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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.

  1. To Whom it May Concern,

    I am writing to express my concern about the proposed federal regulations regarding collecting and curating fossil resources from federal lands. Although I commend the US Park Service for “taking the bull by the horns” and coming up with ideas, I feel that many proposals were created in a vacuum with little or no input from smaller institutions. I would also point out that the vast majority of institutions collecting on federal lands are good stewards of the specimens they curate. The Curator and Collections Managers in these institutions are best suited, based on their training and experience, to determine whether specimens should be made available for histological or CT analysis. Further, molding and casting specimens to create research casts and “handable” specimens has been a standard for over 100 years. Adding an extra bureaucratic hoop to jump through is counter productive, hinders research and is ultimately unnecessary. I encourage all to review these proposals and amend them. Thank you for your time.

  2. Thanks for the comment, Scott! The only minor correction I would add is that, for now, the comments apply only to the USFS (not Park Service). And as clarified in my last post, many agencies already have restrictions in place for molding and casting–I just don’t think they’re necessary if an institution is already a certified federal repository, and the restrictions are particularly unnecessary for digital reproductions.

  3. Casual collecting unfair? Do you realize that 1 unprepared block with a fossil in it that weighs 25lbs in the annual limit! And only 5 can be of any one kind of fossil! And you can’t use a shovel or pick to get it! Unless you’re doing research on micro fossils these limitations are ridiculous.

  4. So you’re asking people to spam the USFS with cut-and-paste spoon-fed comments that people just assume are accurate, signing their names to something they have no knowledge of.

    Well that’s quite an academic ethic you have there, isn’t it.

  5. Fred, read the post. Throughout, I encourage folks to modify their own comments as they see fit (I see at least two mentions of this). In fact, people are advised to read the proposed regulations before commenting.

    I don’t mind critical comments on this blog if they are well-reasoned, but your past two comments are easily answered by simply reading the post to which you are responding. You are welcome to comment here, but please apply a little skeptical inquiry to your statements from here on out.

  6. Kevin–please submit an official comment to the Forest Service! I am gathering that you are a fossil collector, and it is important that the USFS hear from those who are affected by the rules.

    The reference to the rules being unfair was on the fact that museums are held to a tighter standard than casual collectors (as defined in the regulations). I.e., a museum paleontologist cannot collect even an ounce of ammonite shell without a permit, whereas you could as a casual collector. This would severely limit the ability of even invertebrate paleontologists to conduct exploratory work prior to a more formal field season.

  7. As a collector who also does research I guess I am held to the same standard, only it may be more difficult for me to get a permit!

    I am going to submit an official comment to the Forest Service, just have to keep toning it down…

  8. Great post, Andrew. I’ve already submitted my comments, and appreciate the effort you’ve put into making it easier for others to do so. Reading the nitty-gritty of these proposed rules is not easy, and I continue to discover potential issues with each read. But even sending a comment on one issue, collectively, can be helpful. Thanks for your continuing support of these issues!

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