While state and federal authorities are developing a plan of attack for dealing with white-nose syndrome in bat populations, a non-profit organization is criticizing the federal government for moving too slowly on this growing problem.

A draft of a plan outlining how state, federal, and tribal wildlife agencies will collaborate on efforts to slow the spread of the disease is open for public comment from today through December 26. This draft, however, does not provide actual steps for combating white-nose syndrome, which has killed more than 1 million bats in the Northeast since it was discovered in upstate New York during the winter of 2006-07. Rather, it aims to put in place a coordinated national management plan that spans state, federal, and tribal agencies.

"State, federal, and tribal wildlife management agencies have statutory and regulatory authorities for managing trust wildlife species. In exercising these authorities, agencies must comply with applicable laws," notes the 19-page National Plan for Assisting States, Federal Agencies, and Tribes in Managing White-Nose Syndrome in Bats.

"For example, federal agencies must comply with, among other laws, the National Environmental Policy Act, the Endangered Species Act, and the Federal Cave Resources Protection Act. Some of these laws provide alternative procedures to address emergency situations," the document continues. "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."

But at the Center for Biological Diversity, officials say the federal government is moving too slowly on this issue, noting that the Fish and Wildlife Service has yet to list "specific action items" or make "concrete recommendations for research and management of the fast-spreading malady that has hit nine bat species so far, including two on the endangered species list."

Mollie Matteson, a conservation advocate for the Center, said Wednesday in a prepared statement that, "It’s frightening to watch the government’s slow-motion response to what biologists call one of the worst wildlife declines in American history. A year after it first released a draft version of its plan, we have yet another draft, and nothing that actually gives direction or provides resources to scientists in the lab or biologists in the field.”

According to the Fish and Wildlife Service, white-nose syndrome affects hibernating bats. "Named for the white fungus that appears on the muzzle and other body parts of hibernating bats, WNS is associated with extensive mortality of bats in eastern North America," the agency has said.

Since its discovery four years ago, the disease has spread across the eastern United States and Canada, and the related fungus has been found as far west as Oklahoma, according to FWS officials.

"Bats with WNS exhibit uncharacteristic behavior during cold winter months, including flying outside in the day and clustering near the entrances of hibernacula. Bats have been found sick and dying in unprecedented numbers in and around caves and mines," said the Fish and Wildlife Service.

Noting that Halloween arrives Sunday, Ms. Matteson questioned, “What would Halloween be without bats? Scarier still, what would America be without them?”

"If we’re going to stem the spread of this deadly disease, we need the government to move quickly with a well-coordinated, well-funded response," she added. "In moving too slowly and failing to include concrete action, this plan keeps bats on the path to extinction, and we’ll all be poorer for it.”

But at the Fish and Wildlife Service, spokeswoman Anne Froschauer said a lot of behind-the-scenes work has been ongoing while the agency works on the collaboration plan.

"The good news is that the work has not had to wait," said Ms. Froschauer, pointing out that efforts around surveying and monitoring bat populations for the disease and communicating between the various agencies that have roles in wildlife issues have been ongoing.

The effort to develop and finalize an inter-agency response plan will be followed by development of an "implementation plan (that) will identify specific actions, the entities responsible for implementation of each action, and estimated costs."

“More than 50 agencies, organizations and individuals are working in concert on the white-nose syndrome response,” said WNS National Coordinator Jeremy Coleman, Ph.D., of the Fish and Wildlife Service. “The national management plan will help guide our use of limited resources wisely and efficiently in addressing this urgent threat to bats and to our environment.”

Public comments -- as well as any additional scientific or commercial information that arises -- on the collaboration plan will be accepted through December 26. You can find a copy of the plan at the FWS's white-nose syndrome website. Comments may be submitted by e-mail to [email protected], by mail to WNS National Coordinator, New York Field Office, 3817 Luker Road, Cortland, NY 13045-9348, or by fax to 607-753-9699.

The proposed plan includes an overall strategy for investigating the cause of WNS and finding a way to manage it. The plan identifies key actions and the roles of federal and state agencies and other entities in addressing WNS nationally. It identifies seven focus areas of responsibility – communications, scientific and technical information dissemination, diagnostics, disease management, research coordination, disease surveillance, and conservation and recovery of affected species.

The 60-day comment period was ridiculed by Ms. Matteson at the Center for Biological Diversity.

“The nightmare of this disease is only accelerating, but the federal government continues to waste time, as if it has decades to figure things out. The bats can’t tolerate more dramatic losses, and they can’t tolerate any more government foot-dragging,” she said.

The Center offered the following suggestions for combating the disease:

* Immediately declare white-nose syndrome a wildlife emergency

* Dedicate at least $10 million for white-nose syndrome research in next year’s Interior budget

* Develop a systematic plan for restricting access to all bat-occupied caves and mines on Bureau of Land Management lands and prohibit nonessential human access to all U.S. Forest Service caves in the Southwest by the end of the year

* Finalize the national response plan for the disease by mid-January

* Develop a National Park Service plan by mid-February to limit the disease’s spread

* Prohibit nonessential human access to all Forest Service caves in the Intermountain, Northern, Pacific Southwest and Pacific Northwest regions by late February

Back at Fish and Wildlife, Ms. Froschauer said developing a national response plan by mid-January might be ambitious in light of the current comment period on the collaboration network. While she wasn't sure whether FWS could declare a blanket "wildlife emergency," the spokeswoman did say that "pretty much all the agencies and entities involved have elevated this to a pretty critical issue.”

“From my work, all the agencies recognize the critical nature of the response to this," she added. "That’s why we have seen what I would say is unprecedented cooperation across” state, federal, and tribal wildlife entities.

While it was too late in the day Wednesday to reach National Park Service officials in Washington as to whether they had issued a system-wide memorandum outlining how to deal with white-nose syndrome, Great Smoky Mountains National Park officials some time ago closed their caves to the public to try to limit the spread of the underlying fungus, and Mammoth Cave National Park officials have protocols in place that range from requiring cave visitors to wash the soles of their footwear in decontamination solutions in the park's visitor center before entering the cave to providing all the gear for those participating in tours that require visitors to crawl at times.

"In May we started requiring that we provide all of the equipment and coveralls," Mammoth Cave spokeswoman Vickie Carson said late Wednedsay afternoon. "The boots are the only things that we allow people to bring themselves. Everything else -- the coveralls, the helmets, the lights, the knee pads -- we provide all of that. We wash it and decontaminate it every night. It’s been a different way of doing things for us.”

And the park also coordinates all its efforts in dealing with WNS with its Washington headquarters, the state of Kentucky, and the Fish and Wildlife Service.

"With every step that we’ve taken we’ve been in consultation with everybody," said Ms. Carson.

The lack of a formal inter-agency agreement also didn't stop the U.S. Forest Service back in July when its Rocky Mountain Region issued an emergency order closing caves and abandoned mines on national forests and national grasslands in Colorado, Wyoming, South Dakota, Nebraska and Kansas for one year in response to the spread of WNS.

U.S. Bureau of Land Management officials, meanwhile, in late September issued an interim policy for dealing with the disease on their landscape.

Until more detailed guidance is available, implement the BLM-WNS Interim Response Strategy, which includes the following guidance:

* Coordinate and conduct outreach with appropriate internal and external stakeholders to prevent or contain the spread of WNS. Identify caves and abandoned mine features (hereinafter referred to as “sites”; refer to the definitions of caves and abandoned mine features found in Attachment 2) with important bat resources (refer to all three attachments for more detail).

* Emphasize ongoing inventory efforts of Abandoned Mine Land Program Surveys.

* Consider restricting access to caves and abandoned mines on BLM-administered lands in your state. It is suggested that BLM State Directors use a targeted approach to closure that prioritizes sites with important bat resources.

* Adhere to the current version of BLM containment and decontamination procedures.

* Participate in interagency groups to develop state WNS response plans that consider the INRP, as appropriate.

* Recommend locations to test for the presence of WNS at a subset of the sites that have been identified as having important bat resources and support WNS research efforts where practicable and feasible within budgetary constraints.

The BLM will continually assess the effectiveness of this policy and implement adaptive strategies, as appropriate.