Revised Road 18 Caves EA comments by The Access Fund

TRADITIONAL MOUNTAINEERING™
www.TraditionalMountaineering.org™

TraditionalMountaineering Logo representing the shared companionship of the Climb ™

Revised Road 18 Caves EA comments by The Access Fund

July 5, 2001

Walter C. Schloer, Jr.
District Ranger
Bend-Fort Rock Ranger District
Deschutes National Forest
1230 NE Third Street, Suite A-262
Bend, OR 97701

Re: Comments on Road 18 Caves Project Environmental Assessment

Dear Mr. Schloer,

The Access Fund welcomes the opportunity to comment on the Road 18 Caves Project Environmental Assessment (EA.) We would like to compliment the Deschutes National Forest on the preparation of the EA, which improved considerably from the previous draft due to a more thorough examination of the environmental effects of various uses of the caves. In addition, we appreciate your consideration of our previously submitted comments. At this time we are pleased to offer the following supplemental remarks.

The Access Fund
As you may know, the Access Fund is a 501 (c) 3 non-profit conservation and advocacy group representing the interests of climbers in the United States. The Access Fund is the largest national climbers organization, with over 15,000 members and affiliates. The Access Fund’s mission is to keep climbing areas open, and to conserve the climbing environment. Preserving the opportunity to climb and the diversity of the climbing experience are fundamental to our mission.

Working in cooperation with climbers, other recreational users, public land managers and private land owners, the Access Fund promotes the responsible use and sound management of climbing resources. We encourage an ethic of personal responsibility, self-regulation, strong conservation values and minimum impact practices among climbers.

In our previous letters, dated May 24, 2000 and July 7, 2000 and during a site visit on June 19 & 20, 2000 we described how we endeavor to work with public lands managers to preserve climbing opportunities consistent with maintenance of satisfactory resource conditions and the realization of specific management objectives. As we mentioned previously, some of the ways in which we can be of assistance to the Deschutes National Forest include providing grant funding for studies and resource mitigation projects, consulting on policy and planning, helping to organize and educate local climbers and assisting with outreach to the local and national climbing communities.

General Comments
The Access Fund recognizes that managing the Road 18 caves presents a significant challenge for the Deschutes National Forest. We applaud the Forest Service’s effort to solicit public feedback during the preparation of the EA, and we reiterate our support for proposed management actions aimed at protecting cave resources such as relocating and defining parking areas, improved education and outreach, seasonal wildlife restrictions, restrictions to protect cultural resources and restricting cave access to foot traffic only.

We note that the Caves EA now has a more thorough analysis of the effects of humans on wildlife resources, geologic features, vegetation and cultural resources at the caves in the project area. We are encouraged that the preferred alternative preserves limited opportunities for climbing but the restriction on the use of chalk remains a serious concern. We see no evidence in the EA that the use of chalk damages cave resources, nor an examination of whether potential effects would result in deterioration of cave resource values. While it may be prudent to restrict the use of chalk until its actual effects in the caves can be studied, it should not be completely prohibited since climbing in the caves may be dependent on its use. Since there is little to no evaluation of whether chalk is fundamentally necessary for climbing in the caves, or of the effects on climbing if chalk is altogether prohibited, and since the potential adverse effects of chalk have not been thoroughly examined, it is premature to ban all use of chalk in the caves.

We would also point out that although the preferred alternative authorizes existing bolted routes for climbing, there is no language authorizing the replacement of aging or unsafe fixed anchors (bolts.) Such language should be included due to the fact that fixed anchors are a critical safety tool for climbers and their upkeep, including occasional replacement, is a vitally important safety concern. Without occasional maintenance, aging fixed anchors can fail, resulting in serious accidents. Details of a fixed anchor replacement policy could be worked out in cooperation with the Oregon Climbers Coalition.

Comments on Alternative C: the Preferred Alternative
We support the preferred alternative insofar as it preserves climbing opportunities in Hidden Forest and Skeleton Caves but we are unconvinced that a ban on the use of hand drying agents is necessary. In steep, technically difficult, humid environments the use of chalk is widely considered by climbers as essential (i.e., absolutely necessary) for climbing. Local climbers who frequent the Road 18 caves are unanimous in their opinion that chalk use is essential at this location and that a ban on its use means that climbing would become virtually impossible. Therefore, we again urge the Deschutes National Forest to consider alternatives to a complete ban on the use of hand drying agents.

We recommend that the use of chalk be restricted to certain areas within the two caves where climbing would be continued, and that its continued use be made contingent on a formal agreement with local climber organizations regarding standards for visual impacts and other environmental effects. If local climbers are invested in helping the Deschutes develop standards for minimal chalk use, compliance problems can be resolved and other management goals achieved with respect to outreach and partnership with the public.

Furthermore, the inclusion in the EA of the wording prohibiting even the possession of hand drying agents is unnecessary, inconsistent with the goal of maintaining cooperative relations with the public, and may be unconstitutional. Chalk is not a prohibited substance under any federal or state statute that we are aware of, nor are there any specific restrictions on its use on public lands under the CFR or other authorities. The way to promote a satisfactory level of compliance with restrictions on chalk use is through a concerted outreach effort to the climbing community and to allow for its limited use in specific areas where there will be minimal effects on cave resources.

Summary
Owing to their distinct physical and aesthetic characteristics, the Road 18 Caves offer a climbing experience that is unique among all climbing areas in the Pacific Northwest. The Access Fund supports the proposed management actions that would preserve climbing opportunities in the caves, but believes that the proposed ban on use of chalk is at odds with this goal. We encourage the Deschutes National Forest to continue working with the Oregon Climbers Coalition on climbing management and resource protection issues and in particular, regarding the cooperative development of standards for limited use of chalk.

We again thank the Deschutes National Forest for the opportunity to comment on the Road 18 Caves Project Environmental Assessment. We look forward to working with you in the future on this and other climbing management issues.

Sincerely,

Shawn Tierney
Access and Acquisitions Director