It’s down to the wire.  Comments on the DOI (BLM) proposed PRPA rules will only be accepted until Monday, February 6th, 2017. 

Here are the issues in a nutshell:

1    “Casual collecting” is too restrictive

2     “Common” is not defined, and it should be noted that only scientifically valuable specimens are what PRPA intend should be in repositories, not specific taxa.  All non-vertebrates s/b considered common until otherwise stated

3    “Reasonable amount” that can be casually collected is too restrictive

4    “Negligible disturbance” guidelines are too restrictive and should just be equated to “low impact” activity

5    “Research” should be allowed on casually collected specimens

6    There needs to be recourse for donating scientifically valuable specimens that were casually collected to repositories without repercussion – this includes vertebrate specimens accidentally collected in matrix, etc.

7    A permit should not be required for non-vertebrate research collecting, unless it exceeds casual collecting expanded parameters

8    Permitting requirements (especially for non-vertebrates) should be expanded to include the non-degreed avocational publishing community

9    A work-around should be figured out for random, incidental and/or co-mingled vertebrate specimens (like shark & fish teeth and vertebras) that are encountered while casually collecting non-vertebrate sites

10    A work-around should be figured out for places with a high proportion of redundant and/or unarticulated vertebrate bones and bone pieces that professional paleontologist have no interest in collecting so they can be salvaged by amateur/avocational collectors

11    DOI should partner with the amateur/avocational community to achieve their inventorying and monitoring goals.  Partnering with the FOSSIL Project would be a good start

12    DOI should partner with the amateur/avocational community to achieve their outreach goals.  Partnering with the FOSSIL Project would be a good start for this too.

13    Find a work-around for an easier mechanism for locality data to be published, at least for non-vertebrate sites

14    Vertebrates and non-vertebrates are not the same thing – not in scarcity, interest or economic value.  Vertebrates  require a much more sophisticated style and method of extraction, curation and preparation than do non-vertebrates.  Please ensure all the rules reflect this.

If you haven’t already, please pick a topic or two and write a comment about it.

Here is the website to post it to:  Regulations.gov