USFWS Releases Draft National WNS Plan

[PYoungbaer]

Just got word that the U.S. Fish and Wildlife Service is releasing the Draft National WNS Plan tomorrow at 9:00 AM. A press release will come out at that time, and shortly thereafter be posted on their website.

More importantly, it will appear Thursday morning in the Federal Register, opening a public comment period. Please watch for further details.

[BrianC]

Just got word that the U.S. Fish and Wildlife Service is releasing the Draft National WNS Plan tomorrow at 9:00 AM. A press release will come out at that time, and shortly thereafter be posted on their website.

More importantly, it will appear Thursday morning in the Federal Register, opening a public comment period. Please watch for further details.

Thanks Peter

[PYoungbaer]

Here are all the particulars:

Breaking News: USFWS Releases Draft National WNS Plan - Public Comment Sought By Dec. 26.

Press Release Here:
http://www.fws.gov/WhiteNoseSyndrome/pdf/WNSNationalPlanNewsReleaseFinal.pdf

Draft Plan Here:
http://www.fws.gov/WhiteNoseSyndrome/pdf/WNSNational%20Plan_DRAFT_10.21.2010.pdf

Plan Fact Sheet Here:
http://www.fws.gov/WhiteNoseSyndrome/pdf/White-noseNatlPlanFSOct2010.pdf

Plan FAQ Here:
http://www.fws.gov/WhiteNoseSyndrome/pdf/NationalPlanFAQs26Oct2010.pdf

[BrianC]

Here are all the particulars:

Breaking News: USFWS Releases Draft National WNS Plan - Public Comment Sought By Dec. 26.

Press Release Here:
http://www.fws.gov/WhiteNoseSyndrome/pdf/WNSNationalPlanNewsReleaseFinal.pdf

Draft Plan Here:
http://www.fws.gov/WhiteNoseSyndrome/pdf/WNSNational%20Plan_DRAFT_10.21.2010.pdf

Plan Fact Sheet Here:
http://www.fws.gov/WhiteNoseSyndrome/pdf/White-noseNatlPlanFSOct2010.pdf

Plan FAQ Here:
http://www.fws.gov/WhiteNoseSyndrome/pdf/NationalPlanFAQs26Oct2010.pdf

The only reason that a public comment is asked is, to know who their enemies are. What purpose would public comment serve? Do you think that they really care what people think?

[wyandottecaver]

they are required by law to have a public comment period. They have to let you comment, they dont have to listen

[Mudduck]

Listen or not we ALL still need to respond.

[Batgirl]

YES WE DO!!! And most importantly you need to read the section under Disease Management! This is a serious issue as they are suggesting the very same things that Wisconsin is proposing.

[John Lovaas]

This is a serious issue as they are suggesting the very same things that Wisconsin is proposing.

Cavergirl-

I've read the Disease Management section twice- can you highlight the portions that mesh with the WINDR plan? I can't say I've found anything yet.

Thanks- jl

D. Disease Management:
D.1. Overview

Disease management is composed of three complementary goals: to identify and implement science-based management actions to slow the expansion of WNS in order to delay, for as long as possible, the impacts of the disease reaching unaffected regions of the continent; develop and employ solutions to the disease that will ensure the perpetuation of susceptible bat species, and that will provide the best opportunities for their recovery to pre-WNS numbers in affected regions; and ensure that implemented actions will not be detrimental to bat populations or have unacceptable effects on the ecosystems in which they are found. This work is in its infancy and most of the questions critical to its success have not yet been resolved. There are, as yet, no proven applications that address any of the challenges presented below, and it is unclear whether the objectives detailed below are obtainable. This group will assist State, Federal, and Tribal agencies in determining the goals of management actions taken and the most feasible management tools that can be applied.
Monitoring the effectiveness of management actions will be critical to achieving the goals outlined below. Successful coordination and monitoring of all management actions will maximize our potential to learn from them and allow managers to employ adaptive management principles to refine research and management priorities. It will be important to develop and/or maintain the necessary capacity within State agencies to support the implementation of these disease management objectives.

D.2. Goals and Action Items

Goal 1: Critically review current knowledge of WNS disease management to identify knowledge gaps and research needs.
Actions:

(1) Solicit expert review of previous and current research projects and identify knowledge gaps.
(2) Identify priority research questions and capacity not currently being addressed in the investigation of WNS, including human dimensions.
(3) Identify high-priority field activities needed to support research priorities.

Goal 2: Reduce the risk of WNS transmission by humans to acceptable levels.

Actions:
(1) Define “acceptable level.”
(2) Identify the mechanisms for WNS transmission by humans to environment to bats.
(3) Provide guidance on regulation or restriction of human actions that are likely to pose a risk for spreading WNS.
(a) Develop standards for restricting use of potentially contaminated gear (both caving and bat research) at unaffected sites or regions.
(b) Manage cave access to minimize transmission risk.
(c) Develop operating guidelines for commercial caves.
(d) Modify mist netting/harp trapping protocol/techniques.
(4) Develop and implement decontamination/disinfection protocols to guard against human-assisted transmission of WNS to new sites or animals.

Goal 3: Reduce inter-/intra-specific transmission.

Actions:
(1) Conduct and/or support research on bat-to-bat transmission of WNS.
(a) Determine effectiveness of removal of infected and surrounding individuals.
(b) Identify prevalence/distribution of infected animals within hibernacula/clusters.
(c) Develop techniques for identifying infected animals (photo/thermography).

Goal 4: Reduce environmental transmission.

Actions:

(1) Conduct and/or support research of WNS transmission from environment-to-bat.
(2) Develop environmental decontamination techniques.

Goal 5: Eliminate G. destructans from infected individuals.

Actions:
(1) Identify means of G. destructans control that are effective and safe for the bats.
(a) Identify chemical control treatments for G. destructans.
(b) Identify biological control treatments for G. destructans.
(c) Identify effective environmental manipulations to reduce or eliminate G. destructans from affected bats or sites.
(d) Identify effective bat exclusion/inclusion of infected sites/uninfected sites.
(2) Reduce disturbance-related mortality associated with disease management activities.

Goal 6: Limit adverse ecological impacts of management actions to acceptable limits.

Actions:
(1) Research the need for, conduct, and/or support human dimensions research to define acceptable limits for all ecological impacts.
(2) Monitor management action outcomes and use adaptive management iterations to improve results, in light of potential ecosystem impacts.

[Pippin]

Maybe Peter can give us some tips on comments to provide. I read the document, and one thing that stood out to me is that the word "caver" is not mentioned at all, and the phrase "caving community" is only mentioned in terms of maintaining oversight over us. I would like to push to have the caving community totally integrated into whatever management plan is adopted. After all, we're the ones who actually know about caves!

[Batgirl]

Goal 5: Eliminate G. destructans from infected individuals.
Actions:
(1) Identify means of G. destructans control that are effective and safe for the bats.
(a) Identify chemical control treatments for G. destructans.
(b) Identify biological control treatments for G. destructans.
(c) Identify effective environmental manipulations to reduce or eliminate G. destructans from affected bats or sites.
(d) Identify effective bat exclusion/inclusion of infected sites/uninfected sites.
(2) Reduce disturbance-related mortality associated with disease management activities.

John,

When I say that FWS is suggesting the same thing as Wisconsin is proposing, I am not including the idea of defining G.d. as an invasive species, but am rather pointing out that they intend to conduct the same measures "on the ground" as Wisconsin is discussing (ie sealing caves, whether bats are present or not and/or spraying chemical or biological fungicides inside the system). I am not just espousing a conspiracy theory here. I have it on very very good authority that this is a topic of real discussion to prevent movement of this disease to the West and it has outraged many of the biologists inside the organization. If this document is adopted as is, they will move forward on this idea. And it will further give authority to states like Wisconsin to conduct these same measures. (Top of page 3 - The Planning process) "A national plan will assist State, Federal and Tribal agencies in exercising their authorities for managing bats threatened by WNS and in complying with all applicable laws".

Having said this, by their own acknowledgment (bottom of page 11) “There are, as yet, no proven applications that address any of the challenges presented below, and it is unclear whether the objectives detailed below are obtainable”. Then these action items do not need to be even discussed or included here. The implications of this are catastrophic. Earlier in the document, it also states that the base plan would be static, (page 3 – Origin of Plan) but that the elements incorporating implementation strategies will be adaptive. Again, if this is the case, then the majority of this section should be stricken. When more science comes in that supports potential treatment options, then the plan can be amended to include those ideas then. Treatments for managing this disease shouldn’t even be discussed when you don’t have any answers.

Perhaps it should read more something like this:

Goal 5: Eliminate G. destructans from infected individuals.
Actions:
(1) Identify means of G. destructans control that are effective and safe for the bats.
(a) identify safe and effective environmental manipulations to reduce or eliminate G. destructans from affected bats or sites.
(2) Reduce disturbance-related mortality associated with disease management activities.

[John Lovaas]

Hi cavergirl-

I understand your concerns. For me, the "identify" part of those goals reads as "do research"- which is different than "here is our public policy", which is where Wisconsin is.

Excluding bats from any cave is indefensible. I suppose someone could argue that preventing bats from entering a cave impacted by WNS in defensible- but how do you manage the remaining bats who survive WNS? You can't. That idea is probably unworkable.

But I suppose the research will be done. Hell, it's already being done in Wisconsin. Two caves with bat exclusion practices in place- and the bats are already back.

[wyandottecaver]

well note that unlike Wisconsin, which doesnt care about bats (or people) per se. The USFWS document, in the construct of the outline, pre-supposes that any exclusion/inclusion strategies are "safe and effective for bats". Now, if they (as they should) are referring to bats as a species rather than bats as individuals that may mean individual mortality for the "greater good". Im afraid they mean each lil furry bat however. WI is simply a bunch of book trained, half-witted folks in khaki trying to be bat biologists.

The USFWS has a chronic problem. people get into the field cause they "love animals". Thus many of the current biologists are focused on helping lil furry individual bats rather than protecting the species. The whole idea of "curing" or treating individual bats on a mass scale is simply ludicrous. Every dollar and minute of planning spent on it is a waste of resources. Thats one reason among many why their policies invariably fail to do their job....protect species not individuals.

[wyandottecaver]

john,
excluding bats from caves is perfectly defensible. If you think its all humans fault. Even excluding bats from a infected site only works if you KILL THE INFECTED BATS. otherwise those bats can and will find alternate hibernacula and continue to spread the disease.

[John Lovaas]

Even excluding bats from a infected site only works if you KILL THE INFECTED BATS

and they would be have the same success rate as the exclusions- some bats would always get in or get out.

[Batgirl]

John,

Even if you believe that the word "identify" implies doing research, then it should be stated that way. The one thing that I have learned is to never assume anything when it comes to government related documents. While a plan is not policy, these goals can lead to the establishment of new policies which do not require public comment. Government documents have a way of being vague so that they can't be challenged in court. They do it that way on purpose. So, It is important that they include the language that they mean not language that they can interpret to fit their short-term goals.