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.
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]
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.
University of California