"Federal Permits"

Kenelm Philip fnkwp at aurora.alaska.edu
Thu Aug 28 04:09:42 EDT 1997

	I had not expected to spark so much discussion when I posted
my list of conditions for National Park collecting! Now that there
has been all this discussion, I should make a few comments of my own.

	First, my list of conditions was not intended to be all-inclusive,
or to apply to all National Parks. Most of my Park collecting has been
in Alaska, and the list was merely some issues that had come up when I
applied for collecting permits in various Alaskan National Parks. There
are clearly NPS guidelines and rules that must affect all Parks--but in
many cases I was interacting with various resource managers who were
able to be rather flexible about how things were done in their bailiwick.

	For example, I did not mention the resource manager who sent me
a delightful letter warning me that if any of the butterfly specimens
from 'his' Park were damaged or destroyed I could face criminal penal-
ties! Since dermestids can strike occasionally in even the best-kept
collections, and since making genitalic slides involves 'damaging' the
abdomen of the specimen, I was somewhat taken aback, to say the least...
Fortunately I was able to meet him face-to-face later, and explain
these things to him. Apparently, in his ignorance of entomology, he was
trying to apply rules more appropriate for irreplaceable archeological

	In general, I have found NPS employees to have little training
in entomology--so it appears to be the permit applicant's responsi-
bility to educate them. I have found the NPS people in Alaska to be
perfectly willing to be so instructed, and also quite willing to co-
operate with the Alaska Lepidoptera Survey--even to the point of pro-
viding some free helicopter or floatplane time to get us into remote
areas within roadless parks.

	Now for some responses to people's comments:

	Mark Walker asked: "What good are these rules for this type of
violator?" referring to the average tourist. All the average tourist
needs to know is that _no_ natural feature, animal, vegetable, or
mineral is to be taken from the park. Scientists should know (or soon
find out) that collecting permits are required. The person who has real
trouble is the hobbyist collector who has no scientific aims--the
rules do not allow for that kind of use for the parks.

	This attempt to control insect collecting does create an amusing
situation. National Park headquarters have been known to run bug zappers.
I can drive out of Denali N. P. with the floor of my truck half an inch
deep in dead mosquitoes, and the radiator covered with dead butterflies,
dragonflies, etc. and no one bats an eyelash. But should I decide, when
I get home, to stick a pin through one dead mosquito and put a label
on it, I am a Federal criminal unless I had a permit. This is, on the
face of it, absurd.

	On the other hand, I think most of us agree that National Park
material should not be used for commercial purposes. Without a general
ban on unpermitted collecting, it might be very difficult to monitor
collecting which is clearly not in the public interest. I see no easy
answer to this problem. The current rules: 'No collecting without
permit', may go too far (as bureaucratic methods always do), but I
doubt that allowing all people to collect all the insects from National
Parks that they want, regardless of species, is the best way to go

	As for fishing, which is also absurd--the reason for that is
historical, according to a NPS employee: Theodore Roosevelt liked to
fish, and set the National Park system up so fishing was allowed.

	The requirement that collecting be done out of sight of visitors
is one I have encountered only in Denali N.P. (In my other N.P. visits
I have been dropped off in remote areas where there _were_ no other
visitors.) I was informed that a) this is not an absolute rule, one
should simply do one's best to be invisible and not worry if one or
two people see you, and b) the reason is the large numbers of people
going by in tour buses who have no idea you have a permit, and might
conclude anyone can collect insects. I suggested to the NPS that they
might consider issuing scientists bright red armbands, allowing them
to work in plain sight, and tell the tourists at the Interpretive
Centers that people with red armbands are helping to learn more about
the park, for the eventual benefit of the tourists. I was told that
there is no way that such a system would be considered--but I was
not told _why_. Maybe because something like that would have to be
cleared at the highest NPS levels?

	Walker refers to 'grassroots-based research' done by people who
began at the age of eight for the sheer love of it, and are not funded
by federal grants. That's a pretty good description of the Alaska
Lepidoptera Survey, except that I started at 7, and have gotten a few
airplane rides from the feds. It's still possible to do this kind of
thing in the National Parks, as long as your work is perceived as
helping the park obtain information it needs.

	When I mentioned providing a detailed inventory of one's catch,
I left out the amusing part. Several National Parks have asked me to
fill out one 8/5"x11" sheet with _many_ fields on it for _each specimen_
I collect. Filling out several hundred such sheets with mostly inden-
tical information is no one's idea of fun! After consultation, all the
NPS people so far have agreed to accept one such sheet per _batch_
rather than per _specimen_--another case where their vertebrate and
archeological background produces odd results applied to insects until
they think about things a bit.

	Paul Opler, by the way, is quite correct about the current
attitude of NPS towards entomological inventories in National Parks.
The resource managers know that such work is needed, and I have had
NPS people _ask_ me to collect in their parks. There are indeed a number
of hoops to jump through to obtain permits, but I have not found this
an impossible situation to work with. 

	Daniel Glaeske compared the excellent cooperation he received
from a Canadian Provincial Park. I have gotten similar responses from
State Parks in Alaska (and also from some National Parks)--but he should
try Canadian _National_ Parks before he concludes that things are so
much easier there... A Kluane National Park manager told me that the
only butterflies anyone could get a permit to collect in the park were
species found _only_ in the park--widespread species were off limits!
That sounds backwards to me...

						Ken Philip
fnkwp at aurora.alaska.edu

P.S. to Mark Walker: I really do like tundra, but 'tundra-bound' is
a bit inaccurate. Alaska has lots of taiga, as well as coastal rain
forest, and I have spent some time in these habitats too.

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