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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:
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c) *From the F&W site: *[*r*eason 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 ยง 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 to 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