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<div class="moz-cite-prefix">Your reading of 21.23 is off-kilter,
too. <br>
<br>
It does not "disallows the keeping of specimens unless the
scientific collector is issued a special purpose permit under §
21.27."<br>
<br>
In fact, 21.23 says:
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(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.<br>
<br>
Unless your permit for some reason designates an institution other
than yours, you have satisfied this condition and there is no
reason for a special purpose permit. <br>
<br>
I am sorry you have trouble with your regional permitting staff.
You should ask them to call Region 9 (the DC office) for
clarification, though I'm actually shocked to hear that they are
so far off the mark on this one. This is the first time in 16
years that I've heard of any trouble with these provisions, much
less the notion that you need a special purpose permit, because
indeed, special purpose permits are for activities not covered by
other permits. Of course Texas requires you to have the federal
permits. Every state makes that a condition of state permits. It
doesn't mean you have to have the wrong permit. <br>
<br>
Ellen<br>
<pre class="moz-signature" cols="72">Ellen Paul
Executive Director
The Ornithological Council
Email: <a class="moz-txt-link-abbreviated" href="mailto:ellen.paul@verizon.net">ellen.paul@verizon.net</a>
"Providing Scientific Information about Birds<a class="moz-txt-link-rfc2396E" href="https://urldefense.proofpoint.com/v2/url?u=http-3A__www.nmnh.si.edu_BIRDNET&d=AwMD-g&c=-dg2m7zWuuDZ0MUcV7Sdqw&r=CLFZJ3fvGSmDp7xK1dNZfh6uGV_h-8NVlo3fXNoRNzI&m=B4ibaI1o8W3aGAbowQ7JrBn2Ia6fZljn2lIHaROy3Kg&s=QWdHMigdScqGSgUeOWcOKJL-MHCeotpSE_kL1JE2L1c&e=">"
http://www.nmnh.si.edu/BIRDNET"</a>
</pre>
On 2/20/15 3:18 AM, Brown, Matthew A wrote:<br>
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<div><br>
In part I blame being in the office till 1am several nights in a
row, but your comment about regions finally reminded me that, oh
yeah, it's Texas museums that need to have that federal permit
under 21.27, because Texas Parks and Wildlife requires that we
have the Federal permit in addition to theirs in order to handle
migratory birds in the state. Thus, with the special purpose
permits in hand, we have to report annually even if we would
otherwise be exempt from federal permitting requirements. </div>
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<div>However, it also gives us salvage authority, which is how a
large part of our 18,000 specimen collection of modern skeletons
has historically been built. Acting under the exemption you
cited, we could only build collections by gift or by purchase
from individuals or institutions who were permitted or otherwise
authorized. But wouldn't this disqualify most institutions with
collecting programs from the exemption as well? Are there that
many major bird collections that are built solely through gift,
purchase, or individual researchers with a scientific collecting
permit?</div>
<div><br>
</div>
<div>I know I said I was going to shut up on the topic, so I'm
gonna do that now. </div>
<div><br>
</div>
<div><br>
Sent from my iPhone</div>
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