White-nose syndrome has devastated bat populations in the northeast United States and eastern Canada. The disease is now found west of the Mississippi River and continues to spread into the Midwest and South. Multiple species are at risk of extinction.
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The U.S. Forest Service has a responsibility to reduce the risk of this disease spreading by human means to the greatest extent possible. The primary means of preventing transport of the fungus is cave closure.
Where the Forest Service permits access, which should be strictly limited to trips with proven significant scientific, safety and conservation value, decontamination should be mandatory both before and after cave visits.
In addition, part of the Environmental Assessment and cave-management plan should include concurrent research on the real-world efficacy of decontamination techniques. Limited lab analysis has been done on decontamination procedures so far. It is irresponsible on the part of the Forest Service to rely on decontamination as a major method of preventing fungal transport, since the agency has no documentation indicating the actual field effectiveness of decontamination.
Finally, the Forest Service must provide more information, including a range of alternatives for its cave-management Environmental Assessment. The documents now available to the public provide very little detail about the management strategies that would be used, the criteria by which cave permit applications would be reviewed and approved and the thresholds -- or trigger points -- that would prompt new or different management responses. The absence of such information means that citizens have no opportunity to understand the full scope of the proposal, let alone provide detailed responses to it.
I hope you will issue a complete draft Environmental Assessment and allow the public full opportunity to weigh in on the plan for cave management in the Rocky Mountain Region.