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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]

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

Just jumping off from the OP since there have been so many posts I can’t
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, I’d 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 – I don’t know, but it certainly isn’t a cash cow. Doesn’t 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. I’m subject to the same
regulations as anyone else who wants to collect. I’ve 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 hadn’t 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 we’re talking about should be excluded from this permitting
requirement. In the end, I just applied for and got the CDFW “entity”
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 I’ve 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 “out there”, what mechanism exists to
protect them if these departments don’t 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 – we’ve 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? Aren’t 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 don’t 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 people’s rancor up? I’m 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 doesn’t come
close to covering related expenses. Note too, there is nothing in the
regulation mentioning kids collecting for their general interest, so that’s
a strawman.



I’m 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 isn’t 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, you’re
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]

http://www.cdfa.ca.gov/plant/ppd/staff/sgaimari.html

--------------------------------------------------------------------------------------



*From:* Entomological Collections Network Listserve [
mailto:[log in to unmask] <[log in to unmask]>] *On Behalf Of *John
M Heraty
*Sent:* Friday, February 19, 2016 5:58 PM
*To:* [log in to unmask] <[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