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

[Ellen Paul]

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=IyV1IGLbGoOKo10zWwEuDMovP3-p9HEhPjcWXaD_4U4&s=M-wG29_DaOjO7L3aa4ZOH6zD44u5e7mE6VBjqk2RdMo&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, 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 casescenario 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 propertyownership 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 ofany 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
>
>> 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 itwas 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 accountablefor 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
>>>
>>>
>>>
>>>
>>>> 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 anInformation 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 collectionof information on those who are to respond, including through the use ofappropriate 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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>>> mission is to improve the preservation, conservation and management of
>>> natural history collections to ensure their continuing value to
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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=IyV1IGLbGoOKo10zWwEuDMovP3-p9HEhPjcWXaD_4U4&s=F6srMtkopAK5ifsEkBmazYlHrPxC0xOntjLi7ZuWnCU&e=  for membership information.
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