All,
        On Tuesday, May 20, 2014, our SWR Vice-Chair, Jim Evatt notified the 
membership in the SWR, through the SWR mailing list, that a Freedom of 
Information Act (FOIA) request had been filed by the SWR for information 
related to the BLM's management of the threat of White Nose Syndrome (WNS).   
This act, arguably the most significant act taken by the SWR for a generation, 
is the result of a string of events over the last several years.  I want to 
give the membership some of the background that led up to this request.
        As most everyone knows, WNS is a debilitating condition that has 
affected hibernating bats, primarily in the eastern United States and Canada, 
causing very high mortality rates in the bat colonies from the fungus that 
causes it. (P. destructans).  The first evidence of WNS came from Howe Caverns, 
a commercial cave in New York, in 2007.    An initial thought was that perhaps 
a caver from Europe possibly brought this fungus to the United States by 
visiting the cave with clothes that were contaminated with the fungus.  As more 
and more evidence accumulated of the devastating effects of WNS to bats, the US 
Fish and Wlldlife Service developed guidelines for the various cave management 
agencies to use regarding the potential spread of WNS.  These guidelines 
included recommendations to close caves and abandoned mines to human entry 
because of the possibility that humans may be a significant vector to the 
transmission of the condition.
        In January of 2011, the NM BLM published a Federal Register Notice of 
Temporary Closure of 28 caves in New Mexico known to have significant bat 
populations, probably as a direct result of a report of an infected bat in the 
neighboring state of Oklahoma.   That Temporary Closure was for 2 years only 
and expired in January of 2013.  At the 2012 Winter Tech, Ms. Marikay Ramsey  
(BLM bat biologist) announced the intent of the BLM to renew the closure.  In 
January of 2013, at a special meeting in Albuquerque, Jim Goodbar, National BLM 
Cave Program lead,  again discussed that intent, and also mentioned that 3 of 
the caves previously closed would be re-opened.  The BLM revealed that it was 
delegating the management of caving activities under the threat of WNS to a 
state-wide Cave Management Team.
        Cavers waited for the announcement that the Temporary Closure was being 
renewed, or that a new Temporary Closure was being instituted.  This didn't 
happen (and hasn't happened to date).  Instead, the BLM merely said that the 
caves are "closed".  Cavers inquiring about the "closure" were told that BLM 
didn't need to have a Federal Register Temporary Closure because the cave 
specialists could merely refuse to issue permits.  
        This  management plan, if it can be called that, for the BLM caves that 
were previously closed by Federal Register Notice persisted for another year, 
as cavers became increasingly dissatisfied with how the caves were being 
managed.  Meanwhile more research was being done on WNS; research that 
demonstrated that bats were very good at transmitting WNS from one to another, 
but that humans ere not very good at spreading the fungus.  In fact, we know of 
no credible evidence that WNS has been spread from one cave to another by 
humans.
        At the spring SWR regional on April 12, 2014 there was a significant 
discussion of the BLM's continuing stand that they could close the caves by 
just saying they are closed and what to do about it.   One idea was to ask for 
permits for some of the closed caves in order to bring the issue to the 
forefront.  This was done by several folks, including Dave Belski and Stephen 
Fleming, who both requested recreational permits to Fort Stanton Cave.  Both 
were denied.  
        On May 6, 2014 the Oklahoma Department of Wildlife Conservation 
announced that the previous report of a WNS bat in Oklahoma was a false report, 
and that no WNS infected bats had been detected in New Mexico.  On May 9, BLM's 
Chief of Communications issued this statement to the SWR mailing list:  

BLM New Mexico White-Nose Syndrome Closure Strategy Update
May 2014
        BLM New Mexico is evaluating the new information released by the 
National Wildlife Health Center about the Woodward County, Oklahoma bat 
originally tested in 2010 being now reclassified as negative 
forPseudogymnoascus (formerly Geomyces) destructans and White-nose syndrome 
(WNS). 
 At this time, we are sustaining our WNS cave and abandoned mine closure 
strategy.  The BLM’s team of biologists, cave specialists, and managers will 
work internally, as well as with our NM interagency partners, to consider the 
new Oklahoma findings.
        The BLM is the responsible party for managing hundreds of New Mexico 
caves and abandoned mines and their resources.  We will continue to do so by 
using the best available science and by following laws, regulations, and 
national BLM guidance to minimize risk and impacts to these resources.
        Moving forward, we will consider WNS’s significant movement westward in 
the past four years, the number of caves open for recreation vs. those closed 
on public lands in New Mexico (about 1,000 open to 25 closed), and the fact 
that even our closed caves have managed access for scientific and 
administrative purposes.
        We will proceed thoughtfully and scientifically to determine the future 
of our WNS strategy.  We are committed to keeping cavers and the general public 
advised of any changes to our policy.

        Many cavers, including myself, sent e-mails to various responsible 
folks in BLM management encouraging a dialog on the topic of the continuing 
management of these caves.  To my knowledge NONE of those e-mails were 
responded to, not even by a courtesy reply.  

        Meanwhile, cavers and SWR members Dave Belski and Stephen Fleming 
considered their options regarding the denial of their recreational permit 
requests.  They were formulating a response that would attempt to elicit the 
reasons why these caves were closed.  As they formulated the questions, it 
became obvious that what was really necessary was a FOIA request.  Fleming, a 
retired BLM law enforcement officer, wrote the request, initially as his own 
request as a private citizen.  After getting the majority of the request 
written, he shared it with others, including me.  After reading the request, I 
realized that this FOIA request reflects the interests and concerns of the 
caving community at large and should be a request of the caving community.  I 
petitioned the SWR leadership, the executive committee of Peg Sorensen (chair), 
Jim Evatt (vice-chair), Dave Belski (secretary) and Blake Jordan (treasurer) to 
name Fleming as a special representative of the SWR and allow him to file this 
FOIA request on behalf of the SWR.  They agreed that this was in the best 
interests of the region and named him the Federal Liaison.  On Monday morning, 
May 18 the FOIA request on behalf of the SWR was filed with the BLM's FOIA 
coordinator at the state office, with copies to several BLM management folks.

        As I said earlier, this is probably the most significant action taken 
by the SWR in this generation.  It is an action not taken lightly, and is not 
intended to discredit or demean the cave management efforts of the BLM, but to 
bring those efforts to the light of day so that all may understand how 
decisions were made.  If the scientific evidence exists that closure of the 
caves is effective in preventing the spread of WNS then we want to see it.  If 
the evidence exists that WNS is moving rapidly towards New Mexico, we want to 
see it.
        
        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

        "Twenty years from now you will be more disappointed by the things you 
didn't do than by the ones you did. So throw off the bowlines, Sail away from 
the safe harbor. Catch the trade winds in your sails. Explore. Dream. Discover."
    attributed to Mark Twain, but no record exists of his having written this.

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