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Stop Unjustified Raptor Closure in Boulder Canyon

Submitted By: John McNamee on Feb 21, 2006


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Information for Climbers from the Friends of Boulder Canyon

The U.S. Forest Service (USFS) has implemented excessive, unwarranted and unjustified seasonal wildlife closures of the Security Risk Crags for the past five years. The alleged purpose of the closures is to protect a pair of golden eagles that have nested in Boulder Canyon on and off for well over a decade, but have never nested at Security Risk Crag.

For over two years the Friends of Boulder Canyon (FOB) have attempted to work with the USFS to keep Upper and Lower Security Risk open, but despite our attempts the USFS continues this unjustified closure. Although the USFS has excluded the Bihedral and the Riviera from this year’s closure as a result of our objections, Upper and Lower Security Risk remain closed. The USFS has continued these closures, despite clear evidence that the “nest” on Upper Security Risk has not been used by any raptor over the past twenty five years, and has never been used by eagles for nesting.

In the summer of 2004, Brent Bibles of the Colorado Department of Wildlife and Dr. Rob Ramey, at the time Director of Zoology at the Denver Museum of Natural History, rappelled into the Security Risk “nest” to examine its contents. The only evidence of suc! cessful nesting that they found were fragments of shells that they estimated to be approximately 25 years old and which they believed were not eagle’s eggs. Mr. Bibles later conducted a more detailed analysis of the shells which confirmed that the shells were “clearly not golden eagle fragments”. Furthermore, there was no evidence that any bird had nested at that site in the past twenty five years.

Despite this irrefutable evidence and FOB’s request to exclude the Security Risk crags from the closure, the USFS closed Upper and Lower Security Risk and Happy Hour crags in the spring of 2005.

This year we again requested that all Security Risk Crags be excluded from the closure, and again the USFS has unjustifiably closed Upper and Lower Security Risk, two of the premier winter climbing crags in the Front Range.

There is no credible evidence of historical or current use by eagles or other raptors of the “nest” at Upper Security Risk. The unnecessary and unjustifiable closure deprives the public access to public lands for the wrong reasons. The Access Fund, a national climbing advocacy and conservation organization with a long history of supporting valid seasonal wildlife restrictions, withdrew its support for the closure of the Security Risk Crags in 2004 after reviewing the evidence.

The USFS is currently reviewing its closure policy regarding the Security Risk Crags. Attached are the USFS letter asking for public comment and an email from Dr. Rob Ramey to Beverly Baker, the USFS biologist responsible for the closures, requesting that the areas be opened due to the clear evidence that the nest at Security Risk is not an eagle nest. See forums for copies of the letters.

The USFS is taking comments from the public until 27 March 2006. Please take a moment and help fight this unjustified closure. Please write to the USFS and state your strong opposition to the closure of the Security Risk Crags and encourage your friends to do the same. Address your comments to Beverly Baker at bbaker@fs.fed.us and copy! her sup eriors, Christine Walsh at cwalsh@fs.fed.us and James Bedwell at jbedwell@fs.fed.us. Please copy FOB at FriendsofBC@comcast.net so we can accurately count how many responses were sent to the USFS.

Also please copy your representatives in Congress and ask them to prevent the USFS from continuing unjustified closure of public lands. Without political pressure the USFS will continue ignoring the evidence and abusing its discretion, and climbers will continue to lose access to one of the best winter crags in the Front Range.

Member Name DC Phone DC FAX Email
Sen. Wayne Allard (R- CO)
202-224-5941 202-224-6471 allard.senate.gov/public/index.cfm?FuseAction=Contact.Home

Sen. Ken Salazar (D- CO)
202-224-5852 202-228-5036 salazar.senate.gov/contact/email.cfm

Rep. Diana DeGette (D - 01)
202-225-4431 202-225-5657 www.house.gov/degette/comment.shtml

Rep. Mark Udall (D - 02)
202-225-2161 202-226-7840 markudall.house.gov/HoR/CO02/Contact+Mark/Contact+Mark.htm

Rep. Marilyn Musgrave (R - 04)
202-225-4676 202-225-5870 www.house.gov/writerep/

Rep. Joel Hefley (R - 05)
202-225-4422 202-225-1942 www.house.gov/writerep/

Talking points
The following are some talking points that you can enclose in your letter or email. Also, please consider writing a letter to the editor of your the local and regional newspapers.

• We support wildlife closures backed up by credible scientific evidence.
• This closure is unsupported by any scientific evidence.
• The pile of sticks at Upper Security Risk is not a nest.
• Golden eagles have never nested at Upper Security Risk
• Golden eagles are not threatened or endangered.
• No birds have nested at Security Risk in over 25 years.
• Depriving the public of access to public lands is a drastic action that should be taken without good reason.
• Closures of public land mu! st be su pported by demonstrable evidence that the closure achieves an appropriate management goal.
• Unjustified closures decrease the public’s respect for valid closures and compliance with restrictions
• The Security Risk Crags are premier crags with a peak winter season because of their southern exposure. During summer, the routes on these cliffs are too hot to climb. Closing the crags for several months in early winter results a significant loss to the climbing community and greatly decreases the opportunity for climbing at these crags.

Thanks to Chris Archer for providing this info.



Comments on Stop Unjustified Raptor Closure in Boulder Canyon Add Comment
Comments displayed oldest to newestSkip Ahead to the Most Recent Dated Mar 19, 2006
By Hamish Gowans
From: Golden, CO
Feb 21, 2006

John,
Admitting raptor ignorance, I wonder if the old nest might be reinhabited if climbers continue to leave it alone. Does the USFS state this as a goal of the closures?

By bryan
Feb 22, 2006

Though I'm not very well-versed on the issues, I think you make some compelling points. I think most traditional/alpine climbers in general (and the others as well :) ) tend to be very respectful of wildlife and ecological preservation (which is alas not generally what we are made out to be); in fact I would venture to say we care more about it often than those who make such legislations; over-legislation is something that is rampant in national parks, open space etc. We have generally adopted over-regulation instead of general awareness. But I digress. If indeed no birds are in danger, it's ridiculous to legislate such a rule; good luck.

By MB21
Feb 23, 2006

The Security Risk crags have had at least one existing eagle's nest for decades - rock climbing guidebooks from the late 80's even identified it as such. Eagles defend a territory containing multiple nest sites, and their courtship ritual includes a nest selection phase, during which the eagles visit the various nest sites they have to choose from, adding sticks and branches to each nest and finally making their selection. It's logical to assert that the Security Risk nest hadn't been used by eagles for many years because people were disturbing the area by being in it during the nest selection phase.

Although the nest on Security Risk has not been used for some years, the eagles have visited it and added sticks to it each year since the Forest Service closures in the Security Risk area began. For the majority of years since the early 1990's, the eagles have nested on Eagle Rock or not at all in the Boulder Canyon territory. In 2005, the eagles returned to a nest site on Blob Rock and successfully fledged one chick. Annual reproductive success in the Boulder Canyon territory is only 1/2 to 1/3 of the success rates of eagles with nesting territories in less disturbed areas. Have the Boulder Canyon eagles been forced to select Eagle Rock because of disturbance at their other nest sites? Is there something about the Eagle Rock site that is less than ideal for successful reproduction, such as more shade, cooler temperatures and the presence of nest parasites? Perhaps the Boulder Canyon eagles would have preferentially selected a site on the south-facing side of the canyon every year if left alone to select the optimal nesting site.

The Forest Service has tried to reduce the closures' impact on climbers by reducing the Security Risk closure area (to a size smaller than that recommended by the Division of Wildlife), leaving Riviera, Bihedral and Happy Hour (all initially within the closure area) open to climbing access. Also, in three of the last four years, some of the closure areas have re-opened by mid-March, after the eagles have selected their nest site and begun egg incubation.

There are many places around Boulder and even within Boulder Canyon that climbers can go - the eagles have only this one territory to choose from.

The link labeled "forums" in the original posting above contains a letter from the Forest Service and a lot of background information on this topic. Give it a read because it answers a lot of the questions that John raises.

By Tony B
From: Around Boulder, CO
Feb 24, 2006

The post above is quite assertive and authoritative in its statements and conclusions. MB21, however is not a qualified name to me at this time.
MB21, can you please state the source of your data and the nature of your authority and expertise on this subject? Your conclusions seem to be in conflict with that of a wildlife biologist who has directly surveyed the site.
Until I understand your credentials, I have no choice but to side my opinion with the one that has been qualified.

By MB21
Feb 24, 2006

I have a B.S. in Biology, have worked professionally with raptors, and have studied raptors to satisfy personal interest. The information I presented came from the Forest Service (much of which is based on information gathered by Rob Ramey of Denver Museum of Nature and Science, the Division of Wildlife and observations from Boulder County Nature Association volunteer observers) and most of it is available in the Forest Service letter, which you can find through the "forums" link in the original posting above.

In his letters, Rob Ramey suggests that Security Risk should only be closed if the eagles decide to use that nesting site, but by not closing it, you all but guarantee that the eagles will never nest there. Why not err on the side of caution and give the eagles an opportunity to choose that nest site?

By Mike Anderson
From: Dayton, OH
Feb 27, 2006

PICK YOUR BATTLES

As climbers, I think we need to be very careful about which causes we choose to take up arms for.

The seasonal closure of some Boulder Canyon choss pile is not worth risking ill-will between the local USFS administrators and climbers.

Furthermore, I don't think this is an issue worthy of congressional intervention...perhaps it would be smart to save those "big guns" for more universal conflicts such as debates on fixed anchors in Wildnerness that effect the entire nation.

I realize it can be frustrating when your local crag is closed (for only a fraction of the year). However, in a place like Colorado with all the nearby climbing opportunites, it's easy to come across as ungrateful and selfish if you complain about one cliff out of thousands being closed.

I would encourage you to carefully consider if this particular crag is worth the trouble.

By Tony B
From: Around Boulder, CO
Feb 27, 2006

First off, thanks for listing your credentials, MB21. It would still be nice to have a name, provided there is no reason to remain in anonymity.
Second of all, this issue may not be worthy of congressional intervention. Talk about the old lady that swallowed the fly...
(refer to swallowing a spider to get the fly- I don't know why, I guess she'll die)
"Everything I needed to know about the law, I learned in a nursery rhyme."

I think the matter is perfectly suited for debate here and agree that the points made on either side have merit. I think the FACTS are still central to debate because the same letter is referred on both sides.

For my own personal use, having been to that crag exactly once in 12 years, and perhaps 6 years ago, I don't mind what happens to it. I don't like bugging birds, myself.

But legally, precedents may get set, and government power is like a weed. You have to consider that too.

The best outcome in my mind would be that the closure is lifted if the birds don't settle there. Perhaps that is the best thing we should work for in advance. After all, if they have not for 20 years, they probably won't, right?

-T.

By Rick Thompson
From: Mount Nebbiolo, CO
Mar 2, 2006

There are numerous misstatements and misrepresentations in MB21's post that should clarified. But first, let's be clear. The Access Fund and Friends of Boulder Canyon (FOBC) support justified seasonal nesting restrictions, for example, the Eagle Rock and Blob Rock closures. The Access Fund has even provided grant funding to pay for signage alerting climbers of the closure, a further show of the general climbing community’s commitment to ongoing support of seasonal nesting restrictions where clear and demonstrable evidence of nesting is shown.

There is no factual basis to the suggestion that the “nest” at Security Risk is an eagle nest or that it has ever been used - even once - by a nesting pair of eagles. In fact, all evidence establishes the contrary. Colorado Dept. of Wildlife Raptor Biologist Bret Bibles and Dr. Rob Ramey’s inspection of the nest clearly demonstrated that the nest was not an eagle's nest, that is, that no fragments of eagle shells were found anywhere in the nest. Dr. Ramey has also indicated the nest is too small in physical dimension to be an eagle nest. In the most recent meeting the AF and FOBC had with the Forest Service Dr. Ramey showed photos of the nest confirming its tiny size. The only eggshell fragments found in the nest were measured and tested by the Colorado Department of Wildlife Raptor Biologist who stated that they were "clearly not eagle shells" in his report to the USFS.

Irregardless of MB21's suggestions, there is not a shred of demonstrable evidence that this “nest” has ever been used by eagles. Past mention of this being an eagle nest in the old Boulder Canyon Climbers guide amounts to nothing more than conjecture. Richard Rossiter is a great artist and guidebook author, but until now no one has ever cited him as an expert in raptor biology.

MB21's allegation that eagles are responsible for adding sticks to the subject nest may be what he or she would like to believe, but there is no evidence to prove that sticks were added at all and, if sticks were in-fact added, no evidence that eagles added them. During Dr. Ramey's and Mr. Bibles investigation of the nest, Mr. Bibles saw certain sticks that he thought were "newer" than other sticks in the pile. MB21’s conjecture has not been established as true. More importantly, even if some twigs were more recent than others, since the investigation established that the "nest" is not an eagle's nest a more likely explanation is that ravens, rodents put them there.

The bottom line is that MB21 appears to want closures to be as expansive as possible to protect all potential raptor habitat. This closure and the countless other seasonal nesting closures for a variety of species across the country are not about protecting “habitat”. They are intended to protect actual nesting sites during the period each year when courtship, mating, egg incubating and young are being fledged. The laws pursuant to which such closures are enacted do not authorize expansive closures of habitat and closures of any ledge, pile of sticks or other site that MB21 thinks might be a possible alternate nest site. Under that approach every pile sticks or would-be nest from any species on every ledge on every cliff in Boulder Canyon would constitute a potential alternate nest and thereby become the basis of a seasonal closure of public land. That is precisely why the laws governing such closures are narrow in their scope and limited in the species they protect.

At the heart of this issue is what factual basis should be present to justify a seasonal closure of public lands to protect nesting sites. The ongoing nesting patterns at Eagle and Blob meet the litmus test. But given the clear evidence that eagles have ever nested at Security Risk the Access Fund and the Friends of Boulder Canyon believe the seasonal closure of this important climbing resource is unjustified.

That climbers and the USFS are at odds over this matter is unfortunate since we share so many common values and goals with the USFS in protecting our great outdoor resources. We hope that common sense prevails in the near future and that the USFS will do the right thing and lift this unsubstantiated closure once and for all.

Please continue to write to the USFS and oppose this unjustified closure and please copy your federal legislators as well. It is important that they aware of this on-going discussion at the federal level. Thanks to all of you who have written so far.

Best regards,
Rick Thompson
Friends of Boulder Canyon
Access Fund - Front Range Regional Coordinator

By Rick Thompson
From: Mount Nebbiolo, CO
Mar 2, 2006

On a personal note – I believe internet forums should operate on a real names basis instead of allowing acronyms and monikers for posting under the cloak of anonymity.

MB21 – given that you joined this forum 2 days after the Friends of Boulder Canyon Action Alert was posted here and have to your credit exactly 2 posts – both of which pertain to this matter - it would appear you joined this forum not as a climber, but for no other reason than to posture on this issue. Your message sounds like it comes verbatim from US Forest Service speak. Snowfin – you joined on the 28th of February and have the one lone post above to your credit.

For the benefit of those involved in this discussion would you both be so kind as to identify yourselves by name and state any affiliation that might be relevant?

best regards,
rick thompson

By Tony B
From: Around Boulder, CO
Mar 2, 2006

From a personal note, considering that my request for a name was unmet, I have concluded that anonymity was a goal.
This undermines the credibility of the posts made anonymously and leads me to the conclusion that the dispute of facts must be awarded to those using names and signing up for their opinions without hiding.

After all, you have to swear in to give testimony in court, and you have to be ready for cross examination. Not that this is a court or a legal matter, but the fact is that the courts adopted those policies because they were the most sure way to find the real truth.
Nothing without 'oath and affirmation' should stand the test of law or logic.

This point is not made because I think anyone cares what I think as an individual, but rather to point out how actions can play out in the public opinion.

By tiffany fourment
From: boulder, co
Mar 3, 2006

Hello there,
You'll notice that I am a new member, and yes, I did register because I am interested in this issue. If, as was suggested, the fact that I just registered to discuss this makes my argument invalid or at least less acceptable than those of your long-time members, then so be it. I also included my full name, although again, I can't imagine that whether or not I choose to do that should influence whether or not others consider my point of view "valid". In general, while I did write to share my point of view on the topic at hand, the more I read through the posts the more it looks to me like some folks are just kind "running scared", looking for any reason to discount alternative perspectives on this topic. If the only reason that can be found for not fully considering other points of view is that they didn't include names or education or jobs, we're in a sad state, folks. In fact, now that I think about it, my post may be rejected because I have not capitalized letters correctly. That must mean I am not an expert on the subject.
I do not claim to be an expert, and I don't think I (or anyone else) needs to be in order to form educated opinions.
My questions for those out there are:

I have read the reports of both sides. Yes, Rob Ramey is an expert saying one thing. But are the USFS folks NOT experts on what they are saying? And could someone who is claiming "overregulation" please give a couple of reasons WHY exactly they think that the USFS would just close stuff "willy nilly", when there is all of this debate over it? Can someone explain to me what they think the USFS has to GAIN from just randomly calling a closure, if it is as superfluous as folks are claiming it is? What would be their motivation, I wonder, for causing all of this turmoil, if there really was no reason whatsoever to close the area?

I am a climber, as well as a naturalist, but for me, the naturalist comes first. I know (hope) that nobody can deny the incredible amount of habitat (and yes, POSSIBLE habitat that may not be used at this exact moment, but may be available for the future) destruction that has occurred in our beautiful area due to people people and MORE people. While I respect the rights of all of us to hold our various opinions, I simply cannot understand the mentality of people who minimize the rights of any other type of life in order to assert the right of humans.

I will continue to love climbing, and I will continue to appreciate the right of other beings to CHOOSE where they can live out their existence, just as I do. It seems simple to me. I can choose to climb in another area, and I'll have a great time doing it. Easy! and I'll write letters, and team up with other people who may or may not climb but also have the ability to look outside of their own desires, to back up the USFS on their closures, because some things are just more important to me.

Feel free to rip me apart, dismiss me, or write with questions. I have not intended to attack anyone, and I appreciate openness to debate.

By Andy Moore
Mar 3, 2006

I'm a climber and not a naturalist, and I think it makes sense to keep Security Risk and other potential nesting sites closed to climbers until it is clear that raptors have not chosen those sites for nesting. It is logical to me that if you never give the eagles or other raptors a chance to nest at a certain crag that they will choose another crag less popular with humans at this time of year, even if it is not their first choice. Give them a chance to make that first choice, and then open up other crags not chosen.

By the way, I've been an Access Fund member for many years, but I am disappointed in their apparent position on this issue and will not keep that membership if indeed the AF takes a strong stand on keeping these crags open without compelling reasons. I don't consider the current reasons compelling enough.

By Rick Thompson
From: Mount Nebbiolo, CO
Mar 6, 2006

Tiffany, Bob, Andy, Tony, et al

The closure of Security Risk was a recent addition to the long standing Eagle Rock/Blob Rock closure. It was implemented about 4 years ago after a climber reported by phone to the USFS having seen an eagle flying the vicinity of Security Risk crag. To my knowledge, along with the report in Rossiter’s two-decade old rock climbing guide to Boulder Canyon in which he labeled it an “eagle nest”, these two vague reports were the basis of the Security Risk closure. Just because someone says in printed material that it’s one, doesn’t make it so. And just because a climber sighted an eagle in the area doesn’t mean the nest on the ledge at Security Risk is an eagle nest or that the eagles have ever nested there or have any interest in the nest.

In the past 25 years there has not been a single documented or confirmed nesting of golden eagles at that nest. It was not until the very recent inspection of the nest by Dr. Ramey and CODOW Raptor Biologist Brent Bibles, which came approx. 2½ years after the initial implementation of the expanded closure, that any hard scientific evidence was collected. While it seems strange enough to me that public lands could be closed on such minimal, unsubstantiated information, it challenges my imagination that no one at the USFS chose to learn more sooner. It was more than 2 years after the initial closure that a qualified team of experts actually inspected the nest to determine is status and verify whether or not it was indeed a bona fide eagle nest. When evidence was eventually gathered it proved otherwise. That evidence, along with visual sightings, indicates the nest has not been used by eagles as far back as monitoring of eagle nests in Boulder Canyon began. The egg shells found in the sticks that comprise the bottom of the nest were ruled out by CODOW Raptor Biologist Brent Bibles from being eagle shells. In addition, Dr. Ramey has indicated that the nest is too small in physical size for eagles to nest – this perhaps the single most important piece of information from which to formulate a reasoned conclusion. It wasn’t until the recent December 2005 meeting we had with the USFS that the insufficient size of the nest was pointed out to the USFS. And while they seemed surprised by this, they have to this point ignored this important finding. I can only gather the USFA holds out some remote glimmer of hope that someday eagles will whimsically decide to squeeze themselves into an undersized nest that has not been used by their specie in the past 25 years, and most likely never. We don’t believe that hoping and wishing for such an outcome is a sound legal basis for a closure of public lands.

It should come as no surprise that at the national level there is currently discussion, even a proposal, centering around the establishment of a “nest abandonment thresholds”. In other words, a timeframe, after which, through non-use, a nest would be considered “abandoned” and thereby not subject to seasonal nesting closures or other protections afforded under law. The initial proposal established a 3-year timeframe after which the nest should be considered abandoned - 8 times longer than the 25 years of undocumented eagle nesting at Security Risk.

Andy, I was no doubt disappointed to read your last paragraph. The Access Fund takes the responsibility associated with its work in the arena of climbing advocacy and cliff/mountain conservation quite seriously. We consistently work to employ the utmost due diligence and care prior to adopting positions on matters such as this. Often that position is delicate and nuanced, but we always strive to balance our representation of the million+ rock climbers across the US in the most responsible fashion possible. In the arena of protecting raptor nesting sites we took the national lead in the late 1990’s when we published the first-ever guide to managing such restrictions. We brought land managers, wildlife biologists and climbers together to accomplish this. We have worked in partnership with public agencies and private land owners at quite literally hundreds of raptor nesting sites across the U.S. to support such closures and educate climbers of their importance. I am quite confident the greater cause of protecting raptors has benefited immensely as a result of our work. That said there is an important distinction with regard to this closure: every other case has involved nesting sites with a proven track record of nesting by the subject specie. The Blob/Eagle Rock aspect of the subject closure are perfectly justified and we continue to support it, but we take exception to the Security Risk aspect of the closure because there is a complete lack of demonstrable basis for it. Why else would the esteemed Dr. Rob Ramey, one of the most-knowledgeable and experienced raptor biologists in Colorado, indicate it serves so purpose is furthering or protecting Golden Eagles. I hope you can appreciate this paramount distinction. All things considered, The Access Fund cannot be all things to all people and it is often the case that matters such as this cause a shrift within our ranks. I only hope that when one of our members finds themselves in an internal philosophical tug-of-war they weigh the matter at hand carefully and ask for clarification of our position, should it be needed, before deciding to withdraw their support. In this case I remain convinced the Access Fund and the Friends of Boulder Canyon have taken a responsible and logical position. To that end I continue to be miffed why the USFS service remains stubbornly entrenched in their position, especially in light of the absence of evidence supporting the idea that the Security Risk nest is, or ever has been, an eagle nest.

Like Tiffany, I consider myself a passionate aficionado of the great outdoors – a naturalist if you will. I believe this is true of the vast majority of climbers. Unlike Tiffany, I am not inclined to prematurely show bias either way, but rather carefully weigh the influences and make an informed and balanced decision. If, for a moment I thought our position would in any way compromise the health and well-being of the nesting eagles in Boulder Canyon, I would support the Security Risk aspect of the closure. But there remains no logical basis for supporting it.

One last thought – while I have no validating acronyms to associate with my name (i.e. – BS) I have personally worked on seasonal raptor nesting closures for nearly two decades. During my service as the Access Fund’s National Access Director from 1995 through 2000 I worked directly with land managers, biologists and climbers alike to protect these important sites. It is a noble cause to which I continue to be committed to and to support, WHEN such closures are grounded in a factual basis, sound science and the responsible practice of lands management policy.

Best regards,
Rick Thompson
Friends of Boulder Canyon
Access Fund - Front Range Regional Coordinator

By Rick Thompson
From: Mount Nebbiolo, CO
Mar 6, 2006

Perhaps this letter from Dr. Rob Ramey to Beverly Baker, Wildlife Biologist, USFS, submitted in January, 2005 will help illuminate the issue at hand:

Bev,

I just heard from Chris Archer that the USFS will be closing the Security Risk Crag again this year as part of the golden eagle nesting closure. I know that you are trying to do the right thing but I thought that we had been through all of this before.

I disagree with this broad of a closure for the reasons that I stated in earlier communications and at the meeting we attended at the USFS. Basically, protection of wildlife and plants should be based upon real, observable threats and not hypothetical threats. Such an opinion-based approach to wildlife management needlessly restricts public access to public lands, erodes confidence in agency decisions, and diverts resources away from other wildlife in need of protection.

Being a scientist, I treated the Security Risk nest site as a testable hypothesis of eagle nesting. The critical test was straightforward. Are there any observational data or physical evidence supporting its use (e.g. laying of eggs or fledging of young)? As you may recall, consideration of this site as an active golden eagle nest failed the test for two reasons.

First, there is no demonstrated use as a nest in at least 24 years. Second, it was the conclusion of Brent and I that the eggshells in the nest were not eggshells from golden eagles (Brent and I are both very experienced with raptors.). That leaves only a very remote possibility that the very old and very thin egg shells in the nest structure could be from golden eagles.

While you could rely on expert opinion, I encourage you to do better. Seek quantitative analysis by asking Brent to measure the eggshells and run an analysis of variance test on that data compared to the shell thickness data that I had sent to him. If they are significantly different, then this is clearly not an eagle nest and you have the data to support opening that cliff to the public. This should take only one to two hours to complete.

While such a closure can seem like a small detail, its greater importance is in the fact that the public is facing these types of closures across the country and at an increasing rate. We need to both protect wildlife and be fair to the public. When ever we can bring objective hypothesis testing to the process, both benefit.

Best wishes,
Rob
Rob Roy Ramey II, Ph.D


Subsequent to this letter being submitted to the USFS Dr. Brent Bibles completed the testing of the eggshells and ruled out the potential they were eagle shells. I hope this further explains why the Security Risk closure is unwarranted.

By Theo Barker
From: Loveland, CO
Mar 7, 2006

Don't confuse me with the facts! My mind is made up. ;-)

By Kevin Stricker
From: Evergreen, CO
Mar 19, 2006

If you think that the USFS is an altruistic organization dedicated to the preservation of our forests and wildlife then you truly are living in a fantasy world. When I hear that raptor experts have tested the site and that the Access fund is backing them I have to ask what evidence in the contrary that the USFS possesses? Unfortunately we will never know if this evidence exists, for it is easier and less expensive to let the closure remain in effect than take any action.