[Nhcoll-l] NSC Alliance Washington Report - READ THIS ONE!
Sarah Timm
stimm10 at vt.edu
Tue Mar 3 17:06:57 EST 2015
Though I wholeheartedly support documentation for collections and have been
a strong advocate for this in the geological community, I am doing so with
the hope of instilling a new perspective on research collections in
universities and institutions currently not documenting or caring for their
collections at all - because they don't see them as collections and there
is no evaluation, funding, or priority to do so. This is what I wanted to
change with the the help of GSA and policy makers.
The ICR is asking an awful lot of institutions that are doing their best in
this age to preserve, document, and grow existing collections. Though it
would be nice to have that information all in one place and many groups
such as EarthCube are working on that, the information they are asking for
would take an immense amount of time (where did they get 2 hrs/yr from!?)
and really not solve the problem because in another 100 years they would be
asking the same thing again.
*My suggestion to policy makers everywhere is to look at the cause of this*.
As Mathew said, we are already supposed to have this data all nice and neat
and ready to hand over if need be but most of us don't - *why?* *All of the
specimens being collected under federal grants in universities (let alone
the associated data) are being lost - why?* If a group like EarthCube can
pull together data across the sciences to be used for future research then
that's great but that isn't going to solve the underlying issue. My
opinion- let's focus on the cause and the hope of a new perspective for
collections so that in 100 years the data can easily be procured and
reported.
---------------------------
> From: "Bentley, Andrew Charles" <abentley at ku.edu>
> Date: Feb 19, 2015 2:49 PM
> Subject: Re: [Nhcoll-l] NSC Alliance Washington Report - READ THIS ONE!
> To: "Kevin Winker" <kevin.winker at alaska.edu>, "Brown, Matthew A" <
> matthewbrown at utexas.edu>
> Cc: "nhcoll-l at mailman.yale.edu" <nhcoll-l at mailman.yale.edu>
>
> Kevin
>
>
>
> Could not agree more. My other worry here is that there is no mention of
> the reasoning behind this information gathering exercise. Is it purely to
> get a handle on what is in non-federal collections or are there intentions
> maybe more along the lines of what NPS was proposing when they approach us
> some time ago here at KU about specimens held in our collections. We were
> told that once the specimens were deemed to have come from NPS lands that
> they would be sending us loan agreements for the material that not only
> covered ownership of the material but also covered what restrictions were
> being placed on the loaning of the material to third parties. My worry is
> that this is more than just a fishing exercise and that there are secondary
> repercussions to providing this information.
>
>
>
> Andy
>
>
>
> A : A : A :
> }<(((_°>.,.,.,.}<(((_°>.,.,.,.}<)))_°>
> V V V
> Andy Bentley
> Ichthyology Collection Manager
> University of Kansas
> Biodiversity Institute
>
> Dyche Hall
> 1345 Jayhawk Boulevard
> Lawrence, KS, 66045-7561
> USA
>
> Tel: (785) 864-3863
> Fax: (785) 864-5335
> Email: abentley at ku.edu
>
> https://urldefense.proofpoint.com/v2/url?u=http-3A__ichthyology.biodiversity.ku.edu&d=AwIFaQ&c=-dg2m7zWuuDZ0MUcV7Sdqw&r=CLFZJ3fvGSmDp7xK1dNZfh6uGV_h-8NVlo3fXNoRNzI&m=p-iyoQnlaTmk0teBWlFMFJQBNYOTUKbsvZOJhujkaAo&s=m2j4BB9gyHhLGAQBCJveyGs_I82IJ40SFofoi9aMXUE&e=
> <https://urldefense.proofpoint.com/v2/url?u=http-3A__ichthyology.biodiversity.ku.edu_&d=AwMGaQ&c=-dg2m7zWuuDZ0MUcV7Sdqw&r=CLFZJ3fvGSmDp7xK1dNZfh6uGV_h-8NVlo3fXNoRNzI&m=JPLx8FsLDQmDfIlsbDfqwqYacqT9yqq-EKfCICwyjY0&s=08J_v7-7H3jEznNRVg4Kcb2_VlJeJ5hA4G8Nc9g6jx8&e=>
>
>
>
> SPNHC President
>
> https://urldefense.proofpoint.com/v2/url?u=http-3A__www.spnhc.org&d=AwIFaQ&c=-dg2m7zWuuDZ0MUcV7Sdqw&r=CLFZJ3fvGSmDp7xK1dNZfh6uGV_h-8NVlo3fXNoRNzI&m=p-iyoQnlaTmk0teBWlFMFJQBNYOTUKbsvZOJhujkaAo&s=5AhGv6OWNGMRh3wvMDh2yTv_eq0IpEWyL4-Fml5AIpA&e=
> <https://urldefense.proofpoint.com/v2/url?u=http-3A__www.spnhc.org_&d=AwMGaQ&c=-dg2m7zWuuDZ0MUcV7Sdqw&r=CLFZJ3fvGSmDp7xK1dNZfh6uGV_h-8NVlo3fXNoRNzI&m=JPLx8FsLDQmDfIlsbDfqwqYacqT9yqq-EKfCICwyjY0&s=-jfuXeyGwGBTQbFZpIPnaUhUtkiNrLk5KeMSxtOUqcA&e=>
>
>
>
> : :
> A : A : A :
> }<(((_°>.,.,.,.}<(((_°>.,.,.,.}<)))_°>
> V V V
>
>
>
> *From:* nhcoll-l-bounces at mailman.yale.edu [mailto:
> nhcoll-l-bounces at mailman.yale.edu] *On Behalf Of *Kevin Winker
> *Sent:* Thursday, February 19, 2015 1:05 PM
> *To:* Brown, Matthew A
> *Cc:* nhcoll-l at mailman.yale.edu
> *Subject:* Re: [Nhcoll-l] NSC Alliance Washington Report - READ THIS ONE!
>
>
>
> Matthew, from my perspective you are conflating today's capabilities with
> a huge historical mess of uncertainties we in our collection simply don't
> have the resources to resolve. And, while NPS has claimed ownership over
> portions of our collection(s), no other DOI agency has done so. So I look
> at this Information Collection Proposal as a) a major time commitment, b)
> beyond the scope of any prior information request (and assuming something
> that hasn't even been discussed, e.g. ownership by BLM, USFWS, Forest
> Service, etc.), and c) redundant with existing annual reporting
> requirements for modern material.
>
> This thread has helped me to understand the heterogeneities among
> collections and institutions, but here such a request would be difficult to
> satisfy without weeks and perhaps months of thankless labor that does not
> affect whatsoever the caretaking or accessibility of the specimens.
>
> Best, K.
>
>
>
> On Wed, Feb 18, 2015 at 9:42 PM, Brown, Matthew A <matthewbrown at utexas.edu>
> 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
> <https://urldefense.proofpoint.com/v2/url?u=http-3A__jsg.utexas.edu_vpl&d=AwMFaQ&c=-dg2m7zWuuDZ0MUcV7Sdqw&r=CLFZJ3fvGSmDp7xK1dNZfh6uGV_h-8NVlo3fXNoRNzI&m=iOTfRHbDwuCG4BRUuW94Di_lkaKN4-RE56g6mIgBxfc&s=B9lIxw-fOz-WPJqvMCdxlSLVzv0uY4EC4muUQrpTZVQ&e=>
>
>
>
>
> > 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_setCurrentItem_-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
> <https://urldefense.proofpoint.com/v2/url?u=http-3A__gpsfiledepot.com&d=AwMFaQ&c=-dg2m7zWuuDZ0MUcV7Sdqw&r=CLFZJ3fvGSmDp7xK1dNZfh6uGV_h-8NVlo3fXNoRNzI&m=iOTfRHbDwuCG4BRUuW94Di_lkaKN4-RE56g6mIgBxfc&s=awPfYi8-btyDuHtPMxoXl6fcJDUE0iMSNH3_VeMj0KQ&e=>,
> 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 margin 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, bits 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
> <https://urldefense.proofpoint.com/v2/url?u=http-3A__jsg.utexas.edu_vpl&d=AwMFaQ&c=-dg2m7zWuuDZ0MUcV7Sdqw&r=CLFZJ3fvGSmDp7xK1dNZfh6uGV_h-8NVlo3fXNoRNzI&m=iOTfRHbDwuCG4BRUuW94Di_lkaKN4-RE56g6mIgBxfc&s=B9lIxw-fOz-WPJqvMCdxlSLVzv0uY4EC4muUQrpTZVQ&e=>
> >>
> >>> 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
> <https://urldefense.proofpoint.com/v2/url?u=http-3A__jsg.utexas.edu_vpl&d=AwMFaQ&c=-dg2m7zWuuDZ0MUcV7Sdqw&r=CLFZJ3fvGSmDp7xK1dNZfh6uGV_h-8NVlo3fXNoRNzI&m=iOTfRHbDwuCG4BRUuW94Di_lkaKN4-RE56g6mIgBxfc&s=B9lIxw-fOz-WPJqvMCdxlSLVzv0uY4EC4muUQrpTZVQ&e=>
> >>>>
> >>>>
> >>>>
> >>>>
> >>>>> 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=
> "
> >>>>>
> >>>>>
> >>>>> _______________________________________________
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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=nOx2v156D8uT1thUwsFwrfYvlGSuQwB5albVTXKh5v8&s=Ke7H3Zr6Cq6uBUOK9mydwJfBcyPbotxpFdIbqEfseG0&e=
> for membership information.
> >>>> _______________________________________________
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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
> >> 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=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=AwIFaQ&c=-dg2m7zWuuDZ0MUcV7Sdqw&r=CLFZJ3fvGSmDp7xK1dNZfh6uGV_h-8NVlo3fXNoRNzI&m=p-iyoQnlaTmk0teBWlFMFJQBNYOTUKbsvZOJhujkaAo&s=5AhGv6OWNGMRh3wvMDh2yTv_eq0IpEWyL4-Fml5AIpA&e=
> <https://urldefense.proofpoint.com/v2/url?u=http-3A__www.spnhc.org&d=AwMFaQ&c=-dg2m7zWuuDZ0MUcV7Sdqw&r=CLFZJ3fvGSmDp7xK1dNZfh6uGV_h-8NVlo3fXNoRNzI&m=iOTfRHbDwuCG4BRUuW94Di_lkaKN4-RE56g6mIgBxfc&s=nbKAI9YS9rQB29uQKBJ58-HRTJliONbBZlT71p7Uu8o&e=>
> for membership information.
>
>
>
>
> --
>
> Kevin Winker
> University of Alaska Museum
> 907 Yukon Drive
> Fairbanks, AK 99775
>
> _______________________________________________
> 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=p-iyoQnlaTmk0teBWlFMFJQBNYOTUKbsvZOJhujkaAo&s=5AhGv6OWNGMRh3wvMDh2yTv_eq0IpEWyL4-Fml5AIpA&e= for membership information.
>
>
--
*Sarah Timm *
*Curator at Tellus Science Museumsaraht at tellusmuseum.org
<saraht at tellusmuseum.org>*
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