I couldn't attach the letters so I cut and pasted them below.
Letter from RAMEY to BAKER re open sec risk, 20 January 2005:
20 January 2005
I just heard from Chris Archer that the USFS will be closing the Security Rick 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 a 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 me 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 eggshells in the 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.
I am in Frankfurt right now, on my way to Namibia to study elephants. I will out of touch for a while.
Rob Roy Ramey II, Ph.D.
Chair of Zoology and Curator of Vertebrate Zoology
Denver Museum of Nature & Science -----------------------------------------------------------------
Letter from Ramey to Baker December 15, 2005:
December 15, 2005
Bev Baker, firstname.lastname@example.org US Forest Service
I greatly appreciate your inviting me to the meeting and look forward to productive discussion on this and other issues.
I would like to offer a correction. I said, "The absence of evidence does not necessarily imply evidence of absence." I think that most epistemologists would agree that when long-term observations reveal a consistent of absence of evidence, support a particular hypothesis is no longer tenable. That is why some strongly held views can undergo substantial revision as negative observations (evidence of absence) accumulate, refuting the earlier view.
Twenty four years of consistent absence of eagle nesting at Security Risk is compelling factual evidence that this site is not an eagle nest (no eagle eggs, no eagle eggshells, no eagle chicks). Just because eagles have been observed to visit the site a handful of times, does not make it an eagle nest. Just because someone speculates that eagles have added sticks to the site does not make it an eagle nest. Unsubstantiated opinion of other "experts" does not make it an eagle nest.
The continued belief that this is an eagle nest, despite over two decades of evidence to the contrary, looks disturbingly similar to the behavior exhibited by those who believe in paranormal phenomena. While additional evidence is always called for, critical tests that could potentially falsify the belief are typically lacking. Like-minded authorities are called in and their opinions are used in support of those beliefs. Time and money are wasted, because courses of action are followed on the basis of belief instead of science. This lack of critical thinking jeopardizes the recovery of many species and undermines public support for genuine conservation efforts.
It is the criterion of falsifiability that distinguishes science from non-science. What observation would falsify the hypothesis that this site is not an eagle nest? The day that an eagle lays an egg on the stick-covered ledge on Security Risk Crag, it could be called an "active eagle nest". Until that time, it is an abandoned pile of sticks. If eagles use the site as a nest in the future, the USFS can easily extend protection to it - at that time. That is what adaptive management is all about.
I think that the US Forest Service has far larger conservation issues to deal with than protecting abandoned piles of sticks. That is why the U.S. Fish and Wildlife Service had developed a draft policy on what constitutes and active vs. inactive nest.
As I pointed out in our discussion, in several recent publications, and in my testimony to Congress on the Endangered Species Act: allocation of conservation effort needs to go to real, demonstrable threats rather than hypothetical ones. Otherwise, we will consistently squander scarce conservation resources, unfairly deny access to public lands, and fail to conserve the biodiversity that our society values.
Thank you for the opportunity to provide input.
Rob Roy Ramey II, Ph.D P.O. Box 386 Nederland, CO 80466
Dear Interested Party, The Boulder Ranger District is proposing to update the decision for seasonal wildlife closures in a golden eagle nesting territory in Boulder Canyon. On January 6, 2006, a letter was sent initiating scoping under the requirements of the National Environmental Policy Act (NEPA). Copies of the January 6 letter and accompanying map are enclosed. The letter requested that comments be postmarked by January 24, 2006. To provide an opportunity for additional comments, we are extending the comment period to March 27, 2006. To continue protection of the golden eagles in the Boulder Canyon territory while we allow additional time for public comments, we will implement existing closure orders effective February 1, 2006. Eagle Rock, Blob Rock (including East Blob), Bitty Buttress and Security Risk will be closed effective February 1, 2006 until July 31, 2006 unless monitoring allows reopening of some areas. Bihedral, Riviera, and Happy Hour remain open and will stay open for the 2006 season as long as the closures are respected. For your consideration, we are providing additional information below about the natural history of golden eagles, the Boulder Canyon eagle territory, and our reasoning behind these closures. Golden eagles are year-round residents in Colorado and are believed to mate for life, maintaining a pair bond throughout the year. They nest primarily on cliffs in Colorado, though they may occasionally use large trees. Nests are considered perennial once built, eagles continue to add material to them year after year. A golden eagle pair maintains an average of three alternate nests in their territory, which are separated by as little as 1 meter up to more than 5 kilometers. Golden eagles build or repair multiple nests during the courtship phase of breeding, beginning as early as mid December, and add material to nests year-round. When one bird of a pair dies, normally the remaining bird along with a new mate will switch to an alternate nest in the territory. Pairs may also switch to an alternate site due to buildup of parasites such as ticks, mites, blowflies, and lice, which can affect nestlings and adults.
In the Boulder Canyon territory, the golden eagles used Blob Rock in 2005 for the first time since 1992, and fledged one young eagle. In 1993 the eagles attempted nesting at Bitty Buttress and failed, and from 1994 through 2004 they either used Eagle Rock or did not nest. Recent nest success has been relatively low, with the pair raising and fledging one young bird only five out of the 13 seasons from 1992 through 2004. Reproductive success can vary with prey abundance and weather, but the annual reproductive success for this territory of 5/13 or 0.38 is low compared to several studies showing averages from 0.66 to 1.08 young fledged per pair per year.
Golden eagles have a long breeding cycle six months or more from courtship to young birds leaving the nest. Parental care continues for one to six months after young birds leave the nest. The most critical period to avoid disturbance to golden eagles is early in the nesting season, during courtship and incubation. Tolerance to human disturbance varies among raptor species and also among individuals. Golden eagles in general respond to disturbance at greater distances than some other raptor species. Some individuals may tolerate human activity closer than the majority, while other individuals may become sensitized to repeated encroachment and react at greater distances. Disturbance tolerance for a golden eagle pair may change when a mate is replaced. There is a lack of available research specifically addressing impacts of climbing disturbance on cliff-nesting raptors.
The Security Risk nest structure came to our attention in 2001, although it has existed for much longer, being referenced as an eagles nest in a 1988 climbing guide book. The nest is deep, with many layers, characteristic of eagle nests, and the lower layers are old and decomposed. Egg shells were retrieved from one of the lower layers and thickness measurements match those of raven eggs. Ravens also nest on cliffs, and golden eagles are known to use old raven nests. While we do not have documented use of this nest for egg laying or raising of young by golden eagles, large sticks have been added since 2001 to this nest, almost certainly by golden eagles, and the structure is that of a complete nest. This nest is within the golden eagle territory, is about ¼ mile from the nest used in 2005, and within a mile of other known nest sites.
Guidelines recommended by Colorado Division of Wildlife raptor researchers Gerald R. Craig (retired) and Brent Bibles include seasonal restrictions to human encroachment within ¼ mile of golden eagle nests and any alternate nests from December 15 to July 15. For the Boulder Canyon territory, based on incubation dates in recent years, closure beginning February 1 appears to be early enough to allow the eagles time to choose a nest site, while allowing winter climbing through January. July 31 allows enough time for fledging and a short period of parental care once the young birds leave the nest. Also, February 1 and July 31 are consistent with nesting closures for birds of prey on other local public lands. Buffer zones around some of the nest sites are less than ¼ mile due to topography and fragmented land ownership in the area.
The Boulder Ranger Districts strategy in implementing the Boulder Canyon seasonal closures is to allow the golden eagles time to select a nest site each season with as little human disturbance as possible, by closing areas in the vicinity of recently used and alternate nest sites. Through the efforts of volunteers and Forest Service employees, the area is monitored for eagle activity, and once nesting is verified, we reopen some areas to climbing and other activities. In three of the last four years, some areas were reopened by mid March.
Because of the popularity of winter climbing on south-facing slopes in the closure areas, in 2005 we left Bihedral and Riviera open, while Security Risk, Upper Security Risk, and Happy Hour, as well as Eagle Rock, were closed for approximately six weeks. The Blob Rock/Bitty Buttress area remained closed through July 31 because the eagles nested there. For the 2006 season, we are leaving Happy Hour open in addition to Bihedral and Riviera. These crags will remain open as long as climbers and other Forest visitors remain in the open areas and the closures of Security Risk and surrounding areas are not compromised.
Current status for the Boulder Canyon seasonal wildlife closures is located on signs posted in the area, and on the Boulder Ranger District web site at fs.fed.us/r2/arnf/recreatio….
Please refer to the enclosed January 6 letter for a description of the proposal, project location, and other pertinent information. Comments on this proposal should be postmarked by March 27, 2006 in order to receive full review. If you wish to remain involved and receive future mailings related to this project, please comment on the proposal or request to receive further information. Written comments should be emailed to email@example.com or mailed to: Boulder Ranger District, Attn: Beverly Baker, 2140 Yarmouth Ave, Boulder, CO 80301. If you have questions on this proposal or would like more information, please contact Beverly Baker at 303-541-2517.