[NHCOLL-L:5315] Question for Registars - CITES, COSE & Endangered Species Permit

[O'Brien, Mark]

I'm hoping that someone can help me out on a vexing question.
In applying for a renewal of our CITES/COSE permit, the form asks:

6. [ ]Yes [ ]No  Do you maintain any specimens protected under the Endangered Species Act?
 a. If "yes" do you wish to import or export these specimens?_______
 b. if yes, provide a  copy of your ESA authorization for this activity.

According to my USFWS contacts, an ESA Permit is only needed to the "TAKING" of listed species.  Any protected specimens that we have in the collection would have been collected either before listing, or if protected, the person doing the taking, would have to have a permit specifically for the specimens taken, not the museum. I.e., we have specimens of Hine's emeralds obtained under a permit issued to the group  of people that are covered by said permit.  The museum did not do the "taking" and we are a recognized repository for specimens covered under the ESA (and technically, specimens collected under permit from the USFWS are property of the Federal Government).

So, it seems superfluous for us to have a Endangered Species Permit, but yet the CITES/COSI form ask for one as if it were required.  What am I missing? How are others handling this?

Many thanks in advance.

Mark
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Mark F. O'Brien, Collection Manager
UMMZ Insect Division, 1109 Geddes Avenue
University of Michigan, Ann Arbor, MI 48109-1079
734-647-2199    fax: 734-763-4080
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