Comments on the Road 18 Caves EA by Charles Larson

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Charlie Larson's comments on the Road 18, Lava Caves Environmental Assessment.

Mr. Larson is author of:
Caves of Oregon: Oregon Speleological Survey Bulletin 49, second edition.
Larson, C.V. and Larson, J. 1996.
Vancouver: ABC Publishing.
13318 NE. 12th Avenue
Vancouver, WA 98685
May 15, 2000

Les Moscoso, Team Leader, Road 18 Caves EA
1230 NE Third Street, Suite A-262
Bend, OR 97701

Dear Les:

This letter is my response to the Road 18 Cave Strategy and Road 18 Cave Environmental Assessment.

First, regarding the terminology in the Cave Strategy and EA: Terms like "unique" and "eliminate," which have very narrow well known meaning, are so pervasive that a
question arises, is the writer serious? I suggest that "eliminate" be replaced with "reduce," unless elimination is a realistic goal. Some of the phrases are ambiguous; e.g.
"unique microclimate" and "unique vegetation" and are not defined in the Strategy, EA, or anywhere else in speleological literature. (The only thing unique about the Road 18
caves is their geographic location and their alteration by human activity; three of the system's caves were once sterilized by fire.) The strategy seems topsy turvy. The
emphasis is on things that can't be fixed ("restored"), either because they are gone, or because no one knows what the natural condition is or was, while some serious
threats to the underground are minimized or ignored. Also, regarding "opal:" Opal is a general term for siliceous minerals, but it also connotes a gemstone. I suggest the
phrase be replaced by "calcareous and siliceous speleothems."

In general, it seems to me that this Strategy and EA have wandered a little far field. Recreation is the highest and best utilization of the Road 18 Caves, but the Strategy and
EA seem bent on discouraging it. Except for the efforts to educate the caving public, every remedy offered is aimed at discouraging recreational use in one way or another.

The term "significant cave," which entered the speleological world in the FCRPA, literally meant significant as compared to other caves, and did not convey any other
meaning. Accordingly, the argument that "common wildlife" (Strategy, p.3) or "wildlife habitat" (EA p.2) is affected by caves is a hard sell. The Strategy and EA focus too
much on banal abstractions; implausible relationships between caves and the subaerial world; and feel-good issues like "solitude," "sense of discovery," "heritage values,"
when it is the subterranean system that is threatened (see below).

The caves of the Arnold and Horse lava tube systems are no longer part of a natural landscape, and haven't been for centuries. They are part of a cultural landscape; some of
the caves are close to becoming part of an urban landscape.

At least as early as 1370 AD(1), and probably earlier, prehistoric hunter/gatherers "who lived in the litter and often filth of their cave homes(2) turned the mouths of these
caves into unsanitary landfills, littered the area with stoneworking debris, imported who knows how many alien plants and seeds, painted doodles on cave and sinkhole
walls, and built huge fires inside the caves - fires large enough to sterilize the caves and contaminate the vadose zone for perhaps miles if the subterranean air shed
happened to be sucking air at the time.

There is little record of recreational use of the caves prior to World War II, but bootleggers contributed to the unsanitary landfills in the cave openings and undoubtedly
smoked the vadose as the Indians had before them. Amateur artifact collectors turned the sinkhole landfills upside down. Biologists, some well meaning and some self
serving, and groups of students from OMSI led by those biologists, and State workers investigating the prevalence of rabies, decimated the bat populations in the caves. The
area was logged in the '20s and as a consequence ground temperatures changed. Indeed, the only thing literally unique about these caves is the degree to which they have
been impacted by human activity.

Following World War II recreational caving grew roughly as the city of Bend grew. It will continue to increase unless the city stops growing. There is both good and bad
news. The good news is that the general public doesn't mind that the caves are worn and torn; e.g. consider the hundreds of thousands of people who enjoy Lava River Cave,
or Ape Cave at Mount St. Helens, despite the fact that those caves are virtually barren and heavily littered between cleanups. Who is complaining about the conditions they
encountered in Road 18 caves? Is it a vocal minority? Also, lava tubes themselves are virtually indestructible, and like campgrounds, parking lots and toilets, they can be
periodically dunged out, as good as new to the typical recreational caver.

To the average recreational caver the "sense of discovery" is quite different than it is to organized cavers who have had the opportunity to compare pristine and degraded
caves. A recent Bend Bulletin headline sums it up rather well: "Despite vandalism, Redmond Caves a good getaway." (Anyway, on a lighter note, how can it be claimed that
the sense of discovery is lost when its so common to find burned underwear in caves?)

The bad news is: Beneath the surface in central Oregon is a vast body of highly porous rock housing a vast system of underground cavities. How vast? Chitwood, the first
person to appraise it surmised that as much as one fifth of Central Oregon's underground is air filled space; and "From Madras to Chemult, this volcanic country holds at
least 30 cubic miles of emptiness."(3,4) And, keep in mind, this is just the unsaturated zone.

No one knows what percentage of these voids are interconnected, but holes in the ground that blow air for days at a time suggest huge vadose volumes. No one knows if
this vast porosity is a single system or several distinct systems, but there can be little doubt that the Road 18 Caves share a single system of subterranean cavities. The
cavities range in size from interstices between grains of volcanic dust up to the largest cavities, caves. Caves are simply the largest of these cavities, a pivotal distinction.

The cavities are arbitrarily divided by some biologists specializing in subterranean fauna into mesocaverns ranging in size from 1 mm to 20 cm (7.27 in.) wide, (9,28,29) and
microcaverns (less than 1 mm wide).(5,6) They could of course be classified in any number of other ways, but one characteristic is indisputable: the distinction between
caves and cavities smaller than caves. Caves are a minuscule fraction of all subterranean cavities. In central Oregon, for example, using Chitwood's estimates and the
aggregate volume of known caves, the ratio of cave space to all other subterranean space, is about 0.0000014. (This is a very rough estimate, especially since both volumes
are estimates.)

By volume, caves don't amount to much as part of the cavernous subterrane, however, they have a disproportionate role in trans-surface flows of mass and energy.
Regarding air flow they may be thought of as the arteries of the subterranean system. They are also a focus of subsurface injection of harmful substances into the system. If
a "watershed analysis" or holistic (ugh!)" or system analysis approach is appropriate, this other, far more important underworld cannot be ignored in the Strategy and EA.

The importance of protecting the other subterranean cavities i.e. smaller than proper caves(A)cannot be overemphasized. Those smaller cavities are instrumental in the
transfer of mass and energy to and from caves, and they are the real home of subterranean fauna.(7) The principal threats to this other underworld are either not adequately
addressed, or ignored altogether, in the Cave Strategy or the EA; they are:

1. Altering ventilation patterns:
Excavating new openings to caves, or closing or altering the size or configuration of existing cave passages or surface openings, or other wise interfering with the natural
ventilation patterns had the potential of being the greatest conceivable human impact on a subterranean system. It inevitably alters the pattern and rate of air flow (both
ventilation and internal circulation) to some degree. As a consequence, the system's enthalpy, hydrologic budget; and the condition and composition of subsurface air, are
affected. In short, the environment provided by the system , and in turn by the cave, is changed. In both the Strategy and EA, the effect on the cave environment of digging to
enlarge passages, or restricting passages in any way, is totally ignored; see Gates below.

2. Fire
"Fire is equally as threatening, especially if air is flowing into the subterranean system. Campfires in caves are not just threats to human health and life, they have the
potential of contaminating relatively large parts of the subterranean domain during periods of air inflow. The fires built by Indians in many central Oregon caves, especially the
huge fires in the Charcoal caves and Stout Cave, in the Arnold System near Bend, certainly sterilized the caves, and conceivably poisoned a large part of the subterranean
air shed if the wind was right. Range fires or forest fires - natural or otherwise - could of course be similarly as devastating to subterranean fauna. Smoke is not only toxic, it
lowers relative humidity, threatening the hydrophilous species. Any use of tobacco underground is threatening to small animals. Although the smoke is not ordinarily enough
to significantly lower humidity, nicotine in that smoke, and in the leftover tobaccos is a potent insecticide."(8)

The restrictions on fire need at least the emphasis placed on that dreaded substance climbing chalk, and the effect of surface fires must be recognized in management
decisions. It is difficult to say which is the greater threat, altering ventilation patterns or fire; either is potentially devastating to subterranean fauna.

3. Paints:
Solvents and propellants associated with spray paint are threats to subterranean fauna, although typically far less threatening than either of the above. Is the possession of
spray paint banned?

4. Litter
Most litter in caves is inert(9) and, though unsightly, is not particularly threatening to the subterranean environment. As a matter of fact, several noted cave biologists
recommend that certain kinds of litter be left in impacted caves. However, human body waste, in addition to being repugnant, destabilizes subterranean biotopes by
enrichment and at some level could conceivably contaminate ground water.

5. Liquids
Liquids of any sort, toxic or not, are potentially damaging to the subterranean system because as they percolate downward they may carry contaminants with them.
Washing walls is not a good idea.

Gates:
While everyone marvels at the ingenuity and forethought of public and private cave developers who construct air locks to preserve the natural cave environment, modern land
managers increasingly obstruct wild cave openings with gates, apparently without regard to the cave or subterranean environment.

a. Why are not cave gates subject to the same intense scrutiny as bolt anchors for example, when altering cave ventilation has the potential of being the greatest
conceivable human impact on a cave system? Gating a cave or cave passage should require at very least an EA, and perhaps an EIS because of the potential for
widespread disturbance of the subterranean environment. And, on the subject of exemption from environmental concerns, why are cave closures exempt from NEPA?

b. Gating a cave ought to be straightforward: there are only two considerations. First, of course, is the need. The second consideration is: How (not whether) will the gate
impact the cave environment. Do all cave gates significantly affect the cave environment?; of course not, but magnitude and significance of the disruption is not predictable
without, as a bare minimum, a guesstimate of the system's size and its inflows, outflows, and accumulations of mass and energy.

In the Cave Strategy, the need for gates keeping people away from bats (the sacred cows du jour) is at least plausibly set forth, but the Strategy and EA are silent regarding
the certainty of accompanying environmental change. Despite stern warning against the perils of gating, from various well known authorities on the subject, the Cave
Strategy recognizes no environmental consequences of gating, offering instead a bunch of asinine euphemisms like "zero airflow restriction gate," suspensions or outright
denials of natural laws, and immunity from environmental assessments.

Please note that the following quotes address the effect of, not the need for a gate.

"Bat gates, installed as management efforts, have at times increased predation on bats... The decision to gate a cave or mine should be made only after careful analysis,
baseline microclimatic and airflow measures and baseline monitoring for bat use... careful microclimatic monitoring before and after installation is also essential to assess
potential impact to bat species... If temperature or humidity is changed more than 2% the gate is not acceptable... Welding creates fumes which may be noxious... The
decision to gate a cave or mine should be made only after careful analysis, baseline microclimatic and airflow assessment, predator access considerations, and baseline
monitoring for bat use... Therefore, when contemplating activities for the protection of bats, it is important to remember that other organisms are involved... Before place a bat
gate, the impact of gate construction on other resource values must be assessed."(10)

"Welding fumes can be very toxic, especially if the metal being welded contains zinc or other elements... Welding in caves should be preceded by a study of air movements
to see if contaminants will be naturally blow out of the cave entrance, or else a temporary exhaust system should be used."(11)

"Gates may alter air flow patterns and thus potentially alter the cave environment in such a way that the cave is no longer a suitable habitat."(30)

"... some gate structures result in negative effects, such as the bats can or will not[stet] fly through them and they restrict wind flow, important to temperature
regulation."(12)

"In brief, structures which in any way alter air flow should be avoided. Any structure which blocks an entrance can affect not only airflow, but also the supply of food (in the
form of entrance debris) for those cavernicoles requiring in-cave sources."(13)

"Many cavernicolous animals are thought to be extremely sensitive to even slight changes in air flow, temperature, and humidity."(13)

"...we do not recommend gating caves except as a last resort, because of often severe environmental effects from cave gates and their susceptibility to vandalism... the
distribution of webs changed markedly after a cave entrance was gated... Generally speaking, we feel that gating should be avoided in the Cave Basalt if at all possible.
Gates often have a severe impact on the caves or species they are supposed to protect, and of course gate construction is bound to impact the entrance flora and fauna."(9)

Reference Condition: Strategy.
Why is the Reference Condition set at 1870? Except for the evidence of centuries of Indian occupation, no one knows much about the condition of these caves in 1870 or
earlier. The earliest extant literature regarding them (Oregonian, 1889) describes Indian lodges in the Hidden Forest trench. It might be advisable to set some other time as a
reference condition, because it was around 1870 when the first settlers arrived in central Oregon, and some might say that this smells suspiciously like racial bias against
white Europeans. The Strategy and EA can be read as implying a pre-1870 aura of naturalness, sweetness, solitude, light , and good vibes; all snuffed out by those rascally
settlers and their descendants.

Action Common to All Caves:(EA)
1. Information kiosks: Excellent, the best of the EA proposals.
Because caves are secluded places and constant supervision is prohibitively expensive, management and installation of caving ethics must take place before the visitor
enters the cave. In the long run, education has the greatest potential of conserving caves and of making their maintenance affordable.

"The future of caving depends on educating people... if you present the information in the proper manner [in a manner that they will take to hear], and give a good
conservation message, 99 percent of the people will take that message back to them." Cave Conservationist 16(4):4.

"Education of the public is the best preventive to avoid graffiti."(14)

"...[education] may in the long run be most effective in cave preservation... if people can be made aware of the aesthetic and scientific values of caves they are less likely to
cause damage to a cave."(15)

"Effective public education is probably the single best way to ensure acceptance of sound management policies."(16)

An occasional display ad in the Bend Bulletin, outlining the need for cave conservation and good caving manners, would be money well spent.

2. Bats
Locking up certain of these caves for the exclusive use of bats and biologists would be far more justifiable if it was preemptive, but it doesn't even have that saving grace. It is
an impulsive, exclusive use of not just public property, but public property with a long history of unfettered human use.

In the belief that caves are essential to the survival of C. townsendii-and without knowing the whereabouts of these bats for months at a time-and the knowledge that they
roost not only in caves, but mines, and tunnels, buildings; bridges,(B)hollow trees; bird houses; and crevices-and despite evidence that they get by elsewhere without
"solitude;"-and despite the existence of many other cave roosts within the bat's range-and the existence of Stookey Ranch Cave about one mile away from Wind Cave,
described as "most important hibernaculum known in central Oregon" ..."during the winter months this cave protects 60% of [C. townsendii] in central Oregon,"(12) a
population that was "steady" as recently as 1996;(17)- it was deemed imperative that Wind Cave not only be protected, but that roads into its area be closed to free access.
It could be said that this action begs for a logical explanation.

References supporting the assertions (above) are too many to include in this document. I have offered references as well as copies of pertinent literature, in the past, to no
avail.

3. Parking lots:
Moving the parking areas will not reduce percolation of oil and other contaminants into the subterrane, it only moves the focus of injection away from the immediate vicinity of
a cave. However, the threatened biota is not in the cave, but in the subterranean system-e.g. "Skeleton Cave which is relatively dry appears to be barren of cave biota."(18)
The real threat is the presence of automobiles on and contaminants from Road 18 traffic which far exceeds that from parked cars by several orders of magnitude.

A short walk to popular caves harmlessly discourages fortuitous visitation, like beer parties; e.g. as demonstrated at Ape Cave (Mount St. Helens) and Lava River Cave.
However, moving the parking lot away from the cave also discourages visitation by the aged and infirm. The 2/3 mile walk to Wind Cave(0.9 miles on the drawing) is so
unreasonably far that it seems designed to severely handicap, not just moderate, recreational use of Wind Cave, and in effect would deny access to that entire area. It would
not only bar most recreational use, it will alienate locals who-rightly to some extent-see these caves as theirs, and also provide far more incentive to drive around it. This
would effectively close the cave to recreational use and increase traffic in other caves.

Deg Cave" "Closed to all use" is not precisely the case; it is summarily set aside for wildlife management; specifically the bats.

Climbing:
The issue of rock climbing in caves once seemed to be a tempest in a teapot, about on a par with tall tree climbing so roundly deplored in Audubon Magazine (Sept.-Oct.,
1995). The reaction of a few self serving individuals, besides being appallingly hypocritical, was so far out of proportion to physical damage to the caves, that it seemed only
a matter of time before common sense and reason prevailed. However, the issue has assumed the characteristics of a jihad. The Road 18 Cave Strategy, the EA, and even
Forest Service rhetoric as reported in the media seem permeated with irrational vindictiveness. Is there a subjective component to policy on climbing in caves?

How can an agency entrusted with the welfare of caves rail against the one time displacement of about 200 peanut sized pieces of basalt bedrock (roughly a 4.8 inch cube
distributed over 200 bolt holes) and at the same time ignore the deposition of a greater volume of human body waste (urine and feces) every weekend that Lava River Cave is
open? How can the chalk lines, and all but invisible bolt anchors left by rock climbers be so bitterly denounced, and a hideous steel monstrosity like the gate on East Lava
River Cave-or the one proposed for Wind Cave-be condoned? Surely this requires a selective sensitivity. One thing is abundantly clear, the District needs to retain someone
who is not offended by, and who can distinguish between, pictographs, spray paint, mineral films, climbing chalk, dry lichen, dehydrated rat urine, or bird guano.

Also, if magnesium carbonate is an ingredient of climbing chalk, it would be wise to ascertain if the thin whitish precipitates on the walls and breakdown, especially in Wind
Cave and Stout Cave, are or contain magnesium carbonate, a substance sometimes comprising caliche. If so, Hill and Forti; 1986, 1997)(19) will surely be interested in
knowing that what they describe as a fairly common class of speleothems (magnesium carbonates) might be such a potent reagent.

Charlie the Cave: exactly where would the gate be; were there bats in there prior to excavation; and has any consideration, study, etc. of the cave environment and
ventilation pattern been made?

"Rock art" ("archaeological graffiti"(20)) may be protected under other laws and regulations, but not under FCRPA; it is not natural.

Stout Cave: The statement on p.25 (strategy) is ambiguous: should not the statement read "...absence of human use..."?

Biota:
Regarding the "...unique microenvironment located at each cave entrance." I mean no offense, but frankly, this sounds like gobbledegook. The plants listed are common as
dirt in similarly sheltered sites all over central Oregon, and Oregon Grape is the state flower isn't it?

Does "unique" mean limited to surface depressions (collapse sinkholes and collapse trenches) associated with cave openings, or are depressions with impassable openings
included? How is the microenvironment defined? Is it inside or outside a cave, or both?; or is it the "plant community" itself? Common plants grow sporadically far beyond
their normal range in surface depressions, everywhere, but that does not make them unique to depressions. If anything, it makes them preadapted. The same plants and
plant associations flourish in dozens of depressions associated with the Arnold System, whether or not they include a cave opening, and in hundreds of similar depressions
all over central Oregon.

Hollows (surface depressions) typically have distinct microclimates, with or without caves. These microclimates depend chiefly on the width/depth ratio and orientation of the
depression. For a detailed explanation of this common phenomenon see Geiger.(21) The fertility of these depressions depends chiefly on proximity of water, and soil formed
of wind blown silt trapped therein.

There is a large body of data, research, and literature regarding the effect of the atmosphere on caves, but virtually none about the converse, because caves have no
significant effect on the atmosphere. The explanation of how cool cave air benefits plant communities is certainly a novel hypothesis, but I cannot make sense of it. I am
guessing that this is the same conjecture offered by Bureau of Land Management (1996)(22) whereby plants in the "unique microclimate" of "sinkhole areas" benefit from
moist cave air. Atmospheric pressure fluctuations (cited in the Road 18 Cave Strategy) are a cause of cave air flow; one of several. However, it is the only cause that
presumably cancels out; i.e. over time the volume of atmosphere flowing in must equal subsurface air flowing out. Would plants therefore benefit only half the time?

The ground temperature, and consequently the temperature of motionless or slow moving subsurface air, in the Bend area, is about 45F. For the sake of argument, suppose
the cave air temperature to be the anecdotal 45F, and ambient sinkhole temperature to be 45F or lower. Cave air is humid. The atmosphere at 45F in the Bend area would be
drier than subsurface air(C). At ambient sinkhole temperatures of 45 or less, condensation of water vapor from cave air could occur if it could mix with cooler air in the
sinkhole; if somehow a lid could be placed on the sinkhole. However, humid 45F air emerging from a cave, being lighter immediately rises into the atmosphere(D). This is a
common phenomenon and is manifested by plumes of "steam" (fog) rising from surface openings on frosty morning, a familiar sight in central Oregon.(23) Since humid cave
air leaves the sinkhole before significant(E) condensation can occur, and condensation of moist 45F cave air can't occur at ambient sinkhole temperatures above 45F, how
does the plant community benefit? If supporting data, research, or literature exists, please advise me.

Second paragraph, page 2, Cave Strategy:
"Solitude" is not a cave resource (neither is the "sense of discovery"). A cave resource is "material or substance."(24,25)

"Stable temperatures:" Cave temperatures are far less changeable than surface temperatures, but they are definitely not stable. Cave temperatures vary widely over space
and time: diurnally, seasonally, annually, during all sorts of meteorologic events and anomalies, following forest fires, and in response to human intervention. Temperatures in
lava tubes are especially variable because of their relatively thin overburden.

For example: A common temperature deep within Young's Cave in the Horse System (not much unlike Boyd or Skeleton caves) in July was 11C (52F), varying +-1 C
diurnally. The following February the temperature at the same place was 4.4C (40F), varying +-1C diurnally.(26)

On an August day in 1976, the dry bulb temperature three feet above the floor 100 feet into Skeleton Cave was 57.6F;47.8 at 1,100 feet; and 43.0 at 2,200 feet, the end of
the cave. Although no corresponding winter temperature observations have been published, rest assured that the temperature gradient would be reversed in the cold season.
Air near the entrance would be at or below freezing periodically; at the cave's end it could even be several degrees warmer or colder than during the summer, depending on
the temperature lag through the overburden.

"hydrologic values:" Is this the "hydrologic" cave resource that miraculously appeared in the FCRPA Regulations, without definition?(25) "Hydrologic" was not enumerated in
the FCRPA. (Neither was air.): and in fact, the FCRPA specifically excludes certain water resources. The Bend Fort Rock District may have the distinction of defining
hydrologic cave resources.

I am guessing that this is in reference to the saturated air in the vadose zone that provides habitat for moisture loving animals whose home is the spaces in fractured rock;
animals that wander into caves from time to time. Mesocaverns are the real home of the "Common [vertebrate] wildlife species" (and many others) listed in the Strategy, to
which they withdraw when disturbed by people. Oddly, packrats do not seem to be much upset by the presence of people; their behavior is commonly curiosity rather than
fright.

"These caves (Youngs Cave Complex) do not appear to be much used by plants or animals other than by a local species of woodrat. Over the year of Lunar Base Research
Team baseline observations animal sightings were few and almost completely confined to entrance areas."(26)

There are no invertebrates in these caves that do not exist in far greater numbers in the surrounding network of fissures and small cavities. The animals listed do constitute
common wildlife species, all over the northwest, but the populations are not dependent on caves. Cave habitats are at most minor adjuncts to their real home, the
small-space habitat.

Geologic/Paleontologic:
These caves are very good examples of a well developed lava tube system, but lava tubes are not uncommon. There are more than 450 named lava tube caves in Oregon,
not including rockshelters, surface tubes, and unnamed tubes, which number in the hundreds. The Road 18 Caves were not, to begin with, very well decorated with lava
stalactites and stalagmites, and nearly everything that was easily broken or collected is long gone. The secondary mineral deposits consist almost exclusively of siliceous
or calcareous mineral precipitates in the form of evaporite films. These films date to a far earlier time and are now being extensively leached away by percolating and dripping
water.

Scientific/Educational: Is he use of Road 18 Caves as lunar analogues actually occur, or is this speculative? Studies were conducted in the caves on the Young's Cave
Complex (Horse System on the north edge of Bend) and in Derrick Cave(far south), but were Road 18 Caves so used?

Sure, there is a lot of speculation about "scientific" use, but it does not usually bear fruit. Applying the yardstick of publication, hardly any of the research on these caves is
scientific; especially taxpayer-funded agency research which rarely makes it to the public.

Table 9: Common Conditions, Goals, and Recommendations: Under Geology/Rock natural processes are supplanted by vandalism and defacement? What is a "rock
formation"?

Cave Evaluations, Ratings, and Classes:
Is this section of the Strategy devoted to just Road 18 Caves, or caves in general? For example: none of the Road 18 Caves [listed] are in anything remotely resembling
"pristine" condition. And what in the world does "used for display purposes only." mean? What is the biological resources rated "5" in Boyd, Skeleton, Wind, Bat, Deg,
Charlie...., and Stout caves?

Page 11: "caves" have been published?

Native Plants:
"No plant species or community of species is known to be indigenous to, or dependent on caves or depressions associated with caves. On the other hand, because caves
and entrance areas have been visited, occupied, or modified for millennia by prehistoric hunter/gatherers, and heavily visited by modern man, plant and animal communities
there are apt to include so many exotic species that a "natural" designation is impossible. Indians are known to have harvested and stored nearly 100 varieties of roots,
seeds, berries, and herbs.(27) And, who knows how many plants were introduced by bootlegging activity, or recent burgeoning recreational caving."(8)

If searching for a unique plant community associated with a cave, the last place to look would be the sinkholes associated with large cave openings in the Arnold System.

Air:
It seems odd to see "air" listed as a resource, and though technically it is, an interesting paradox arises, is it cave air only while actually in the cave, which may be briefly,
and is air discharged into the atmosphere still cave air? Atmospheric pressure change is one of several causes of cave air flow, but it is the only one that cancels out, and it
is not much affected by topography or vegetation. Whether or not air and liquid water are cave resources is of little significance, but their composition and condition are of
pivotal importance to the subterrane, because they carry much of what goes into subterranean systems.

The Existing Condition vis-à-vis air is not, however, the natural condition in these caves. air flow in the upper level of Charlie the Cave flow is attenuated by a gate; the lower
entrance was not opened until 1979. There are anecdotal reports that some rock was moved (excavated) by cavers visiting the depths of Hyphenated Cave, beneath the
Atrium in Stout Cave. Also, cave air flow (other than that cause by atmospheric pressure changes) would have been considerably affected by the pine forest once covering
the area.

To summarize:
Recreation is the optimal use of Road 18 Caves, yet every remedy but one - education- is aimed at discouraging recreational caving. Lighten up. The area of the Road 18
Caves is a cultural landscape, parts of it are what is known in fire fighting jargon as urban interface. In a way, the District is hoist on its own petard; these caves did not have
to be declared significant, as I pointed out to no avail at the 1993 meeting in Bend.

Restoration is not realistic. Even if possible, more friction between management and recreational caving would be generated. The best that can be hoped for is maintenance.
Clean them up periodically with volunteers, like the Adopt-a-highway programs.

Allow climbing in the mouths of a few of the caves, leave the bolts already in place, require permits (with no guarantee of acceptance) for new bolts, require that chalk lines
be acceptably unsightly; e.g. by using colored chalk or periodic cleanup, by the climbers, as a condition of future climbing privilege.

As for prehistoric graffiti: Avoid mentioning it. Time and weathering taking care of the problem.

Stop trying to saddle recreational caving with the misfortunes of a few bats. These bats face far more serious problems than cavers-like pesticide and hands-on researchers,
etc. If these few square miles and these few caves are the sole salvation of C. townsendii, then the District should arrange a quiet ceremony to bid them good-bye.

Concentrate all resources not necessary for maintaining the caves in a condition acceptable to the general public-vocal minorities notwithstanding-on the following:

1. Educate people about responsible behavior in caves. Given the proximity of the city of Bend, education holds the only hope of maintaining them in an acceptable
condition.

2. Minimize threats to the underground system (listed above).

Thank you for the opportunity to comment on the Strategy and EA.

Sincerely yours,
Charles Larson

REFERENCES
1. Cressman, L.S. and Perry, W. J. 1938. Charcoal Cave, an archeological puzzle. Oregon Historical Quarterly, Vol. 39, pp.39-49.
2. Bordwell,C. 1987. Fort Rock Cave: Monument to the "first Oregonians." Oregon Historical Quarterly 88:117-47.
3.Chitwood, L. 1985. Central Oregon underground world filled with wind that roars, whistles. Oregonian Oct.31.
4.Chitwood, L. 1985. Correspondence to Charles Larson. Date May 16.
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9.Senger, C. M. and Crawford, R. 1984. Biological inventory, Mount St. Helens Cave Basalt Flow, final report. Unpublished survey for U.S. Forest Service.
10. Howell, D.J., et al 1996. Management Recommendations for Townsend's Big Eared Bat, Corynorhinus (Plecotus) townsendii. Unpublished interagency document.
11. Elliot, W.R. 1998. Cave fauna conservation in North America. www.uetxas.ed
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17. Lew Becker, personal communication, 1996.
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A) Caves that fit the definition strictly and accurately.

B) There is a maternity colony of C. townsendii in a modern concrete highway bridge in eastern Oregon.

C) There could be sites in Oregon where subsurface air is drier than the atmosphere, but no one has described one yet.

D) Moist air will rise in the presence of drier air because water vapor is only about two thirds as dense as dry air. Fully water saturated air at about 45F would rise in the
presence of dry air at 45F.

E) There are circumstances where the rarefied air cannot escape before some condensation occurs; e.g. small openings where the moist air comes in contact with cold
surfaces. Not uncommonly, condensation occurs when moist, rising cave air contacts a sinkhole's free face above the drip line, sustaining mosses and even small plants.

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