[Nhcoll-l] USFWS closing migratory bird salvage permits

[Makayla Dean]

Hi all,

I wanted to add to the conversation with the information we received when emailing about our permit status. I hope it helps another museum in a similar position to us. It seems that because we are removing and storing tissue samples, as well as accepting birds from intentional salvage efforts, we need a Scientific Collecting and Research permit. We emailed migratorybirdpermits at fws.org the following:

Hello,
I am the Zoology Collections Manager at the Cincinnati Museum Center located in Cincinnati, Ohio. We are a 501(c)(3) non-profit museum that contains biological collections for use in education and research. Salvage of dead animals is the main source of our specimens. I am writing to inquire about a new exception to obtaining a USFWS permit for the salvage of migratory birds that is outlined in the Code of Federal Regulations (50CFR Part 21.12(b)). We need to confirm that we do not need a federal permit for migratory birds at this time. Historically, we have obtained the Migratory Bird Special Purpose – Salvage permit for salvaging birds, which has since expired. I have included more information about our institution and our practices below.
Our institution accepts deceased birds from museum staff members, members of the public, university professors, wildlife rehabilitators, Audubon Society members, and Lights Out members. These birds are salvaged both opportunistically and intentionally, such as members of the public finding a deceased bird by happenstance (opportunistic) or Audubon Societies and Lights Out programs sending out members to document and collect window strikes during migration (intentional). Our institution is not collecting live birds nor euthanizing birds for research. We only accept previously deceased birds from outside sources.
During our preparation process, in which we prepare the bird for public archive, we remove muscle and organ tissue samples from already deceased birds and store those at -80C. We also clean and retain all skeletal material from each bird. Unaffiliated researchers may also request the removal of tissues or feathers from a preserved skin for destructive analysis, which we approve on a case-by-case basis. Our institution is not taking tissue samples or feathers from live birds. All of our work is completed on deceased birds.
I would be happy to share with you copies of our previous federal permits if those would be helpful, as well as answer any questions you may have. Given the above information about our institution, will you please clarify the new regulations in regards to salvaging for our institution so we may proceed accordingly? Does our institution need a 3-200-7: Migratory Bird – Scientific Collecting Permit?
If we do not need a permit for the above activities, what types of records do we need to maintain about birds we bring into our collection?
We received the following in response:

The simple answer is "yes", because you are taking samples from the bird carcasses you will nee a scientific collection permit.  If you were simply preserving the birds or their parts as educational or reference specimens, then you would not need a permit, that action is cover under an Regulatory Authorization. And, Audubon and Lights Out, if they are intentionally searching for and collecting bird carcasses need a scientific collection permit, too. Our salvage authorization only applies to incidental salvage and not intentional salvage.

I hope that helps.

Rocky Montgomery
Permits and Operations Unit Lead
Migratory Birds Program




Makayla Dean | they/them

Manager, Zoology Collections & DNA Lab

Cincinnati Museum Center

1301 Western Avenue, Cincinnati, Ohio 45203
MDean at cincymuseum

C: (513) 549-6251

O: (513) 287-7000 ext 7307

cincymuseum.org
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