Here's the letter I sent. I am encouraging A) Forest-level targeted management, and B) caver agreements like that established in R2, and like the one we're working toward here in WV. Feel free to use it as "inspiration" in your own comments, but please do not copy any of my text verbatim.
Jen, thanks for sending that excellent NSS letter!
_________________________________
Liz Agpaoa
Regional Forester
USDA Forest Service
Ms. Agpaoa,
I am writing today with comments on the USDA Forest Service's proposed five-year region-wide "blanket" cave closure for the Southeastern Region (R8). My name is David Riggs, I'm a coordinator of the West Virginia Speleological Survey, and I currently serve on the working group to establish a cave management policy on the Monongahela National Forest (R9) along with several Forest Service employees, as well as representatives of the US Fish and Wildlife Service and the WV Division of Natural Resources.
First, and most importantly, I want to stress that the Southeast Region is far too large a unit to manage with a single sweeping closure policy; cave closures should be applied on a Forest-by-Forest basis. The Southeast Region accounts for just over 25% of the area of the entire continental United States. Managing caves in Virginia with the same policy as caves in Texas simply because they fall under a common managerial office is a way to ensure that neither states' resources are appropriately handled. Cave closures and similar drastic management policies should be applied at the Forest level, with a focus on each Forest's own needs, not region-wide.
Secondly, the cave environment encompasses many fragile resources; blanket cave closures, with their sole focus on bats, neglect the management of all other cave resources. The Forest Service depends on public volunteers to provide "eyes and ears" into its cave and karst resources, as well as for conservation of those resources. Responsible, organized cavers provide the Forest Service with up-to-date data on issues like karst groundwater contamination, vandalism, new biological records, archeological and cultural artifacts, newly discovered caves and cave passages, etc. If you speak to those who maintain the cave records for each of your individual National Forests, you will find that the source of those records are the very people you are banning from caves. Would you consider ignoring the management of every facet of a fragile wetland for five years?
I urge you to do the following:
- Do NOT issue region-wide cave closures; rather, allow cave management decisions to happen at the Forest level, where those decisions can be tailored for the individual needs of each Forest.
- Prefer targeted management of known critical bat caves so that other resource and management needs are not ignored. Blanket closures are counterproductive to the needs of fragile cave resources.
- In accordance with the Forest Service's existing Memoranda of Understanding with The National Speleological Society and The Cave Research Foundation, and by fostering relationships with local statewide cave survey organizations, implement cave access policies which maintain the ongoing data collection, scientific research, conservation, and resource inventory necessary to maintain your cave and karst resources. Again, blanket closures do more harm than good to these precious resources.
I hope that these comments aid you in your decision-making process. Agencies are understandably in a bind given the severity and speed with which White-Nose Syndrome has spread amongst hibernating and migrating bats. The lessons learned from the Northeast show that the knee-jerk reaction of blanket cave closures are an unsuitable and damaging management strategy. My goal in writing is to encourage you to learn from these lessons, and implement sane policies which can help maintain our imperiled bat species while simultaneously protecting the numerous other fragile resources found only in caves.
Please feel free to contact me should you wish to discuss any of these matters further, or if I can be of any help in establishing relationships similar to those we are currently fostering between the West Virginia Speleological Survey and the Monongahela National Forest.
Sincerely,
David A. Riggs