[Nhcoll-l] NSC Alliance Washington Report - READ THIS ONE!
Kevin Winker
kevin.winker at alaska.edu
Thu Feb 19 15:47:07 EST 2015
One thing to keep in mind (there are a lot of offline discussions going as
well) is that historically paleo and cultural specimens/objects have been
treated very differently from natural history specimens/collections by
Federal agencies. So in this respect we are partially speaking past each
other. In natural history, by and large, so far, NPS was unique in claiming
ownership. So Matthew, you'll find a lot of disagreement among the group
over what exactly is a Federal collection -- a separate (but very
important) issue from untangling historic localities and land ownership.
Both issues are things that will require time to resolve and neither can be
accomplished with an information request.
Best, K.
On Thu, Feb 19, 2015 at 11:28 AM, Brown, Matthew A <matthewbrown at utexas.edu>
wrote:
> I'll try to walk through this in as straightforward a way possible, it
> will be longish, but thorough (this paragraph will also serve as the
> conclusion if you don't make it to the end.) The legal authority is very
> clear in both the MBTA and NPS examples, and I've included at the end the
> BLM repository instructions too, in response to the comment that NPS is the
> only agency that asserts ownership. I'm not arguing that museum collections
> management isn't difficult, time consuming, and expensive. I'm also fully
> aware that collections objects and records are often not in great shape,
> I've worked all over the country for nearly 20 years to conserve and care
> for them. I am however, arguing that holding Federal collections is an
> activity of special trust, with rules that we've explicitly agreed to be
> bound by in order to keep them, and that knowingly breaking the laws
> (especially without making a good faith effort to come into compliance)
> isn't an excuse if we happen to find them inconvenient. On to the nitty
> gritty...
>
> First of all, the laws specifically require compliance with the terms and
> conditions of permits. I fully realize that the CFR 50, Chapter 1,
> Subchapter B, Part 21, Subpart C, § 21.23 is the scientific collecting
> authority for the MBTA, and as I said last night, it doesn't authorize the
> holding of museum collections. In fact, § 21.23(c)(1) states-
>
> "(c) Additional permit conditions. In addition to the general conditions
> set forth in part 13 of this subchapter B, scientific collecting permits
> shall be subject to the following conditions:
> (1) All specimens taken and possessed under authority of a scientific
> collecting permit must be donated and transferred to the public scientific,
> or educational institution designated in the permit application within 60
> days following the date such permit expires or is revoked, unless the
> permittee has been issued a special purpose permit (See § 21.27)
> authorizing possession for a longer period of time."
>
> Ellen cites § 13.46 Maintenance of records, but §13.48 Compliance with
> conditions of permit, goes on to state-
>
> "Any person holding a permit under subchapter B and any person acting
> under authority of such permit must comply with all conditions of the
> permit and with all appllicable laws and regulations governing the
> permitted activity."
>
> The special use permit required by § 21.27 for a museum collection
> specifically require that the repository-
>
> "8.Will I be required to keep records of my activities?
> Yes. You must maintain accurate records of operations on a calendar-year
> basis. Your records should reflect each bird that is held, the number of
> presentations given with each bird and the disposition of each bird.
>
> 9. Will anyone inspect my records or birds held for educational purposes?
> By accepting a Federal Migratory Bird Special Purpose Possession Education
> (Dead) permit, you authorize an agent of the U.S. Fish and Wildlife Service
> to enter your premises at any reasonable hour to inspect the migratory
> birds in your care, your books or records. (50 CFR 13.47)
>
> 10. Will I be required to submit an annual report of activities?
> Yes. You will receive an annual report form for your Federal Special
> Purpose Possession
> – Education (Dead) permit from your Regional Migratory Bird Permit Office.
> The report form can also be found on our website at:
>
> https://urldefense.proofpoint.com/v2/url?u=http-3A__www.fws.gov_forms_3-2D202-2D5.pdf&d=AwIF-g&c=-dg2m7zWuuDZ0MUcV7Sdqw&r=CLFZJ3fvGSmDp7xK1dNZfh6uGV_h-8NVlo3fXNoRNzI&m=B--KlhjRftTu9vvpDDX3mZhEkShlubdxooioNZQSBqI&s=jiteua7QYGob77pRRk0crgrFeP6nuSygaC7bfwfKABY&e=
> . This report must be completed and submitted to your issuing office by
> January 31 of each year."
>
> Likewise, for the NPS, CFR 36, Chapter 1, Part 2, § 2.5 Research Specimens
> also explicitly requires compliance with the terms of collecting permits.
>
> "(a) Taking plants, fish, wildlife, rocks or minerals except in accordance
> with other regulations of this chapter or pursuant to the terms and
> conditions of a specimen collection permit, is prohibited.
>
> (b) A specimen collection permit may be issued only to an official
> representative of a reputable scientific or educational institution or a
> State or Federal agency for the purpose of research, baseline inventories,
> monitoring, impact analysis, group study, or museum display when the
> superintendent determines that the collection is necessary to the stated
> scientific or resource management goals of the institution or agency and
> that all applicable Federal and State permits have been acquired, and that
> the intended use of the specimens and their final disposal is in accordance
> with applicable law and Federal administrative policies. A permit shall not
> be issued if removal of the specimen would result in damage to other
> natural or cultural resources, affect adversely environmental or scenic
> values, or if the specimen is readily available outside of the park area."
>
>
> BLM language-
>
> "REPOSITORY RECEIPT FOR COLLECTIONS
>
> Artifacts and specimens recovered from BLM-administered lands are Federal
> property, and must be managed in a manner consistent with Federal
> stewardship responsibilities for museum collections. Cultural or
> paleontological resource permits for collecting activities require that the
> permittee arrange for curation of artifacts and specimens in an appropriate
> repository. Collections must be deposited in a repository for curation
> within one year of completion of the permitted project, unless alternate
> arrangements have been approved by the BLM permitting official.
>
> This Deposition of Museum Collections Confirmation and Inventory form is
> required as a condition of the permit and must be completed for all museum
> collections originating from BLM administered lands, with the associated
> documentation, to ensure collections are deposited in an appropriate
> curatorial facility. A receiving document generated by the repository may
> be substituted if it contains the same information as this form.
>
> Instructions
> 1. All information requested on this form must be completed by the
> permittee and repository officials.
>
> 2. Permittees must provide an itemized inventory of the objects,
> lots, samples, and associated documentation to be deposited attached to
> this statement. The inventory must include site or locality designation,
> number of units per material type according to BLM and the repository
> standards. A complete collection includes:
>
> · All artifacts, specimens, and environmental materials collected
> with provenience data
> · All survey or excavation records and logs
> · All maps showing locations and boundaries
> · All valid photographs, negatives, and slides
> · All analysis records, and copies of all reports and publications
>
> 3. A repository official must acknowledge receipt of the collection.
> Before signing, the repository official should compare the inventory to the
> actual objects and records being deposited.
> 4. If the permittee and the Repository Official are the same
> individual, an additional Repository Official must be signatory to this
> form.
> 5. After this form has been signed by the repository official, the
> original form with the collection inventory must be submitted the BLM State
> Archaeologist by the permittee.
> 6. Upon submission to BLM, the BLM official may contact the
> repository to verify the inventory of collections deposited by the
> permittee."
>
>
>
>
>
>
> > On Feb 19, 2015, at 6:04 AM, Ellen Paul <ellen.paul at verizon.net> wrote:
> >
> > The record-keeping requirement under the MBTA is actually not the
> regulation that pertains to scientific collecting.
> >
> > This is the regulation pertaining to scientific collecting:
> https://urldefense.proofpoint.com/v2/url?u=http-3A__www.gpo.gov_fdsys_pkg_CFR-2D2013-2Dtitle50-2Dvol9_xml_CFR-2D2013-2Dtitle50-2Dvol9-2Dpart21.xml-23seqnum21.23&d=AwIF-g&c=-dg2m7zWuuDZ0MUcV7Sdqw&r=CLFZJ3fvGSmDp7xK1dNZfh6uGV_h-8NVlo3fXNoRNzI&m=B--KlhjRftTu9vvpDDX3mZhEkShlubdxooioNZQSBqI&s=qGvl9HW7UvHARJR95VkYrxxdSm8MZ4043km960V__8M&e=
> >
> > This is the requirement under that section:
> >
> > (4) In addition to any reporting requirement set forth in the permit, a
> report of the scientific collecting activities conducted under authority of
> such permit shall be submitted to the issuing officer on or before January
> 10 of each calendar year following the year of issue unless a different
> date is stated in the permit.
> >
> > These regulations went into effect in 1974.
> > In addition, the overarching general permits provision says:
> > § 13.46Maintenance of records.
> > From the date of issuance of the permit, the permittee shall maintain
> complete and accurate records of any taking, possession, transportation,
> sale, purchase, barter, exportation, or importation of plants obtained from
> the wild (excluding seeds) or wildlife pursuant to such permit. Such
> records shall be kept current and shall include names and addresses of
> persons with whom any plant obtained from the wild (excluding seeds) or
> wildlife has been purchased, sold, bartered, or otherwise transferred, and
> the date of such transaction, and such other information as may be required
> or appropriate. Such records shall be legibly written or reproducible in
> English and shall be maintained for five years from the date of expiration
> of the permit. Permittees who reside or are located in the United States
> and permittees conducting commercial activities in the United States who
> reside or are located outside the United States must maintain records at a
> location in the United States where the records are available for
> inspection.
> >
> > As you can see, the legal requirements differ vastly from best
> collections practices.
> >
> > The NPS info you cited is a permit condition, not a statute or
> regulation. My point here is that many specimens collected on public lands
> managed by the NPS were collected long before permits were issued. Thus,
> this becomes a retroactive requirement that has no legal basis and that is
> extremely onerous.
> >
> > Beyond that, the point is that none of this was legally required between
> 1918 (when the MBTA was enacted) and some point in the early 1970s. So this
> is in fact a request for information that was not legally required at the
> time of collection and that is in fact onerous and extremely burdensome for
> many of your colleagues.
> >
> > Again, I point out that DOI estimates that it will take 20 years to
> compile the data for the materials in its possession and to do it in that
> time frame, they will need additional resources (lotsaluck with that).
> Accepting for the sake of argument that they have 90% of the materials and
> the non-federal facilities have 10% (how can they possibly know?), that
> means it could reasonably take the non-federal facilities an average of 2.2
> years, not 2 hrs, 20 minutes.
> >
> > Ellen
> >
> > Ellen Paul
> > Executive Director
> > The Ornithological Council
> > Email:
> > ellen.paul at verizon.net
> >
> > "Providing Scientific Information about Birds
> > "
> >
> https://urldefense.proofpoint.com/v2/url?u=http-3A__www.nmnh.si.edu_BIRDNET&d=AwIF-g&c=-dg2m7zWuuDZ0MUcV7Sdqw&r=CLFZJ3fvGSmDp7xK1dNZfh6uGV_h-8NVlo3fXNoRNzI&m=B--KlhjRftTu9vvpDDX3mZhEkShlubdxooioNZQSBqI&s=rh6b_3AQ0hPPaKIr0JN3HJDP0QhEZhbxpAJdYoqXWOE&e=
> "
> >
> > On 2/19/15 1:42 AM, Brown, Matthew A wrote:
> >> I am awash with wonder and befuddlement. The point has indeed been
> missed spectacularly. This ICR is a request for information that we are
> already supposed to keep. The point is that these aren't new regulations.
> It's a survey. As a professional research community, we should be
> responding to the call for comments. But we should also be in possession of
> the facts first.
> >>
> >> Ellen asked "Would appreciate seeing the actual statues and regulations
> (laws) that state that those permitted to collect on federally managed
> public lands are required to keep such detailed records. The reason I
> mentioned permits is that based on my own research, this is the only place
> this requirement appears (and based on permits for wildlife, I doubt any
> permits specify what information must be recorded and maintained)."
> >>
> >> Sure, each collection is different and has different requirements, and
> we ought to talk about them. Take ornithological collections, for example.
> Just the migratory birds, even. Below is the link to the Code of Federal
> Regulations, Title 50, Chapter 1, Subchapter B, Part 21, Subpart C, Section
> 21.27, Special Purpose Permits. My extant bird collection is built and held
> legally because, in addition to our state permit and several others, the
> USFWS issued a Special Purpose – Possession of Dead Migratory Birds for
> Educational Purposes permit, which requires, in part 1-
> >>
> >>
> >>
> https://urldefense.proofpoint.com/v2/url?u=http-3A__www.ecfr.gov_cgi-2Dbin_text-2Didx-3FSID-3D8e499d90225dbdd35842765573ed6836-26node-3Dse50.9.21-5F127-26rgn-3Ddiv8&d=AwIF-g&c=-dg2m7zWuuDZ0MUcV7Sdqw&r=CLFZJ3fvGSmDp7xK1dNZfh6uGV_h-8NVlo3fXNoRNzI&m=1FKQB8YNEoaKu6EsnuegYVyOpW-dL6c_MkAWVB1hb6Y&s=TP8x9JoHM9hQ094qEr8ghSUM8xbFQCHjDdPD2p6xCNA&e=
> >>
> >>
> >> "(1) Permittees shall maintain adequate records describing the conduct
> of the permitted activity, the numbers and species of migratory birds
> acquired and disposed of under the permit, and inventorying and identifying
> all migratory birds held on December 31 of each calendar year. Records
> shall be maintained at the address listed on the permit; shall be in, or
> reproducible in English; and shall be available for inspection by Service
> personnel during regular business hours. A permittee may be required by the
> conditions of the permit to file with the issuing office an annual report
> of operation. Annual reports, if required, shall be filed no later than
> January 31 of the calendar year following the year for which the report is
> required. Reports, if required, shall describe permitted activities,
> numbers and species of migratory birds acquired and disposed of, and shall
> inventory and describe all migratory birds possessed under the special
> purpose permit on December 31 of the reporting
> >> year.
> >> "
> >>
> >> So, that is the requirement just to hold migratory bird collections,
> the scientific collecting permit a few sections earlier in 21.23 requires
> reporting of specific locality info. I've got another, more specific permit
> with even more rules for holding Bald and Golden Eagles. With regard to
> Federal land, if those birds were also collected from NPS property under
> the required NPS collecting permit, for example, the following is an
> excerpt of what is required as conditions for collecting there-
> >>
> >> >From
> >>
> https://urldefense.proofpoint.com/v2/url?u=http-3A__www.nps.gov_yell_naturescience_npsconditions.htm&d=AwIF-g&c=-dg2m7zWuuDZ0MUcV7Sdqw&r=CLFZJ3fvGSmDp7xK1dNZfh6uGV_h-8NVlo3fXNoRNzI&m=1FKQB8YNEoaKu6EsnuegYVyOpW-dL6c_MkAWVB1hb6Y&s=XirIysMv9qeebOAd4PhtWRFWeyJrxoea0yJ-5adg38s&e=
> >>
> >>
> >> • New specimens must be reported to the NPS annually or more frequently
> if required by the park issuing the permit.Minimum information for annual
> reporting includes specimen classification, number of specimens collected,
> location collected, specimen status (e.g., herbarium sheet, preserved in
> alcohol/formalin, tanned and mounted, dried and boxed, etc.), and current
> location.
> >> • Collected specimens that are not consumed in analysis or discarded
> after scientific analysis remain federal property.The NPS reserves the
> right to designate the repositories of all specimens removed from the park
> and to approve or restrict reassignment of specimens from one repository to
> another.Because specimens are Federal property, they shall not be destroyed
> or discarded without prior NPS authorization.
> >> • Each specimen (or groups of specimens labeled as a group) that is
> retained permanently must bear NPS labels and must be accessioned and
> cataloged in the NPS National Catalog.Unless exempted by additional
> park-specific stipulations, the permittee will complete the labels and
> catalog records and will provide accession information.It is the
> permittee’s responsibility to contact the park for cataloging instructions
> and specimen labels as well as instructions on repository designation for
> the specimens.
> >>
> >> The Wildlife and Fisheries regs date to at least 1974 (and the
> Migratory Bird Treaty Act itself to 1918, also of note is the Lacey Act of
> 1900), and I already pointed out last night the stipulations from the early
> 60s in the DOI permit issued for Big Bend National Park (under the
> authority of the Organic Act of 1916 and the Antiquities Act of 1906).
> Permits are contracts. But seriously, this is Museum Studies 101. If we
> were to travel back to 1910 and try to explain to Joseph Grinnell why we
> were making excuses for not having locality data he'd kick us in the seat
> of the pants. I don't have 3 million specimens in my collections, only
> about a million and a half, dating back to the 1880s. So it's true that I
> can't appreciate the scale of Doug's particular problem, and I certainly
> wouldn't feel so inclined to be a jerk about it if it weren't for
> statements like "How do I know, then, when I collect something, if I am
> inside the park boundaries or if I am on the private property? Yes, if
> >> I
> >> have a good gps, I can check later" by the Executive Director of The
> Ornithological Council, which seems to justify illegally collecting in
> Shenandoah National Park because one can't be troubled to carry a map. The
> original survey of Mt. Everest in the 1850s was accurate to a height within
> 35 ft of modern methods, I would sincerely hope that a 21st century
> scientific advocacy group could figure out how to find a property line.
> >>
> >>
> >>
> >> Matthew A. Brown
> >> Head of Collections, Vertebrate Paleontology Laboratory
> >> Lecturer, Department of Geological Sciences
> >> Jackson School of Geosciences
> >> The University of Texas at Austin
> >> R7600, Austin, TX 78758
> >> Office:(512)232-5515
> >>
> >> matthewbrown at utexas.edu
> >>
> >> jsg.utexas.edu/vpl
> >>
> >>
> >>
> >>
> >>
> >>> On Feb 18, 2015, at 5:40 AM, Ellen Paul <ellen.paul at verizon.net>
> >>> wrote:
> >>>
> >>> So if you read the notice, you saw that they estimate that the annual
> burden (to complete the entire report) is 2 hrs, 20 minutes.
> >>>
> >>> How many times can you do this in 2 hrs, 20 minutes (not that this is
> all they are going to ask you to submit; they want other info, too).
> >>>
> >>> Yes, today you can tell exactly where you are with a GPS. What about
> all those collectors prior to say, approximately 1996, who didn't have GPS
> or, if they did, were working at a time when precision was deliberately
> limited to 100 meters and in random directions from the actual point? You
> do have materials collected prior to 1996, yes? How did someone in 1887
> know exactly where they were?
> >>>
> >>> Would appreciate seeing the actual statues and regulations (laws) that
> state that those permitted to collect on federally managed public lands are
> required to keep such detailed records. The reason I mentioned permits is
> that based on my own research, this is the only place this requirement
> appears (and based on permits for wildlife, I doubt any permits specify
> what information must be recorded and maintained). So by asking for
> information prior to the issuance of permits with this requirement, they
> are imposing a substantial retroactive requirement.
> >>>
> >>> And by the way, you just wasted 15 minutes searching for maps from
> Falls Church, Maryland. The canal is in Maryland, but Falls Church is in
> Virginia and four miles inland from the Virginia side of the river.
> >>>
> >>> Ellen
> >>>
> >>> Ellen Paul
> >>> Executive Director
> >>> The Ornithological Council
> >>> Email:
> >>> ellen.paul at verizon.net
> >>>
> >>> "Providing Scientific Information about Birds
> >>> "
> >>>
> https://urldefense.proofpoint.com/v2/url?u=http-3A__www.nmnh.si.edu_BIRDNET&d=AwIF-g&c=-dg2m7zWuuDZ0MUcV7Sdqw&r=CLFZJ3fvGSmDp7xK1dNZfh6uGV_h-8NVlo3fXNoRNzI&m=1FKQB8YNEoaKu6EsnuegYVyOpW-dL6c_MkAWVB1hb6Y&s=sKCMm-5DfDQqT4Wps9dhOBkisM3fyXftdtTaqNWf7jA&e=
> "
> >>>
> >>>
> >>> On 2/17/15 10:00 PM, Brown, Matthew A wrote:
> >>>
> >>>> Assuming I have precise coordinates, the process is extremely
> straightforward. The USGS offers free downloads of all of their topo maps,
> including historical maps, so if I were working on specimens from the C&O
> Canal, for example, I'd start by searching the relevant sheets for a place
> like Falls Church MD between 1951 and today, like this 1994 map (Rockville
> dates back to 1908)-
> >>>>
> https://urldefense.proofpoint.com/v2/url?u=http-3A__store.usgs.gov_b2c-5Fusgs_catalog_setCurre
> >>>>
> ntItem_-28isQuery-3Dyes-26layout-3D6-5F1-5F61-5F58-26uiarea-3D2-26ctype-3DcatalogQuery-26next-3DseeItem-26carea-3D-2524ROOT-26citem-3D00000008210000000012-29_.do&d=AwIF-g&c=-dg2m7zWuuDZ0MUcV7Sdqw&r=CLFZJ3fvGSmDp7xK1dNZfh6uGV_h-8NVlo3fXNoRNzI&m=w5vb7PORY3ET933NJFZfDei0GFwC0UDHeaty93Fw4rY&s=GDHftjvSAvMM-ux2UZ_YWCa0XGUv95ZGWyvDJcpKkdo&e=
> >>>>
> >>>>
> >>>> and also probably composite state maps from a source like
> gpsfiledepot.com, which I use as a layer in my GPS and in Garmin's free
> Basecamp software. Without precise coordinates, it is usually still doable,
> and our collections manager, Chris Sagebiel, is a master of forensic
> locality IDs. Yes, in the past we have consulted field notes, and when not
> available or to supplement them, index card catalogs, photo archives, tax
> offices, personal correspondence files, primary literature, government
> reports, the original collector or field crew, people who were children in
> the 1930s when the WPA collected on their ranch, museum exhibits, and in a
> worst case scenario even Federal land managers who typically have highly
> detailed records to find original locality or temporal property ownership
> information. Admittedly, I haven't been there, and allowing for surveying
> errors, I seriously doubt that there is a section of the C&O Canal where
> property ownership can't be established within the
> >>>> margi
> >>>> n of error of a $50 GPS unit.
> >>>>
> >>>> As a point of interest, the oldest permit in our records that
> immediately comes to my fingertips was issued by DOI in 1962 authorizing
> the collection of vertebrate fossils from Big Bend National Park under the
> authority of the Antiquities Act of 1906. Section 7.f of the permit
> requires that the permittee furnish "a complete inventory and locality
> description of any specimens collected" and send reports to DOI and the
> Smithsonian. This ICR is requesting information that we, as repositories,
> are already required by law and regulation (and professional ethics) to
> keep. So, yes, DOI and SI should have them already, but as you mentioned,
> the Inspector General notes that the records aren't complete. Ostensibly,
> we, the collectors, are the ones doing research. Is it not fair to assume
> that as museums we keep copies of permits, field notes, and other accession
> records, and can link them to the objects? Without that data, they aren't
> specimens at all, they're just novelties or curiosities,
> >>>> bit
> >>>> s of flesh and sawdust and sand.
> >>>>
> >>>>
> >>>>
> >>>>
> >>>> Matthew A. Brown
> >>>> Head of Collections, Vertebrate Paleontology Laboratory
> >>>> Lecturer, Department of Geological Sciences
> >>>> Jackson School of Geosciences
> >>>> The University of Texas at Austin
> >>>> R7600, Austin, TX 78758
> >>>> Office:(512)232-5515
> >>>>
> >>>> matthewbrown at utexas.edu
> >>>>
> >>>> jsg.utexas.edu/vpl
> >>>>
> >>>>
> >>>>> On Feb 17, 2015, at 5:26 PM, Ellen Paul <ellen.paul at verizon.net>
> >>>>> wrote:
> >>>>>
> >>>>> How are you going to determine the status of the location where a
> given item was collected at the time it was collected, assuming you had
> precise coordinates?
> >>>>>
> >>>>> There were no permits until the 1970s or so, as best I can
> determine. There may have been letters of authorization issued by
> individual protected areas, and perhaps that is noted in your records. But
> absent a permit or other document (assuming you kept each document and it
> can link each document to a particular specimen and vice versa), how will
> you know if it was collected from public lands at the time collected? Go
> through all the field notes? What if the field notes were lost, destroyed,
> are illegible, or not conclusive?
> >>>>>
> >>>>> Heck, at the time collected, the collector would have had to know
> he/she was actually on public lands. Even now, that isn't always feasible.
> They don't all have fences or boundary markers. I can take you to the C&O
> Canal and from one section to the next, you won't have any way to know if
> you are on federal, state, or county property.
> >>>>>
> >>>>> Ellen
> >>>>>
> >>>>> Ellen Paul
> >>>>> Executive Director
> >>>>> The Ornithological Council
> >>>>> Email:
> >>>>> ellen.paul at verizon.net
> >>>>>
> >>>>> "Providing Scientific Information about Birds
> >>>>> "
> >>>>>
> https://urldefense.proofpoint.com/v2/url?u=http-3A__www.nmnh.si.edu_BIRDNET&d=AwIF-g&c=-dg2m7zWuuDZ0MUcV7Sdqw&r=CLFZJ3fvGSmDp7xK1dNZfh6uGV_h-8NVlo3fXNoRNzI&m=w5vb7PORY3ET933NJFZfDei0GFwC0UDHeaty93Fw4rY&s=EfRiurc08nI4jPLTegdX_ErwPnj8MG6Uc0uIT5EAcL4&e=
> "
> >>>>>
> >>>>>
> >>>>> On 2/17/15 6:16 PM, Brown, Matthew A wrote:
> >>>>>
> >>>>>>> Are you really going to take the time to go back through your
> collections - every item! - to determine what came from DOI-managed public
> lands - ever - even though not georeferenced that precisely at the time
> collected, even though the exact site may or may not have been DOI-managed
> public land at the time?
> >>>>>>>
> >>>>>> Um... yes. I'd be a pretty poor steward if I couldn't be
> accountable for what my institution holds in our public trust collections.
> >>>>>>
> >>>>>>
> >>>>>>
> >>>>>>
> >>>>>>
> >>>>>>
> >>>>>> Matthew A. Brown
> >>>>>> Head of Collections, Vertebrate Paleontology Laboratory
> >>>>>> Lecturer, Department of Geological Sciences
> >>>>>> Jackson School of Geosciences
> >>>>>> The University of Texas at Austin
> >>>>>> R7600, Austin, TX 78758
> >>>>>> Office:(512)232-5515
> >>>>>>
> >>>>>> matthewbrown at utexas.edu
> >>>>>>
> >>>>>> jsg.utexas.edu/vpl
> >>>>>>
> >>>>>>
> >>>>>>
> >>>>>>
> >>>>>>
> >>>>>>> On Feb 17, 2015, at 12:25 PM, Ellen Paul <ellen.paul at verizon.net>
> >>>>>>> wrote:
> >>>>>>>
> >>>>>>> I hope everyone has read or will read this specific item because
> it is a big deal for museum collections:
> >>>>>>>
> >>>>>>>
> >>>>>>>
> https://urldefense.proofpoint.com/v2/url?u=http-3A__www.gpo.gov_fdsys_pkg_FR-2D2015-2D02-2D03_html_2015-2D01880.htm&d=AwIF-g&c=-dg2m7zWuuDZ0MUcV7Sdqw&r=CLFZJ3fvGSmDp7xK1dNZfh6uGV_h-8NVlo3fXNoRNzI&m=nOx2v156D8uT1thUwsFwrfYvlGSuQwB5albVTXKh5v8&s=SWv4ecrUIXFG5zsWfnHrFuQJPhIv9KEo92dbsnRymkA&e=
> >>>>>>>
> >>>>>>>
> >>>>>>>
> >>>>>>>
> https://urldefense.proofpoint.com/v2/url?u=http-3A__www.gpo.gov_fdsys_pkg_FR-2D2015-2D02-2D03_pdf_2015-2D01880.pdf&d=AwIF-g&c=-dg2m7zWuuDZ0MUcV7Sdqw&r=CLFZJ3fvGSmDp7xK1dNZfh6uGV_h-8NVlo3fXNoRNzI&m=nOx2v156D8uT1thUwsFwrfYvlGSuQwB5albVTXKh5v8&s=iHt12FZYwcCSSpinV_g8p7SkIWAX0uBPETumdAySeco&e=
> >>>>>>>
> >>>>>>>
> >>>>>>> Under the Paperwork Reduction Act, federal agencies can't request
> information from non-federal entities or citizens without permission from
> the White House Office of Management and Budget. To obtain approval for an
> Information Collection Request (ICR) they must publish the proposed ICR for
> comment which is what they are doing here.
> >>>>>>>
> >>>>>>> This request is no doubt in part a result of the reports of the
> Inspector General (at least two over the past decade) that criticized DOI
> rather harshly for not having adequate inventories of stuff collected from
> public lands managed by DOI agencies (USFWS, NPS, BLM).
> >>>>>>>
> >>>>>>> Take a good look at what they are going to require you to do.
> We've had this discussion in the context of the NPS situation. Are you
> really going to take the time to go back through your collections - every
> item! - to determine what came from DOI-managed public lands - ever - even
> though not georeferenced that precisely at the time collected, even though
> the exact site may or may not have been DOI-managed public land at the
> time? You'd have to know the boundaries of each site at the time of
> collection, assuming it was even designated as a:
> >>>>>>>
> >>>>>>> National Wildlife Refuge
> >>>>>>> National Park
> >>>>>>> Public land area managed by the BLM
> >>>>>>> National wildlife preserve
> >>>>>>> Elk refuge
> >>>>>>> National bird refuge
> >>>>>>> etc.
> >>>>>>>
> >>>>>>> at the time of collection.
> >>>>>>>
> >>>>>>> And they estimate that this will take 2 hrs, 20 minutes per year.
> >>>>>>>
> >>>>>>> THEY RECEIVED NO COMMENTS IN RESPONSE TO THE PRIOR NOTICE
> PUBLISHED IN MARCH 2014.
> >>>>>>>
> >>>>>>> The Department of the Interior invites comments on: (a) Whether
> the collection of information is necessary for the proper performance of
> the functions of the agency, including whether the information will have
> practical utility; (b) The accuracy of the agency’s estimate of the burden
> of the collection and the validity of the methodology and assumptions used;
> (c) Ways to enhance the quality, utility, and clarity of the information to
> be collected; and (d) Ways to minimize the burden of the collection of
> information on those who are to respond, including through the use of
> appropriate automated, electronic, mechanical, or other collection
> techniques or other forms of information technology. ‘‘Burden’’ means the
> total time, effort, or financial resources expended by persons to generate,
> maintain, retain, disclose, or provide information to or for a federal
> agency. This includes the time needed to review instructions; to develop,
> acquire, install and utilize technology and systems for
> >>>>>>> the
> >>>>>>> purpose of collecting, validating and verifying
> information, processing and
> >>>>>>> maintaining information, and disclosing and providing information;
> to train personnel and to be able to respond to a collection of
> information, to search data sources, to complete and review the collection
> of information; and to transmit or otherwise disclose the information.
> >>>>>>>
> >>>>>>> Think about the potential consequences of not complying once this
> goes into effect.
> >>>>>>>
> >>>>>>> I really suggest you read this notice carefully.
> >>>>>>>
> >>>>>>> Ellen
> >>>>>>>
> >>>>>>> Ellen Paul
> >>>>>>> Executive Director
> >>>>>>> The Ornithological Council
> >>>>>>> Email:
> >>>>>>>
> >>>>>>> ellen.paul at verizon.net
> >>>>>>>
> >>>>>>>
> >>>>>>> "Providing Scientific Information about Birds
> >>>>>>>
> >>>>>>> "
> >>>>>>>
> https://urldefense.proofpoint.com/v2/url?u=http-3A__www.nmnh.si.edu_BIRDNET&d=AwIF-g&c=-dg2m7zWuuDZ0MUcV7Sdqw&r=CLFZJ3fvGSmDp7xK1dNZfh6uGV_h-8NVlo3fXNoRNzI&m=nOx2v156D8uT1thUwsFwrfYvlGSuQwB5albVTXKh5v8&s=UCUDJ9K4Mcnb-BpPFb_xUJjuDwcZ7hpAD_gHk48b_J0&e=
> "
> >>>>>>>
> >>>>>>>
> >>>>>>>
> >>>>>>> _______________________________________________
> >>>>>>> Nhcoll-l mailing list
> >>>>>>>
> >>>>>>> Nhcoll-l at mailman.yale.edu
> >>>>>>> http://mailman.yale.edu/mailman/listinfo/nhcoll-l
> >>>>>>>
> >>>>>>>
> >>>>>>> _______________________________________________
> >>>>>>> NHCOLL-L is brought to you by the Society for the Preservation of
> >>>>>>> Natural History Collections (SPNHC), an international society whose
> >>>>>>> mission is to improve the preservation, conservation and
> management of
> >>>>>>> natural history collections to ensure their continuing value to
> >>>>>>> society. See
> >>>>>>>
> https://urldefense.proofpoint.com/v2/url?u=http-3A__www.spnhc.org&d=AwIF-g&c=-dg2m7zWuuDZ0MUcV7Sdqw&r=CLFZJ3fvGSmDp7xK1dNZfh6uGV_h-8NVlo3fXNoRNzI&m=nOx2v156D8uT1thUwsFwrfYvlGSuQwB5albVTXKh5v8&s=Ke7H3Zr6Cq6uBUOK9mydwJfBcyPbotxpFdIbqEfseG0&e=
> >>>>>>> for membership information.
> >>>>>>>
> >>>>>> _______________________________________________
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> >>>>>>
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> >>>>>> http://mailman.yale.edu/mailman/listinfo/nhcoll-l
> >>>>>>
> >>>>>>
> >>>>>> _______________________________________________
> >>>>>> NHCOLL-L is brought to you by the Society for the Preservation of
> >>>>>> Natural History Collections (SPNHC), an international society whose
> >>>>>> mission is to improve the preservation, conservation and management
> of
> >>>>>> natural history collections to ensure their continuing value to
> >>>>>> society. See
> >>>>>>
> https://urldefense.proofpoint.com/v2/url?u=http-3A__www.spnhc.org&d=AwIF-g&c=-dg2m7zWuuDZ0MUcV7Sdqw&r=CLFZJ3fvGSmDp7xK1dNZfh6uGV_h-8NVlo3fXNoRNzI&m=w5vb7PORY3ET933NJFZfDei0GFwC0UDHeaty93Fw4rY&s=L1J32IU99zLKxDdwdq6Inl4Sh4eLLRI4cYE2nMi7uS8&e=
> >>>>>> for membership information.
> >>>>>>
> >>>>>>
> >>>> _______________________________________________
> >>>> Nhcoll-l mailing list
> >>>>
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> >>>> http://mailman.yale.edu/mailman/listinfo/nhcoll-l
> >>>>
> >>>>
> >>>> _______________________________________________
> >>>> NHCOLL-L is brought to you by the Society for the Preservation of
> >>>> Natural History Collections (SPNHC), an international society whose
> >>>> mission is to improve the preservation, conservation and management of
> >>>> natural history collections to ensure their continuing value to
> >>>> society. See
> >>>>
> https://urldefense.proofpoint.com/v2/url?u=http-3A__www.spnhc.org&d=AwIF-g&c=-dg2m7zWuuDZ0MUcV7Sdqw&r=CLFZJ3fvGSmDp7xK1dNZfh6uGV_h-8NVlo3fXNoRNzI&m=1FKQB8YNEoaKu6EsnuegYVyOpW-dL6c_MkAWVB1hb6Y&s=6kplSfJcVeMmo8D0B2i6LFdCkt5VKu5PJL4xJijBAag&e=
> >>>> for membership information.
> >>>>
> >>>>
> >>>
> >>
> >> _______________________________________________
> >> Nhcoll-l mailing list
> >>
> >> Nhcoll-l at mailman.yale.edu
> >> http://mailman.yale.edu/mailman/listinfo/nhcoll-l
> >>
> >>
> >> _______________________________________________
> >> NHCOLL-L is brought to you by the Society for the Preservation of
> >> Natural History Collections (SPNHC), an international society whose
> >> mission is to improve the preservation, conservation and management of
> >> natural history collections to ensure their continuing value to
> >> society. See
> >>
> https://urldefense.proofpoint.com/v2/url?u=http-3A__www.spnhc.org&d=AwIF-g&c=-dg2m7zWuuDZ0MUcV7Sdqw&r=CLFZJ3fvGSmDp7xK1dNZfh6uGV_h-8NVlo3fXNoRNzI&m=B--KlhjRftTu9vvpDDX3mZhEkShlubdxooioNZQSBqI&s=rbpCoFK7WSHhJRdwYSgCWWa_bwINrA7U-40qTnwKpFU&e=
> >> for membership information.
> >>
> >>
> >
>
> _______________________________________________
> Nhcoll-l mailing list
> Nhcoll-l at mailman.yale.edu
> http://mailman.yale.edu/mailman/listinfo/nhcoll-l
>
> _______________________________________________
> NHCOLL-L is brought to you by the Society for the Preservation of
> Natural History Collections (SPNHC), an international society whose
> mission is to improve the preservation, conservation and management of
> natural history collections to ensure their continuing value to
> society. See https://urldefense.proofpoint.com/v2/url?u=http-3A__www.spnhc.org&d=AwIFaQ&c=-dg2m7zWuuDZ0MUcV7Sdqw&r=CLFZJ3fvGSmDp7xK1dNZfh6uGV_h-8NVlo3fXNoRNzI&m=o5usLaTBbyZUZgb_34ZGfDAGNmeTt3TssJwCTcuhavk&s=KoAgRNlGdoAqYGX-f2jfxXdpSmhfcTm4al9Tgmlk5vY&e= for membership information.
>
--
Kevin Winker
University of Alaska Museum
907 Yukon Drive
Fairbanks, AK 99775
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