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Help revise proposed US Forest Service regulations for paleontology–comment now!

The United States federal government is drafting new regulations for paleontology on federal lands, following the recent passage of the Paleontological Resources Preservation Act (PRPA). The first round of proposed regulations comes from the US Forest Service, an agency with many fossil resources under its care. Although most aspects of the proposed regulations are a step in the right direction, some parts could hinder the ability of museums to manage fossils in their care and the ability of scientists and other members of the public to learn from fossils. I outlined some of my own concerns in a recent post (available here, with a great discussion); scientific organizations (particularly the Paleontological Society) and paleontologists alike echo these and other concerns.

The US Department of Agriculture (the parent body for the USFS) is soliciting comments on the draft regulations. We have until July 22. If it appears that there is a lack of interest in this issue, the regulations may not changeAct now!

An outcrop of the North Horn Formation, rocks primarily on USFS land in Utah that preserve the end of the Age of Dinosaurs and the beginning of the Age of Mammals. Photograph by Andrew A. Farke; CC-BY 3.0.
An outcrop of the North Horn Formation, rocks primarily on USFS land in Utah that preserve the end of the Age of Dinosaurs and the beginning of the Age of Mammals. Photograph by Andrew A. Farke; CC-BY 3.0.

Comments made easy!
To make things easy, Joe Sertich (Curator of Dinosaurs at Denver Museum of Nature and Science) and his colleagues (including paleobotanist Ian Miller and me) have crafted a short form letter that outlines some major concerns with the proposed regulations as well as ways to fix them (text at the end of this post). All you have to do is cut and paste the text into the official comment form with your name. Modify the text any way you like, depending on your personal opinions…if you want something that exceeds the length limit of 2,000 characters, you have the option to upload a longer document (one option is available here). Make sure to take care of this by 11:59 pm EDT on Monday, July 22.

Your Homework

Quick Comment – Sample Text

Proposed regulations for paleontological resources impose unfair, uncompensated burdens on repositories acting in the public’s interest and deprive repositories of the professional discretion needed to manage collections to scientific standards. Help protect paleontological resources by giving repositories the necessary flexibility to grow and manage public collections.

291.11 Casual collecting on National Forest System lands. This section unfairly singles out research-based paleontologists for a greater level of regulation than the casual collector. Research-based collections of paleontological resources should require permitting only when fieldwork exceeds casual collecting.
291.22 Becoming an approved repository. Please clarify how the authorized officer will work with the repository official to determine the content of the collection prior to deposit. Undue interference with curatorial authority will lead museums to decline acceptance of specimens collected on Federal lands–specimens that the Federal government does not have the resources to care for.
291.24 Standards for access and use of collections. This section includes provisions not addressed in the Act and add undue administrative burden on repositories. By virtue of receiving Repository Approval, institution officials should have authority to make reasonable decisions on use and care of specimens according to institutional policies and professional standards.
(e) Fees–Clarify whether the repository may charge one-time curation fees for specimens collected on Federal land by permitted depositors and whether the USDA is able to provide ongoing funding to support curation of these federally-owned collections.
(f) Reproductions–Requirements of sections 1 and 2 on approval for reproductions are excessive and should be eliminated. As written, they would severely limit accessibility of even digital representations to the public. Modern digitization methods pose little physical risk to specimens.

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