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By the way, the USFS does issue collecting permits, even for insects, 
negating that argument. Special Management areas may require permit for 
even recreational collecting. The Caribbean National Forest is an 
example of a requirement for insect collectors to have a USFS permit, 
and for a few years at least, so was Madera Canyon.

Mike

On 2/20/2016 1:31 PM, Doug Yanega wrote:
> On 2/20/16 11:52 AM, Ivie, Michael wrote:
>> To answer one specific question yes the state does have jurisdiction. 
>> You cannot hunt in the national forest without a state hunting 
>> license.  You cannot fish in the national forest or BLM land without 
>> a fishing license which comes from the state. There's nothing 
>> intrinsically difference between that and the insect permit. Yes I 
>> know you can't Fish
>> on land but you know what I mean.
>>
> These are not equivalent cases; the National Forest Service does not 
> issue hunting or fishing licenses, so there is no conflict of 
> jurisdiction in your example. The National Parks Service DOES issue 
> collecting permits. What's happening is the CDFW is telling the NPS 
> that they should not be granting Federal NPS collecting permits to 
> people who do not already have CDFW collecting permits from the State. 
> This IS a conflict of jurisdiction; as I noted, at least one NPS 
> administrator in California explicitly rejects the CDFW's claims of 
> authority - thereby also directly contradicting your answer.
>
> Peace,
>

-- 
__________________________________________________

Michael A. Ivie, Ph.D., F.R.E.S.

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Montana Entomology Collection
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Montana State University
Bozeman, MT 59717
USA

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USA


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