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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:

"Ray, Ann" <[log in to unmask]>

Reply-To:

Ray, Ann

Date:

Tue, 23 Feb 2016 23:42:10 +0000

Content-Type:

text/plain

Parts/Attachments:

Parts/Attachments

text/plain (63 lines)

Again, speaking from my own experience, I was not allowed to conduct research on any state-owned or operated property or jointly operated properties (for example UC system reserves or Nature Conservancy lands) without the permit.  I had to provide a permit #.  I was compelled to follow the rules.

-Annie 

-Sent from mobile; please excuse brevity and autocorrect errors 

Ann M. Ray, Ph.D.
Assistant Professor
Department of Biology
Xavier University
104 Albers Hall
3800 Victory Pkwy.
Cincinnati, OH 45207 USA
T. +1 513-745-2054 




> On Feb 23, 2016, at 18:36, Ivie, Michael <[log in to unmask]> wrote:
> 
> I can't seem to find the penalty for violating this requirement?  I assume all permit requirements have some cost for non-compliance?  Assuming there is a penalty, and that a fine is involved, could CDFW enrich themselves considerably by using the databases we so earnestly keep making public to identify violators and send a dunning letter for every specimen?
> 
> No, THAT is worth panicing over.
> 
> Mike
> ________________________________________
> From: Entomological Collections Network Listserve [[log in to unmask]] on behalf of Doug Yanega [[log in to unmask]]
> Sent: Tuesday, February 23, 2016 4:20 PM
> To: [log in to unmask]
> Subject: Re: collecting permits in the U.S. or Canada
> 
> On 2/23/16 12:21 PM, Gaimari, Stephen@CDFA wrote:
> In any case, I have no idea what the fees here specifically go to.
> The CDFW website explicitly states what the fees are for, as John Heraty noted earlier:
> ----
> c) From the F&W site: [reason for new enforcement] "For the last 7 or so years, CDFW reviewed 1,200 to 1,500 SCPs or amendments/ year, while spending approximately $6 for every $1 of fee revenue"
> 
> d) From the F&W site: [Goal] FGC  1002(i): fee adjustment to recover costs (not to exceed implementation costs). Fund permanent, dedicated staff.
> ----
> 
> The fees are to cover administrative costs - specifically, the salary of the guy issuing the permits. It's there in black and white. The permit fee is to cover the cost of issuing permits.
> 
> I will also point out that every single argument you've made in support of what CDFW is doing, and why, applies EXACTLY as well to plants as it does to invertebrates. And yet, the CDFW - even though they explicitly claim jurisdiction over scientific collecting of plants - has NOT implemented a permitting requirement for plants. If invertebrate permits are necessary, then how are plant permits any LESS necessary? In plain truth, the fact that they obviously don't NEED to issue plant permits is prima facie evidence that they don't NEED to issue invertebrate permits, either. Also, even if we accept the need for permits, the National Parks Service manages to issue collecting permits without charging fees, so why is it that they cannot follow this example?
> 
> I will also point out that if all CDFW wanted was data from invertebrate specimens collected in CA, I would happily send them all 91,000 CA records in our database, for free, upon request. But, oddly enough, they do not appear to actually have any interest in data - they have no archives, no stated repository, no online resources, nowhere people can deposit or retrieve scientific collecting data. Their so-called "data portal" contains no occurrence records or distribution maps of invertebrates at all, and their taxonomic resource interface is - to be polite - a complete joke. Just go to https://nrm.dfg.ca.gov/taxaquery/Default.aspx and click on invertebrates - all they have is a checklist of ~7500 "species names" which, in alphabetical order, start off "A Bedbug (Hesperocimex coloradensis)" followed by "A Beetle (Coenonycha pygmaea)", "A Blue (Philotiella leona)", and so on. A vanishingly small number of these checklist entries indicate whether or not the species is native t!
> o California, and that is the extent of distribution data. Not only that, but some of this is baldfacedly wrong, like their entry for the Monarch, which they explicitly state is NOT native here:
> 
> https://nrm.dfg.ca.gov/taxaquery/SpeciesDetail.aspx?taxonid=1227&STitle=Danaus+plexippus+plexippus&PTitle=Monarch
> 
> Our "National Butterfly", and they have no records, no photos, no literature, and don't even acknowledge that it's native in CA. This is not scientific, this is useless, or even WORSE than useless. If all the actual specimen data that researchers submit are going into the proverbial "round file", then what purpose do mandatory collecting reports serve? Your arguments about the utility of gathering data about invertebrates are fine, but they clearly do NOT apply to what the CDFW is doing, since they are clearly not using our data, let alone making it available to anyone after we submit it.
> 
> It is not the filing of paperwork or payment of fees per se that we are objecting to. It is that (1) we are being asked to file paperwork and pay fees for no purpose, and (2) a large measure of what we ARE being asked for are things we cannot provide (e.g., lists, in advance, of species names and numbers, etc.)
> 
> Sincerely,
> 
> --
> Doug Yanega      Dept. of Entomology       Entomology Research Museum
> Univ. of California, Riverside, CA 92521-0314     skype: dyanega
> phone: (951) 827-4315 (disclaimer: opinions are mine, not UCR's)
>             http://cache.ucr.edu/~heraty/yanega.html
>  "There are some enterprises in which a careful disorderliness
>        is the true method" - Herman Melville, Moby Dick, Chap. 82

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