By Richard Rhinehart ~ December 21st, 2012. Filed under: Cave Survey, Caving News, Conservation.
By Richard Rhinehart
Denver, Colorado, December 21, 2012 â€“ In a letter submitted today to the USDA Forest Service regional office in Lakewood, Colorado, the Colorado Cave Survey of the National Speleological Society calls upon the federal agency to open public caves to visitation, focus White Nose Syndrome management efforts to biologically-important caves, hire a regional cave specialist and to work cooperatively with the National Speleological Society in future cave management and policy decisions.
Cave Survey Chair Derek Bristol of Littleton, Colorado submitted the letter in response to a public call for comments by the Forest Service regarding potential actions regarding management of caves and inactive mines in the five state Rocky Mountain Region. In response to the potential spread of the Geomyces destructans pathogen that creates the deadly White Nose Syndrome among selected hibernating bat species, the regional office in Lakewood closed all public Forest Service caves and inactive mines in Colorado, Kansas, Nebraska, most of Wyoming, and the Black Hills of South Dakota on an emergency basis in late July, 2010. Following emergency one-year renewals of the closure in July 2011 and August 2012, the regional office announced in early November that the agency was seeking a longer-term management plan and policies for 2013 and beyond.
The Colorado Cave Survey, an internal organization of the non-profit National Speleological Society, has had a long relationship with the Forest Service, dating back to 1969. Until the 2010 closure of caves on Forest lands in Colorado, the Survey actively managed access to the stateâ€™s longest known cave, the 12-mile-long Groaning Cave near Glenwood Springs. In addition, the Survey also provided recommendations and management assistance to the regionâ€™s Forests for three decades. Since the implementation of the Closure Order, relations between the Survey and the Forest Service have been much cooler, even following a relaxing of the closure in August 2012. Since August, members of the Society have been allowed to apply with the Forest Service for access to selected public caves during an April through October season.
Writing on behalf of the Survey, Bristol appeals to the Forest Service to open caves on their lands that have no bats, since it is still unproven that humans can effectively transmit the spores for the fungus that has infected and killed millions of bats in the eastern United States. Despite more than two years of research since the original closure order in July 2010, knowledgeable scientists still disagree as to whether humans were responsible for the fast spread of the disease from 2007 through 2009, or if bats were the primary vector.
Bristol also encourages the Forest Service to concentrate their scientific efforts on caves and abandoned mines in the region that harbor the majority of known bats. Throughout the region, studies indicate that bats favor particular sites for roosting, hibernation and the little-understood fall â€śswarming.â€ť Caves without bats should not be treated the same as caves known to have bats.
In opening caves to public visitation, Bristol recommends that the agency continue to require decontamination of visitor gear and clothing, particularly when the visitor has been outside the region. Many of the cave areas in the Rocky Mountain Region are geographically separate, so proper decontamination should be sufficient to keep caves clear of the pathogen, if humans are a valid vector for transmission of the spores.
Bristol encourages the Forest Service to rebuild relationships with their partners in the caving community, reaching out to cavers and bringing them into meaningful management discussions and planning. In Colorado and the Black Hills particularly, for 30 years the USFS maintained exceptional relations with cavers and cave organizations, resulting in tens of thousands of hours of volunteer assistance and savings in expenditures. In addition, Bristol suggests the region hire a designated cave specialist to handle cave issues and work with outside organizations in management and policy. He notes that other federal agencies, including the Bureau of Land Management and the National Park Service, as well as other regions of the Forest Service, have successfully brought in knowledgeable specialists to manage the caves in a region or unit.
The Lakewood office of the Forest Service accepted comments through December 21 for potential changes and adjustments to the current cave closure policy. The current policy expires in early August, 2013, and federal officials are hopeful of devising a new cave management policy before this expiration. Public hearings throughout the region may be forthcoming in the first two quarters of 2013.
Full Text of the Colorado Cave Survey Response to the Forest Service
USFS Region 2 Cave Management Environmental Assessment
USDA Forest Service
740 Simms Street
Golden, CO 80401
Dear Mr. Schillie:
Iâ€™m writing on behalf of the Colorado caving community to comment on the National Environmental Policy Act (NEPA) Environmental Assessment that is being prepared for the management of caves and abandoned mines in the USDA Forest Service – Rocky Mountain Region in response to the threat of white nose syndrome (WNS).
Purpose and Need
While WNS is certainly a devastating disease with significant and irreversible ecological and economic impact, the mechanisms for the spread of the disease are still not fully understood. The observations and scientific studies conducted over the past seven years, since the disease was first identified, clearly show that bat to bat interaction is the primary vector for its spread. Management policies to date have focused on the theoretical and minor risk of human transmission. There is very little the USFS can do to limit the natural spread of the disease, and Draconian policies such as the blanket cave closure orders have likely caused more harm than good by limiting the collection of baseline data and disenfranchising cavers. In your scoping letter you state the purpose and need as â€śto reduce the potential for human introduction, spread, and impacts of the fungus Geomyces destructans, and the bat disease commonly known as white-nose syndrome (WNS) by providing management options for caves and abandoned minesâ€ť. This addresses only a small part of what should be done as part of an adaptive management plan. Given the fact that the disease is widespread in eastern North America, and limiting bat to bat transmission is not practical, management plans should focus on minimizing the impacts of the disease once it arrives and consider steps to increase the survivability and recovery of affected bat populations. Scientific study and baseline data collection need to be accelerated and recovery plans need to be developed. With the limited resources available within the USFS, it is critically important that the specific actions that follow from this purpose and need are developed in cooperation with the caving community and that any management policies are mutually beneficial to caves, cave life, and cavers.
Below are a series of suggested actions that the USFS should take as part of an adaptive management plan.
1. Limit management policies to WNS disease mitigation. While caves and cave life are delicate and require protection, any management policies being considered in the current context need to be tied to limiting the impact of WNS. When the risk of human transmission of WNS abates, then access limitations need to be lifted.
2. Access policies should be based on the risk of human transmission. As our understanding of the potential for human transmission of the Geomyces destructans (Gd) fungus advances, policies need to adapt. There have been far too many access limitations and other actions based on propaganda or theoretical risks. Any policies need to balance benefits against negative impacts. There is a significant downside to limiting access to caves, and these factors have not been considered in the â€śemergencyâ€ť policies of the past few years. Caves need to be managed for a multitude of purposes, and limiting the very small risk of human transmission of WNS should not completely outweigh the benefits of cave science, conservation, education, and recreation.
3. Involve the caving community in any future policy decisions. The National Speleological Society has a Memorandum of Understanding with the USFS (11-MU-11132424-018) in which there is agreement to cooperate on cave management issues. Also, one of the purposes of the Federal Cave Resources Protection Act of 1988 is to â€śfoster increased cooperation and exchange of information between governmental authorities and those who utilize caves located on Federal lands for scientific, education, or recreational purposesâ€ť. These agreements and laws have not been honored in the issuing of emergency cave and mine closure orders in the Rocky Mountain Region and elsewhere. Developing future policies that are beneficial, effective, and widely adopted requires involving those who are most knowledgeable about the resource, i.e. cavers.
4. Focus WNS management on â€śbiologically importantâ€ť caves. Criteria have been proposed to qualify caves or mines as biologically important for bats based on type of use, species type, and population. Seasonal access restrictions and exemptions should be prioritized on this basis. There is no need to restrict access to non-bat sites, and there is an increased need to permit data collection and monitoring of important sites. Permits should only be a consideration when exemptions are needed to collect data in biologically important sites during sensitive times of the year, and the permit process should be streamlined.
5. Continue to require decontamination of gear before and after visiting caves and mines. The risk of human transmission of WNS through the transport of Gd spores on clothing and gear is extremely small, but this can be effectively reduced to zero through the use of decontamination procedures. This requirement should be continued until more is understood about the potential for human transmission. Local agencies should continue to set policy on the need for decontamination when visiting multiple sites within a limit geographical area.
6. Apply limited resources towards improving knowledge about bats. There is limited understanding about bat populations, distribution, habits and behaviors, habitat, and many other important factors that are critical in preparing for, detecting, and dealing with the arrival of WNS in the region. Government agencies need to be urgently collecting baseline data rather than worrying about enforcement of ineffective cave closure policies. Now is also the time to leverage volunteer labor in collecting this much needed data and this is only possible through cooperation.
7. Hire a â€śCave Specialistâ€ť. There are more than 1,000 caves in Region 2 of the USFS and there is not one person with the knowledge, experience, or responsibility for effectively managing cave resources. Many other USFS, BLM, and NPS units with significant cave resources have specialists on staff to help make educated management decisions. A cave specialist could coordinate the needed field work to identify biologically important bat sites, collect and organize data, coordinate agency and volunteer efforts, collaborate with the caving community on effective cave access policy, identify resource protection needs, etc. Hiring a cave specialist would enable the region to much more effectively respond to the risk of WNS, and also deal with other ever-present cave resource management concerns.
8. Adaptive management triggers. In the scoping letter there are suggestions about the need for â€śtriggersâ€ť that would invoke a change in management policy, such as when WNS is confirmed within a given radius of the region, or even within the region. The proximity of WNS confirmed sites to the Rocky Mountain region should have no effect on policy. Current and proposed policies are based on the risk of human transmission, not bat to bat transmission, so bat migration routes and foraging areas have very little meaning to the risk of human transport of Gd. Existing and proposed policies, including access restrictions and decontamination requirements, assume that the disease is already in the region and very easily transmitted by human activity (both very conservative assumptions). If anything, access policies and decontamination requirements can be loosened if the disease were to become widely confirmed across the region.
9. Disease mitigation. The EA scoping letter and other correspondence from the USFS Region 2 in the recent past have proposed ecological engineering options such as â€śfungicidal applicationâ€ť and â€śexcluding bat accessâ€ť though the sealing or netting of cave entrances. The caving community is strongly opposed to these ideas as they are likely to have much greater unintended negative consequences.
With this Environmental Assessment there is an opportunity to reverse some of the damage caused by the blanket cave closure policies of the past few years. There is still time to collect the data needed to understand and better prepare for the possible impacts of WNS on our region. Itâ€™s only through cooperation that these goals may be accomplished.
Thank you for your consideration.
Chairman, Colorado Cave Survey