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Frame Problem for Bats

The frame problem is discussed in Shanahan, M., 1997, Solving the Frame Problem, MIT 
PRESS, summarised very briefly here. The AI community uses the 'frame problem' as 
shorthand for the difficulties that arise when the effects of actions and events are 
represented in formal logic. AI researchers start from two premises: "The best way to 
understand intelligent behaviour is as the product of correct reasoning on correct 
representation." and "The best way to explicate the notions of correct representation and 
correct reasoning is through formal logic." This leads to a situation calculus that reasons 
about situations, fluents (properties that can change), and actions. The naive situation 
calculus has an enormous number of axioms (approximately #fluents x #actions in number) 
that mostly state: "When you take this action, that fluent doesn't change." Much of the work 
on the situation calculus has revolved around ways to drop all those 'stays the same' axioms.

I'm constantly exposed to this perspective in my robotics work. My background, however, is 
in bat behaviour. Now I suggest echolocating bats are reasonably intelligent animals that live 
mostly in an internal model of their external environment. (See references to the 
Wiederorientierung phenomenon for the argument.) A motor action by a flying bat changes 
almost everything about the mapping between the external environment and its internal 
representation. Hence, for a flying bat the situation calculus has few 'stays the same' axioms 
that might be dropped. Yet bats are able to make a living.

It's unlikely bats represent actions and fluents as discrete 'things'. I suspect almost 
everything in their internal model is a distributed pattern of neural activity. Either the 
patterns are stable, and the transformation from what they hear to pattern updates is very 
complex; or the transformations are stable, and the patterns change wildly as they 
manoeuvre in the air. How do you reason on that?

So, has anyone thought about what intelligent behaviour in animals says about the frame