>     This should be an opportunity to clean the slate of recent cave =
>management practices by the BLM in New Mexico.  When the evidence is =
>there for us to examine, can we proceed with a plan, incorporating the =
>scientific evidence now available, that appropriately protects our bats, =
>but also provides appropriate access to the caves that the BLM has =
>closed?  I encourage everyone to comment and/or voice your concerns or =
>approval of the action that the SWR leadership has taken.  They have =
>done this on your behalf.  If you agree with it, let them that they have =
>done the right thing.
>
>Steve Peerman

      Below is a message I sent to various BLM (and USFS) recipients ten 
days ago.  It was my own idea--I sent drafts to the FSCSP board for 
suggestions, but did not ask for group sponsorship, because I wanted it 
clear that I was not writing as anyone else's representative.  Thus far, 
no addressee has sent me any response.  I don't know if they are taking 
time to draft a careful reply, or will just ignore me.  I did this before 
I learned that SWR was going to make the broader FOIA request (which I 
approve), that addresses all of the BLM closures and not just FSC.

                                          --Donald

----------------
>From dgdavis Mon May 12 12:05:13 2014
Date: Mon, 12 May 2014 12:05:13 -0600
To: jasonw...@gmail.com, mbi...@blm.gov, jdutc...@blm.gov,
 jgood...@blm.gov, cschm...@blm.gov, jstov...@blm.gov, mtup...@blm.gov,
 jj...@blm.gov
Subject: BLM management of Fort Stanton Cave
Cc: i...@fscsp.org

      I first visited Fort Stanton Cave in 1960, and am a long-term member
of the Fort Stanton Cave Study Project and its predecessor groups.  I led
most of the exploration/survey trips in Snowy River South between 2003 and
2009 (up to station SRS337).  After that, the cave went beyond my
endurance barrier, and I had to retire from personal pushing of the SRS
frontier, but have continued active in the FSCSP, have published many
articles on history and geology of the cave, and remain deeply interested
in the progress of exploration and science there.

      I am writing because I am deeply dissatisfied with the current 
management of Fort Stanton Cave.  In 2010, a single case of the White Nose 
Syndrome bat-pathogen fungus was reported in a southwestern Oklahoma cave. 
This was immediately used as a trigger to close New Mexico BLM caves, and 
to put access to FSC under a White Nose Committee which imposed severe 
restrictions on entry.  Many of the activities proposed by the FSCSP have 
been denied or seriously limited since that time.  (I also have been told 
that the projects of independent scientists trying to work in FSC have 
been seriously impacted, but will limit my present comments to the FSCSP.)  
The White Nose Committee has subsequently been reconstituted as a Cave 
Management Team, but the policies have continued with little change.

      It was announced recently that the "infected" Oklahoma bat from 2010
has been retested and found to have been a false-positive case:

https://www.whitenosesyndrome.org/news/oklahoma-removed-list-suspected-bat
-fungus-areas

      White Nose Syndrome has yet to be confirmed any farther west than
Missouri.  I suggest that it is time to re-evaluate keeping the management
of FSC under control of a committee that was hastily formed under the
alarming--but false--premise that WNS was nearing New Mexico, and whose
cave-closure policies have never been scientifically shown to be effective
in slowing the spread of WNS.  The BLM in Colorado has recently updated
their WNS policy, and it does not include blanket cave closures.

      The present situation is ironically contradictory.  Without FSCSP,
Snowy River would never even have been found, and would certainly not now
be a National Conservation Area.  FSCSP and its leaders have been formally
honored by BLM, and FSCSP was awarded a BLM $100,000 Cooperative Cost
Share Agreement with an extensive list of Joint Objectives to be performed
by FSCSP volunteers over the five-year period of the contract.  Yet the
restrictions on entering the cave have made it unclear that these
objectives can be fulfilled, and have left the recent expedition attendees
with so little to do that some FSCSP members have been abandoning the
Project in frustration.  What the Project needs most is not money, but
freely-available access and release from micromanagement.

      The matter has recently been further complicated by cavers applying
for exploration trips in Snowy River South outside the framework of the
FSCSP expeditions.  This might not be a problem if there were no limits on
access to the cave.  But under the present rules, which set a 120 person-
entry "carrying capacity" limit per year, non-FSCSP trips could be
competing directly with FSCSP for permits, which would further weaken the
position of FSCSP without making the exploration go faster or better.

      I see no reason why this cave should be subject to a numeric
carrying capacity at all (a concept which is normally applied to renewable
resources such as wildlife that have a measurable rate of replacement). 
As far as I can tell, any carrying capacity in this non-renewable context
must be totally arbitrary, and no evidence has been presented that "120"
relates in any demonstrable way to protection of the cave from WNS.  But
even if the carrying-capacity concept is retained, BLM has developed a
state-of-the-art decontamination system far superior to that currently
used at infected caves in Kentucky.  If BLM believes that its own decon
system works to prevent the possible spread of WNS, then it should be
capable of protecting a more reasonable number of cave entries.

      There is a valuable depth and continuity of knowledge and records in
FSCSP, and BLM should not take actions that may further limit the
organization's ability to offer meaningful activities to its members and
maintain an unfragmented data base.  Non-FSCSP trips should be approved
only if the limit on access is raised, should meet all requirements that
would be applied to FSCSP trips, and should share all data with FSCSP.

      Finally: To manage the cave responsibly, the BLM needs first of all
to know where the cave is, and where its water comes from.  Mapping of the
main Snowy River corridor (the source of the Snowy River calcite channel)
has been stalled at station SRS730 for a year by denial of permission
because the passage was nearing private property.  Electrical resistivity
testing from the surface has been continuing to try to see where the cave
goes, but the passages are deep, and the results have been too vague to
use for management.  The only way to find where Snowy River goes is to
resume the underground survey, and correct any drift by cave-to-surface
radiolocation as needed.  The rate of survey should be increased to the
limit set by the number of qualified explorers available.  Only then,
knowing exactly where the cave is, can its hydrology be understood, and
issues regarding surface ownership be addressed using the needed
information about which specific properties actually overlie the cave.

                                          --Donald Davis
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