CMP) where needed, we did not advocate for REC-O-09 or a CMP in the Plan. Climbing management plans and Forest Plans are very different in scope and purpose. CMPs are important site or area specific tools, useful for securing climbing access and managing resource impacts, especially when there is elevated use or concern. Notably, there are only three U.S. Forest Service CMPs in the entire country, and these are very focused on specific crags or areas, climbing area use patterns and resource concerns. In contrast, Forest Plans are larger and more comprehensive in scope. The information and guidance they provide is more general, laying big picture foundation pieces for management of an entire forest. Does climbing policy have a place in big forest wide plans? Yes, absolutely. Broad climbing guidance is very important, and there are decades of precedent for this approach from other National Forests in New Hampshire, Kentucky, California and Wyoming. Shoshone National Forest in Wyoming, home to the Winds and Wild Iris, is an excellent example.

Prior Pisgah Nantahala forest plans made zero mention of climbing, so Plan-level direction was a long overdue need–especially considering climbing’s widespread popularity and 70+ years of historic use on this Forest. By not providing basic climbing policy on key issues within this Plan, planners failed to address a real and growing recreational need. They effectively punted addressing this need to a future, vaguely defined, second priority CMP process. To be clear, CCC and Access Fund will certainly be involved and supportive of any climbing management planning process, if and when Forest planners have the resources and bandwidth. But ‘planning to plan’ misses the mark and won’t give our community or land managers the guidance we need now.
 

The policy most concerning to CCC and Access Fund is REC-S-19, which potentially implements pre-decisional closures of climbing areas prior to the creation of a Forest Climbing Management Plan. Additionally, the “unique habitats” described in the Standard are far too vague and could result in widespread closures of historic and important climbing areas throughout the Forest. Further, this Standard uses closure as the only management tool rather than collaboration, monitoring, and education.  We issued formal objections to REC-S-19 to the Forest Service, but our objections and recommended alternatives were not accepted. This policy remains a concern and we will vigilantly monitor how the Forest applies this recreational management standard.

The plan’s policy around climbing fixed anchors in Wilderness and Recommended Wilderness (CDW-S-05 & RW-S-13) is also very concerning. CDW-S-05 states that any fixed anchors placed in Designated Wilderness must have line-officer approval for placing new fixed anchors or replacing existing fixed anchors. This completely new requirement was not recommended by CCC and Access Fund. How the climbing community will meet this requirement and go through the line-officer approval process is not defined. This is an untested policy and process without precedent from any other National Forest. On a positive note, the Forest Plan did incorporate our suggestions that fixed anchors are not banned in Wilderness, that fixed anchors should be non-reflective to match the local rock, and that fixed anchors should be placed using non-motorized tools in Designated Wilderness.

While the new Forest Plan does not reflect all of our recommendations or hopes, we look forward to collaborating with the Forest, other stakeholders, and supporting successful plan implementation. Access Fund and CCC remain committed to our successful, ongoing partnership with this Forest, a collaboration which predates the Plan by almost three decades.  A great example of this implementation is our upcoming work on the officially approved Table Rock Climbing Access Trail. CCC, Access Fund, and Wild South will be building this trail to meet the needs of rising climbing numbers, mitigate erosion, improve rescue access, decrease unnecessary social trails, and decrease potential trampling of rare species. Join us!

Bulleted Version:

Positive Climbing Management Outcomes:

  • EIS Appendix A, Pages A107-A109: The Forest’s “Response to Comments” section reflects the work of the Carolina Climbers Coalition and Access Fund throughout the planning process. This section shows the Forest’s responses to the Access Fund and CCC’s objectionsto various aspects of previous drafts of the Forest Plan. Although not all of our suggestions were incorporated into the Forest Plan, several of our concerns were addressed while some were punted to a later Tier 2 Goal of creating a Climbing Management Plan.
  • EIS Appendix A, Pg A107: This ‘Response to Comments’ section states that the Forest Plan has not placed restrictions on fixed anchors, with the exception that in Wilderness areas such as parts of Linville Gorge, line officer approval will now be required prior to fixed anchor installation to ensure there are not impacts to natural or cultural resources.
  • Final Plan, Chapter 2, Pg 81, PAD-S-06: The Forest planners took note of our early objections and improved the wording of this standard to reflect best practices for peregrine falcon management. This updated wording on climbers positive collaboration on peregrine falcon protection was also added in the Final Environmental Impact Statement (see 3-342).
  • Final Plan Pg 123: REC-O-09 Tier 2: This Tier 2 Objective states a desire to improve the climbing experience, including adding climber access trails and staging areas as system trails that can be maintained
  • Final Plan P. 162 (also listed in many Geographic Areas within the plan): The Forest Plan places emphasis in education as a primary management tool for what is referred to in the plan as “low impact camping and climbing techniques”.
  • Climbing is recognized as an activity that people enjoy throughout the Forest Plan, and specifically listed in each Geographic Area with known climbing resources. “Connecting people to the Land” is emphasized as a goal of the Forest. Public input and collaboration with the climbing community is emphasized throughout the plan as a recreational management strategy. 

Negative Climbing Management Outcomes:

  • Final Plan: Chapter 2, Pg 124: REC-S-19: This standard potentially implements pre-decisional closures of climbing areas prior to the creation of a Forest Climbing Management Plan. This standard uses closure as a management tool rather than collaboration, monitoring, and education. The unique habitats as described are far too vague and could result in wide spread closuresof historic and important climbing areas throughout the Forest.
  • Omissions: Fixed anchors: The Forest Plan did not incorporate our suggested guidance for fixed anchor use in wilderness and non-wilderness areas despite widespread support by the Pisgah Nantahala Forest Partnership and public input.
  • The Forest did not provide any guidance allowing for erosion control or other impact mitigation on climber access trails and staging areas that are non-system or undesignated, despite practicing this progressive maintenance and restoration approach at non-climbing sites on the Forest, and despite other National Forest’s demonstrating an appropriate way to mitigate impact on non-system trail use. They are sticking with a black or white, all or nothing, system trail or non-system trail approach, where NEPA designation is the only tool. It’s an outdated, limited approach and simply unrealistic for modern recreational use of National Forests, climbing or otherwise.

Mixed Bag:

  • Final Plan: Pg 123, REC-O-09 Tier 2: At the Access Fund and CCC, we have mixed feelings on this Objective because many of the proposed attributes of this futureClimbing Management Plancould have been incorporated into this 2023 Forest Management Plan. Otherwise, we are just planning to plan and punting climbing management attributes down the road while closures outlined in REC-S-19 could be implemented. With Standards set like REC-S-19, entering into a climbing management planning process with pre-decisional closures would hinder the outcome of a Climbing Management Plan. Additionally, the Forest Plan does not outline a mechanism, timeline, point person, or scope of this future Climbing Management Plan. On a positive note, this standard states that the Climbing Management Plan’s purpose is to improve the climbing experience in the Forest. CCC and Access Fund’s work at Table Rock and Looking Glass, fixed anchor replacement work, as well as our peregrine work throughout Pisgah/ Nantahala are tangible examples of the Forest Plan component in motion and we feel that these on-the-ground collaborations are what will drive the future Climbing Management Plan.
  • Pg 273: Chapter 4: Management Areas -Congressionally Designated Wilderness CDW-S-05; This Standard states that any fixed anchors placed in Designated Wilderness must have line officer approval for new or replacement of fixed anchors within Designated Wilderness. This is a new requirement of the Forest and the CCC and Access Fund did not recommend this approval process. On a positive note, the Forest Plan does incorporate our suggestions that fixed anchors are not banned in wilderness, that fixed anchors should be non-reflective to match the local rock, and that fixed anchors should be placed using non motorized tools in Designated Wilderness.
  • Final Plan: Pg. 283: RMS-04: All climbing activities in the Roan Mountain Management Area are closed to climbing due to rare habitats in rocky habitats within this 20 mile Management Area. This area has been closed for decades to climbing. Although we are inherently opposed to climbing closures, the inventory of impact-sensitive rare species in this area caused the CCC and Access Fund to not object to this Standard.

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Photo: Bradley Carter on Linville Gorge's 'Open Book' by Shannon Millsaps