NSS Comments on Colorado BLM EA

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NSS Comments on Colorado BLM EA

Postby bigredfoote » May 31, 2014 9:35 am

The comments below were submitted by the NSS in response to the Colorado BLM request for comments on their WNS EA http://www.blm.gov/co/st/en/BLM_Informa ... 014/0.html.

Additional comments were submitted by several Colorado cavers as well.


First of all, I would like to thank you for the opportunity to comment on the BLM Colorado proposed White-
Nose Syndrome Adaptive Management Strategy and Environmental Assessment. It is encouraging that
alternatives were assessed and that an arbitrary and immutable policy wasn't produced.

As I am sure you are aware, since the publication of the EA, the status of the Oklahoma bat has changed from
suspected positive to confirmed negative and the theory of "geographically discontinuous spread" has no
scientific validation.

I believe the No Action Alternative should be the preferred alternative. It allows for more positive outreach with
stakeholders, continued assessment of caves and bats, and use of current containment and decontamination
protocols. It does not spend excessive effort attempting to manage suspected human movement when bat-to-
bat transmission is known to be the primary concern.

I encourage the BLM to consider additional addendums to their decontamination protocols based on future
research findings and best management practices.

The National Speleological Society looks forward to continuing to work with Colorado BLM as an interested
stakeholder to study and protect cave resources including bats.


Jennifer Foote
NSS WNS Liaison
Frequent Poster
Posts: 76
Joined: Apr 29, 2008 9:32 pm
NSS #: 45211
Primary Grotto Affiliation: Pajarito

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