In the last few months, scandals have gutted the upper leadership of the National Park Service, and they are going through a major transition. NPS Director Jarvis will be retiring at the end of 2016, but before the Trump administration has a chance to appoint the next director, Jarvis will issue one last order, Director’s Order (DO) #100: Resource Stewardship for the 21st Century.

This order outlines a framework for how the NPS will protect natural resources and steward national parks. The draft DO, cynically regarded by some as “DO-No”, institutionalizes a risk management strategy called the Precautionary Principle. If institutionalized, this Precautionary Principle would allow land managers to prohibit or restrict appropriate uses if “an activity raises plausible or probable threats of harm to park resources.”

Sounds reasonable enough, but in practice this may not play out well for climbers and other recreation groups. The Access Fund supports well-substantiated, science-based decisions, and DO#100 would allow managers to prohibit or restrict climbing—without any evidence—if they believe it’s plausible that climbing activities might result in unacceptable impacts.

This “ban first, ask questions later” principle would allow decision-makers to prohibit lesser-understood activities until future studies shed light on issues of concern. Rock climbers are a relatively small minority of National Park visitors, and climbing management is typically lower priority than management issues that affect larger visitor populations. As we see frequently, rock climbing studies and inventories are constantly postponed or never conducted due to funding challenges, staffing shortages, and land manager attrition.

So, even though rock climbing is considered an “appropriate use” under Jarvis’ previous DO#41[i], climbers commonly experience years of unsubstantiated closures and restrictions while waiting for research to be conducted and management strategies to be adapted. Examples of this include North Cascades National Park, where a “temporary” bolt moratorium stands until a Wilderness plan revision is completed, at an undefined date. And Sequoia and Kings Canyon National Parks, where poorly developed climbing management policy is awaiting further implementation guidance. Institutionalizing the Precautionary Principle under DO#100 will exacerbate this phenomenon, and very likely result in more unsubstantiated restrictions on appropriate uses like climbing.

Access Fund is already experiencing significant challenges implementing fair and consistent climbing management in national parks. Several parks have recently revised Wilderness climbing management strategies and have severely tightened the screws, without compelling justification, on new route and fixed anchor placements and replacements. DO#100 will provide NPS with additional justification to prohibit first and ask questions later.

Climbers are conservationists and long-standing national park supporters. If the NPS continues to restrict legitimate uses, they risk disenfranchising the climbing community while losing valuable National Park System supporters and partners.

Access Fund is rallying our partners and will submit comments on the draft DO#100 by November 18th, 2016. We’ll keep you posted on this critical issue.

[i] Director’s Order #41: Wilderness Stewardship, Section 7.2, National Park Service, US Department of the Interior (May 13, 2013).