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ECN-L  February 2016, Week 4

ECN-L February 2016, Week 4

Subject:

Re: collecting permits in the U.S. or Canada

From:

"Gaimari, Stephen@CDFA" <[log in to unmask]>

Reply-To:

Gaimari, Stephen@CDFA

Date:

Tue, 23 Feb 2016 03:38:39 +0000

Content-Type:

text/plain

Parts/Attachments:

Parts/Attachments

text/plain (83 lines)

Hi Barry - none of that would force you to go it alone. I'm sure at any given time there are people looking to have a permit for a particular place, California or elsewhere, that require permits. This listserv is a good place to network such things, I would think. Some places have a fee per person - it's fortunate CA doesn't do that!
Cheers,
Steve
________________________________________
From: Barry OConnor [[log in to unmask]]
Sent: Monday, February 22, 2016 6:35 PM
To: Gaimari, Stephen@CDFA
Cc: [log in to unmask]
Subject: Re: collecting permits in the U.S. or Canada

Hi Steve - I can certainly see your point of view as a government agency in California with 40 people on the permit. So the cost per person is 420/40/3, or around $4 per person per year. I don't live in California, but I would like to collect 2 species of mites for molecular analysis. So in my case it would cost me $420 to collect those two taxa. I don't have a grant right now to cover such things, so this issue means a lot more to me (in dollar terms) than it does for you. Perhaps I could disguise myself as a hobbyist?
All the best! - Barry


- So many mites, so little time!

Barry M. OConnor
Professor and Curator
Department of Ecology and Evolutionary Biology
Museum of Zoology
1109 Geddes Ave.
Ann Arbor, Michigan 48109-1079 USA
phone: 734-763-4354
FAX: 734-763-4080
e-mail: [log in to unmask]<mailto:[log in to unmask]>

On Feb 22, 2016, at 9:07 PM, Gaimari, Stephen@CDFA <[log in to unmask]<mailto:[log in to unmask]>> wrote:

Just jumping off from the OP since there have been so many posts I canít decide which one to reply to! Anyway, there have been lots of comments and viewpoints expressed. I am curious to see the results regarding which states currently have fees, and their cost, for scientific collecting permits that include invertebrates. On the other hand, Iíd be more curious to know which states do and do not have laws on the books in this regard, regardless of whether they enforce them. That would be far more telling, because when budgets get tight, any and every government department will look for the areas that will increase revenue. That may or may not be the case here Ė I donít know, but it certainly isnít a cash cow. Doesnít really matter.

I do have a couple of questions, but first some background. In the interest of full disclosure, I work for the state of CA (CDFA), but am not associated with CDFW. Totally different entities. Iím subject to the same regulations as anyone else who wants to collect. Iíve had a blanket State Parks permit (free) for invertebrates and plants since 2003, which has been subject to annual reporting and renewal. During the last permit cycle, I was informed that we had to first get a CDFW permit before they could renew the State Parks permit. This was as new to the State Parks folks as to me, but this had apparently been the case for years, but hadnít been enforced (I think the regulations are more than 50 years old!). In any case, I spent a great deal of time talking with CDFW folks (enforcement for insects was new to them too) about the whats/whys/benefits of what we were doing, etc., and trying to find the loopholes or convince them that the type of collecting weíre talking about should be excluded from this permitting requirement. In the end, I just applied for and got the CDFW ďentityĒ permit, which covers 40 or so participating scientists, as well as the State Parks permit for the same. It cost a total of $420 for a 3 year permit (the State Park permit is still free), and can be renewed, etc. ($420 every 3 years). The reporting requirements are the same as the State Parks permit Iíve been doing for 13 years. So on to my questions.


1)       Should an environmentally-focused state (any state) department *not* express a vested interest in their invertebrate fauna? When there are state and federally listed species ďout thereĒ, what mechanism exists to protect them if these departments donít even have an idea what anyone is doing on the lands for which they are assigned stewardship? Just trust that people will avoid them? Sorry, I doubt that. Should a State Park be concerned with its archaeological heritage? Without being aware of proposed collecting activities and collecting methods, how do they communicate that an area should not be dug into (e.g., for pitfall traps Ė weíve encountered this one in our 13 years of State Parks permits)? Or is that unimportant?

2)       Given that we entomologists try to sell the importance of invertebrates (which of course they are!), why would we expect or want them to be ignored from this perspective? Arenít they as important as mammals, birds and fish? We cannot say out of one side of our mouths how critical they are to biodiversity and conservations, but out of the other that they are not significant enough that the government should try to monitor even the collecting activities of professionals.

3)       Given that an entity permit can have as many participants as you want, is it unreasonable to charge a $420 fee to cover the entire group for three years? Is $100 unreasonable to make changes within that three year timeframe? Thinking of the costs associated with collecting, if you are a serious collector, I donít see this as a major hit, particularly when you are one of many splitting the cost. We have to pay for permits virtually everywhere we go outside the US. Is it the idea that we never had to do it in the past (even though those who work with vertebrates are well used to it) that gets peopleís rancor up? Iím pretty sure no one in CDFW is living fat and sassy off the $420 bucks they get from scientific collecting permits, although they may have been mandated to find and use their legislatively available revenue streams. My guess is the $420 doesnít come close to covering related expenses. Note too, there is nothing in the regulation mentioning kids collecting for their general interest, so thatís a strawman.

Iím going to leave it at that. Just a few things to think about. But as a last comment, working within the system has allowed the 40 of us on the current permit (and many more over the last 13 years) to collect all over California State Parks. Have there been headaches? Sure. Not more than one might expect when you deal with government subdivisions. But so what? Should I expect that the doors of the natural world are simply wide open to me just because I study insects? I wish they were, but it isnít reality. Do I *want* to fill out permit and reporting paperwork, and make a payment every three years? No. Do I feel entitled to having free reign? No. Do I think it is worthwhile to work within the requirements to get where we want to go? Yes. Do I expect that the government is going to say sorry, youíre right, go ahead and proceed unimpeded? Nope. No matter how much I might like it.

Cheers,
Steve

--------------------------------------------------------------------------------------
Dr. Stephen D. Gaimari
Environmental Program Manager I (Entomology & Botany)

<image002.jpg>Plant Pest Diagnostics Center
California Department of Food and Agriculture
3294 Meadowview Road
Sacramento, CA 95832, USA

Tel. 916-262-1131, Fax 916-262-1190
E-mail  [log in to unmask]<mailto:[log in to unmask]>
http://www.cdfa.ca.gov/plant/ppd/staff/sgaimari.html
--------------------------------------------------------------------------------------

From: Entomological Collections Network Listserve [mailto:[log in to unmask]] On Behalf Of John M Heraty
Sent: Friday, February 19, 2016 5:58 PM
To: [log in to unmask]<mailto:[log in to unmask]>
Subject: collecting permits in the U.S. or Canada


Dear all,

I am interested in collecting data on any agencies in the U.S. that collect a fee for issuing collecting permits for terrestrial insects that are not protected or endangered. If so, how much do they charge? If you can please send me a value and link, I will collect the data and report back to the group.

California Department of Fish and Wildlife in now enforcing a scientific collecting permit ($420) for the collection of any terrestrial native insect (invertebrate), including those that are not protected (https://www.wildlife.ca.gov/Licensing/Scientific-Collecting).

I am not interested in those agencies that issue permits but do not charge a fee (I know there are lots of those).

I would like to find out if there is anything similar to what CDFW is applying elsewhere.

Please respond to me individually.

Many thanks,

John Heraty

University of California
Riverside, CA

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