[Nhcoll-l] NSC Alliance Washington Report - READ THIS ONE!

[Ellen Paul]

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=-1gvTARHE-MU9TM4KHU9c0OwNRhl4EJBZ35slDvb-ss&s=IhgcINjqbyELQAtZjuY6DgLiq0A74pg6uj4DIkEs50I&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.
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> 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
>
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>> 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=
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>> 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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> _______________________________________________
> 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=-1gvTARHE-MU9TM4KHU9c0OwNRhl4EJBZ35slDvb-ss&s=C5fiV2VVn1UR1EQmY9FfH8R92hJiQtEQ2i1gqqprxEI&e=  for membership information.
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