[Nhcoll-l] Information Collection Request -Documenting, Managing and Preserving DOI MuseumProperty....

[Kevin Winker]

Chris, that is a well-reasoned encouragement for folks to read the ICR and
respond to it. The burden will indeed vary among institutions and within
institutions among collections. And it may indeed open new opportunities
for federal funding for care of portions of collections.

There is, however, one aspect to keep in mind. It is basically an inventory
of Federal property, one that includes a significant (for some collections
huge) expansion of that concept. So although your statement may be true: "while
there are real issues regarding ownership of certain categories of
specimen, this ICR will not change the situation with regard to ownership.,"
providing an inventory of the scope they claim to own may be considered
acquiescence to that claim. And not providing that scope may be viewed as
not complying with the request. Until we agree on what exactly is Federal
property, such an information request seems to me to be a lose-lose.
Lastly, if we agree that historic ownership understandings hold (e.g.,
archaeological, paleontological, and all NPS material), then from our
institution's perspective the ICR is almost if not entirely duplicative
with existing reporting requirements.

Best, K.

On Sat, Feb 28, 2015 at 10:48 AM, Norris, Christopher <
christopher.norris at yale.edu> wrote:

>  I want to echo the comments made by many others on the list regarding
> the need to read and comment on Information Collection Request (ICR)
> entitled "Documenting, Managing and Preserving DOI Museum Property Housed
> in Non-Federal Repositories." Comments on this are due on 5 March. This is
> an important issue for the US collections community.
>
> Before you do this, you should read the documents - including the
> supporting materials - carefully and understand why the information is
> needed and what you might be asked by agency staff or their contractors if
> this request is approved. There's still quite a lot of confusion in some
> quarters. For example, this is an information request, *not* a new
> regulation, or a law. It doesn't place any legal obligations on you that
> you didn't have before, and while there are real issues regarding ownership
> of certain categories of specimen, this ICR will not change the situation
> with regard to ownership.
>
> Most of the comments published to date have focused on the negative
> aspects of this information request in terms of increased reporting
> burden... appropriately so. But you need to understand exactly what that
> burden will be *for you*; remember, you almost always have
> the opportunity to say that you don't have, or cannot easily obtain the
> information. You should also take some time to weigh the burden against
> the ways in which your collections might benefit from this exercise. Can it
> be used to highlight problems or challenges that you face? Will it let you
> begin a dialogue with your colleagues in the agencies about the need for
> additional resources for curating the collections held at your institution?
> Will it help them make a better argument to their own management for these
> resources?
>
>  Something else that might not be clear from the documents is that once
> an ICR is approved, it must be reapproved by OMB every 3 years.  That means
> that everyone concerned can evaluate what has happened over the intervening
> years and then comment on it when the ICR reapproval is again published in
> the Federal Register.  So If the process turns out to be excessively
> burdensome in practice, there's another opportunity to have it amended.
>
> Within SPNHC we've been taking time to review the documentation and
> talking to our colleagues in the agencies and other non-federal
> organizations. We''ll be making a formal response later this week and I
> would urge anyone with an interest in seeing these collections better
> documented and managed to do the same.
>
>  Chris
>
>
>  PS: if you haven't seen DOI's supporting documentation for this request,
> here's how to access it:
>
>  Go to https://urldefense.proofpoint.com/v2/url?u=http-3A__www.reginfo.gov_public_do_PRAViewICR-3Fref-5Fnbr-3D201412-2D1084-2D001&d=AwIBaQ&c=-dg2m7zWuuDZ0MUcV7Sdqw&r=CLFZJ3fvGSmDp7xK1dNZfh6uGV_h-8NVlo3fXNoRNzI&m=HPD4cfHauu8ZAWSdBYG0bR1Xl65zf1Xnjv6LoRnFaWI&s=YGNxdtKNbaGTDYCP-vASO-4JFuCdNlkLWorhnaHr-tU&e= 
>
>  Once there, click on the "View Information Collection (IC) List" link to
> access the Checklist and other materials and the "View Supporting Statement
> and Other Documents" link to access the Supporting Statement (it's the
> first item in the "ICR Documents" list on that next page).
>
>   =============================
> Dr. Christopher A. Norris
> Division of Vertebrate Paleontology
> Yale Peabody Museum of Natural History
> 170 Whitney Ave.
> PO Box 208118
> New Haven, CT 06520-8118
>
> Past President
> Society for the Preservation of Natural History Collections
> www.spnhc.org
>
> Tel. +1(203)-432-3748
> Fax. +1(203)-432-9816
>
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>
>


-- 
Kevin Winker
University of Alaska Museum
907 Yukon Drive
Fairbanks, AK 99775
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