Act now! Proposed US Forest Service regulations are bad for paleontology

Public lands (those areas owned by the government) are a tremendous asset to the United States, brimming with recreational opportunities, natural resources, beautiful vistas, and best of all: fossils! Many spectacular fossil discoveries within the United States originated on public lands–the elaborately horned dinosaur Kosmoceratops, swim traces of fossil fish, and even beautiful petrified wood with insect burrows, to name just a few examples from PLOS ONE. A long-standing partnership between federal agencies and scientists has been wonderfully productive. But, a new batch of federal regulations threatens paleontological research on fossils from some public lands.

The skull of Kosmoceratops, a discovery made on federal lands. Modified from Sampson et al. 2009. CC-BY.

The skull of Kosmoceratops, a discovery made on federal lands. Modified from Sampson et al. 2009. CC-BY.


A little background
Fossils found on federal lands belong to the American people. In practical terms, the arrangement has worked out quite well for everyone. If I want to collect fossils (particularly vertebrate fossils) on federal land, I first have to apply for a permit from the appropriate agency (Bureau of Land Management, Forest Service, National Park Service, US Army Corps of Engineers, etc.). In the permit, I outline my qualifications as a scientist, state the scientific purpose of my work, and list the areas where I wish to collect. If the permit is granted, I agree to abide by a quite reasonable set of rules (many in place to protect the sites for the long-term).

As an important term of the permit, I must ensure that any fossils I collect are deposited at an appropriate museum that can care for them in the long-term. For vertebrate fossils in particular, this means that the fossils cannot disappear into a private collection. But, the museum will not own the fossils either–they remain the property of the American people. Basic standards of collection care are required for any such federal repository. This is generally a good thing, to ensure that the fossils are always safe and available to researchers. For instance, a cash-strapped museum couldn’t just sell off its dinosaur bones.

In practice, museums invest a lot of resources into these fossils (usually, but not always, with minimal federal support). They cover collection expenses, preparation expenses, research expenses, and curation expenses. When it comes to research, paleontologists historically have been given pretty wide latitude, particularly once the fossils are back at the museum. As long as the museum collections managers and curators responsible for the collections are OK with a research protocol, the feds have been willing to trust museums to make decisions about collections in their care. After all, who better knows what is good for the fossils than those who work with them every day?

This is all about to change.

Good news/bad news
The 2009 passage of the Paleontological Resources Preservation Act (PRPA), as part of a big omnibus bill, was hailed by many paleontologists as a big step forward for our science. In many ways, it was–previous laws governing paleontology on federal lands had been a patchwork quilt assembled over 100 years, with some regulations MacGyvered into service from archaeology (just mention the “1906 Antiquities Act” and you’ll see a paleontologist roll his or her eyes). With PRPA passed, it was time for the relevant authorities to propose guidelines for paleontology on federal lands.

First out of the gate are draft regulations from the United States Forest Service (USFS). Released just a few weeks ago (full text available here), they’re available for public comment until July 22. There is much to like about the regulations–indeed, most paleontologists will notice little difference in how they do business. However, one section in particular is quite worrisome (footnotes are mine):

“(1) Prior to reproducing a paleontological resource, the repository will notify and obtain approval from the authorized officer*. Reproductions include, but are not limited to, molding and casting, computerized axial tomography (CAT) scans, and three-dimensional (3-D) rendering.

(2) The repository may only allow consumptive analysis of specimens if the authorized officer* has determined, in consultation with an agency paleontologist, that the potential gain in scientific or interpretive information outweighs the potential loss of the paleontological resource and provides the repository with written authorization for such use.”

–Quote from Section 291.24, “Standards for access and use of collections”
*”Authorized officer” is not someone who works for the museum–it refers to a government official. As written, they are not necessarily a trained paleontologist!

Microwear on the tooth of the long-necked dinosaur Diplodocus. This image was produced after molding the original specimen--something that would be much more difficult for USFS specimens under proposed rules. Modified from Whitlock 2011. CC-BY.

Microwear on the tooth of the long-necked dinosaur Diplodocus. This image was produced after molding the original specimen–something that would be much more difficult for USFS specimens under proposed rules. Modified from Whitlock 2011. CC-BY.

Why so serious?
If these regulations are enacted as written, paleontologists and museums will need an unprecedented level of government approval for many basic tasks. Here are just a few examples of how this might play out:

  • A museum wants to replicate a Tyrannosaurus tooth found on USFS land, for public outreach. After all, it’s better than having the original specimen handled by countless people. Sorry–you’d better get the Forest Service to sign off before you even think about molding and casting that fossil.
  • A museum wants to laser scan a fossil horse jaw from their collections that was found on USFS land. Gotta get permission from the Forest Service first.
  • A researcher at another museum wants to make a 3D print of the aforementioned horse jaw, from the laser scan made by the museum after they acquired permission to make the scan. Sorry, you’d better check with the USFS before making that print.
  • A graduate student is studying dental microwear on fossil camel teeth from the Barstow Formation. The student gets permission from the museum to mold tooth wear surfaces for her study, and buys a plane ticket and books a hotel room. While browsing collections at the museum, she finds some fossils she didn’t know about that would make an excellent addition to her study. But…they’re from USFS land. Sorry, but she’ll have to come back another time after filling out the requisite paperwork. Unfortunately, her budget is too tight, and the fossil will never make it into her sample.
  • A paleontologist discovers a virtually complete dinosaur skeleton on Forest Service land, and collects the specimen after securing all of the necessary permits. It’s from a small dinosaur that looks like it could be a new species. Or, is it perhaps a young individual of another species from the same area? The best way to find out is to remove a piece of bone and study its microstructure. Previously, a collections officer at the museum could sign off on this. But in this case, the project first has to get clearance from a USFS official. They’re not terribly familiar with histology, and the agency paleontologist they consult certainly doesn’t like the idea of the skeleton from a new species of dinosaur being “damaged.” Permission denied.

Researchers and museums will be hobbled for basic scientific procedures such as CT scanning, histology, isotopic analysis, and molding/casting [important note: see clarification at the end of this post]. Indeed, the burden is such that many will just say “forget it” when it comes to working with USFS specimens. They’ll just sit in a drawer, with their full potential of scientific study never realized. This is completely against the spirit of the original legislation, and not at all what many of its supporters intended.

Thin-sections of this Tenontosaurus bone provide valuable information on how these animals grew. This kind of work would require special approval from the USFS under the proposed regulations. Image modified from Werning 2012. CC-BY.

Thin-sections of this Tenontosaurus bone provide valuable information on how these animals grew. This kind of work would require special approval from the USFS under the proposed regulations. Image modified from Werning 2012. CC-BY.

What’s the problem here?
In the current system, museums are trusted to make decisions about specimens in their care. After all, who knows better about what is good for fossils than qualified and trained collections managers, curators, and paleontologists? The proposed regulations would take these decisions out of the hands of the people with the most immediate knowledge of the specimens and the science, and place the ultimate decisions in the hands of individuals who may be completely unfamiliar with paleontology. Even if the official is a paleontologist, there is no guarantee that they have the expertise or background to make an informed decision about specimens they may have never seen! In the best case, the regulations could add weeks or months of waiting before basic research is allowed to proceed.

But wait…isn’t this just ensuring that rogue museum paleontologists won’t go willy-nilly with federal specimens? Not in the least! Right now, every single museum that is allowed to hold federal specimens (including those from the USFS) has to pass stringent criteria. They are held to high standards for specimen security, storage, and record keeping. If a museum has already jumped through all of the hoops to become a federal repository, it is certainly capable of being trusted to make decisions about scientific use and reproduction of specimens!

Not a scientist?
If you are not a scientist, you are affected, too. “Old” technologies such as molding and casting brought the public into contact with many fossils they never would have seen otherwise, and “new” technologies such as 3D printing have the potential to spread fossils even more broadly. The new regulations will make it much more difficult for museums and other institutions to share their specimens with the public. This is ironic, because the explanation of the proposed rules fully acknowledges the importance of fossil reproductions!

What should you do?
These regulations will have a chilling effect on paleontology, adding layers of red tape to research and outreach that have never needed it previously. Even if you don’t work on fossils from USFS land, you need to take action. As the first set of regulations from a government agency, they may well provide a template for other federal agencies (BLM, NPS, etc.) crafting their guidelines. If you study fossils from the United States, odds are quite good that the rules will eventually impact your work.

Fortunately, these regulations are not yet permanent. Read them over yourself. Submit a written comment by July 22. Encourage your friends and colleagues to do the same. Encourage your professional societies to take a stand (The Paleontological Society has already issued a statement; here’s hoping Society of Vertebrate Paleontology does also!).

The solution is simple: let the museums make decisions about specimens in their care. A simple rewording of the regulations is all that is required. This is best for science, and best for the fossils.

Update/Clarification: In some cases, a “Memorandum of Understanding” between museums and federal agencies is already in place (indeed, my own museum has some of these), that places some restrictions on the use of federal specimens (e.g., for destructive sampling). Anecdotally, these are not universally in place for all agencies. For the ones I’ve looked at, issues of digitization are not addressed yet. In any case, this is an opportunity to do things right. . .let’s remember that these are public specimens. It is not in the public’s best interest to restrict even digital access.

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36 Responses to Act now! Proposed US Forest Service regulations are bad for paleontology

  1. Fred says:

    Are you kidding? My guess is that you are not. The USFS is proposing protections for what’s left of our wilderness and watersheds, all of which are absolutely vital and legitimate… So instead of accept the overwhelming need for safety policies to be imposed, you heap on outrageous, unevidenced, out-of-the-blue fear-mongering “and they could also do this” scenarios which nobody is proposing.

    I know you won’t post comments that point out your extremist “the gubmint’s out to get us!” right wing lunacy, yet ask yourself if anybody but right wing loons will believe anything you post here. (Hint: the answer is no. Nobody.)

    • Kraig Derstler says:

      Fred – Andy’s analysis is modest and his position is well supported. His rhetorical device – using hypothetical scenarios — is appropriate to illustrate situations that could arise if the proposed rules are enacted. All of his hypotheticals are reasonable. I cannot see where the American people nor their property will suffer if museum officials are empowered to do their job and make decisions about scanning, casting, and preparing fossils in their care. I’m not sure how anyone wins if another layer of non-expert bureacracy is invented by the USFS. I urge you and other readers to support Andy’s proposal.

    • William says:

      Fred, your response sounds knee-jerk and suggests you either didn’t read the post or don’t understand it well enough to make an informed comment. About the only detail in your diatribe that actually relates to the issue at hand is that this is a USFS proposal. Everything else you’ve said appears targeted at a straw man of your own creation.

  2. Andrew Farke says:

    Fred–please read the post in detail. This is not at all about protecting wilderness and watersheds (I support efforts to protect fossil localities and their surrounding areas “in the wild”), but about what happens to the fossils after they are collected and back in a museum. CT scans, histology, molding and casting are all museum-based activities. . .if fossils cannot be studied thoroughly, there is little point in collecting them in the first place.

  3. RightCowLeftCoast says:

    The bane that is well-intended government over-regulation is now negatively impacting well meaning scientists. Careful if one doesn’t adhere to the letter of the law, least you incur fines and possible jail time, even if you didn’t have any intent to brake the law.

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  5. Roy Plotnick says:

    One area with lack of clarity is collecting, particularly of common invertebrates, for educational purposes. If I lead a class field trip on to USFS land, do I need a permit or not? Does it count as “casual collecting?” I have written to them that this issue needs clarification.

    • Andrew Farke says:

      Absolutely…another issue is what happens if an interested amateur legally collects an invertebrate fossil on USFS land that they later want to donate to a museum?

    • don hopkins says:

      From the information I got from one Western state (overseeing BLM land use), if you weren’t an invertebrate academic and wanted to collect invertebrates for personal use (your collection), that would be considered ‘hobby’ collecting and wouldn’t require a permit. However, if you lead a class in the field, then the class and the material collected would have an ‘educational use’ and would require a permit.

      • 220mya says:

        Don – Each federal land agency has its own rules on paleontological resources, so the rules for BLM have little to do with those for the USFS. In fact, the BLM is part of the Dept of Interior, whereas USFS is part of the Dept of Agriculture.

  6. Anne O Suibhne says:

    If the government were as concerned about other uses of National Land as this proposed legislation seems to portend, we wouldn’t be arguing about fracking, mining and mountain-top skimming, among other more invasive uses of National Forest and other National lands. The idea that fossils need “protecting” from the very experts who are doing the work (for extremely little thanks, let alone money) by some non-professional bureauocrat, sounds to me like an excuse to waste a lot of time and money that would be much better spent elsewhere.

    I’m not right wing and I don’t know whether the government is “out to get” anybody or not. That statement is so irrelevant I can’t even take it seriously. This just sounds like a foolish waste and another unnecessary layer of bureaucracy to me. I know the respect and passion professional Paleontologists have for their work and for their specimens, and can’t even imagine a scenario where their work would require this kind of oversight.

    I say NO to this proposal. It’s just plain dumb. (That’s my scientific opinion as a Communications Professional (MS, Communications).

  7. Chris Honeycutt says:

    I am really baffled by the new rules regarding replicas, molds, casts and particularly nondestructive scans.

    What is the intent of the law? Why do they want to restrict nondestructive reproduction? There doesn’t seem to be any reason for it.

    • Andrew Farke says:

      Molding is inherently a dangerous process, and specimen damage is always a possibility. Thus, that clause is somewhat understandable. Other methods of reproduction, though? Not sure what the logic is behind it.

  8. Pat says:

    Does this mean I will no longer be able to purchase the casts made from the original tooth and claw of the “dinosaurs” as I had purchased from the Forest Service information/ store at Hoover Dam? Will the Forest Service be making the casts themselves for the purpose of selling, and casts will no longer be allowed for study?

    • Andrew Farke says:

      You would probably be able to purchase casts–it would just require museums go through an extra bit of paperwork before they can make them (if they aren’t required to do so already–similar agreements are already in place for some agencies at some museums).

      • Andrew Farke says:

        And as for research casts, those would also be allowed…if the museums get permission first. Again, this is already in effect in some cases. However, that doesn’t mean it’s a good thing…the regulations as written don’t have any time limits in place (so there is no guarantee requests to mold/cast will be answered in a timely fashion) nor is there any way to appeal (if the request is unreasonably denied).

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  10. T Fremd says:

    For the most part, this is a good piece. The title threw me, however … it seems that it really is “Act Now! Proposed US Forest Service Regulations IN SECTION 219.24 Are Bad For Paleontology, But There is much to like about the regulations–indeed, most paleontologists will notice little difference in how they do business”

    • 220mya says:

      I agree with Ted. Although I completely agree with Andy’s critique, and I think there are other areas of the draft regulations that need improvement, the title is sensationalist and misleading. Overall, the writing and implementation of these regs is a good thing as long as a few sections are modified based on comment from paleontologists.

      • Andrew Farke says:

        Thank you for your comments…I apologize if the title came off as sensationalist…that was not my intention at all, although I can see how it can be read that way. However, I still maintain that selected portions of the regulations *are* bad for paleontology as a science (and as you note and I note in the post, other parts are quite fine). There is little point for a museum to invest in infrastructure and staff salaries to support these collections if the activation energy required to actually use the collections is intimidating or prohibitive.

        In any case, this probably calls for a follow-up post. . .the good news is that all of these issues are fixable, particularly if interested individuals comment.

        • 220mya says:

          Yes, but your title implies the whole set of regulations is bad for paleontology.

          As I said before, I completely agree with you on the areas of the draft are concerning, and hopefully commenting on the draft will help sort that out.

  11. Alton Dooley says:

    I’m a bit torn on this.

    I approve of the federal agencies having more stringent regulations in place. They are ultimately the ones responsible for the preservation of the specimens, even if they farm out the task to repositories. The agreements my museum has in place with BLM requires pre-approval for destructive sampling and producing replicas. I’m not crazy about those aspects of the agreement, particularly the one requiring pre-approval for producing replicas. In particular, I don’t see the logic in not allowing 3D scans, and in regulating the production of replicas once scans or molds have been produced. There is no risk to the specimen to produce casts/prints if the molds or scans already exist.

    However, when we loan out specimens that belong to the museum (not BLM), a standard part of the loan is that no destructive sampling is done, nor replicas produced, without our prior permission. So the proposed restrictions are similar to those that museums put on any loans that we make of our own specimens.

    That said, the lack of expertise in paleontology, particularly at the USFS, is likely to be an issue if they are tasked with making decisions on the use of fossils. In the case of the BLM and Park Service, at least in my experience, the person making the decision is usually a paleontologist of some sort, and I’ve not had any issues come up along these lines. If the USFS is going to accept that regulatory responsibility, they need to ensure that they have staff with the expertise to properly carry out those regulations.

    While I think these regulations need some revision, I don’t think there are massive flaws; as I mentioned above, my main issue is with production of replicas.

    • Andrew Farke says:

      Thanks for your comments on that! A good perspective…I can see where you’re coming from on having some jurisdiction by the USFS over reproductions. Ideally (as others have noted here), some of this could be handed off to the institutions in a repository agreement. Still, I would feel better if that were clarified and made more consistent in the regs themselves.

      I completely agree on the issue about paleontological expertise in the agency…this seems to be a very mixed bag, with considerable variation from agency to agency, as well as from state to state. Many of the concerns I’ve heard from colleagues have arisen as a result of archaeologists or other tangentially related staff making permitting/collecting decisions. This is not to say these folks are bad people–just that they aren’t familiar with how paleontology works. For my part, I’ve had generally pretty positive interactions!

  12. Matthew D. Trager says:

    This post came up on my daily Google Alerts notice for “Forest Service,” and I’m glad that it made the list.

    The variety of concerns in the original post and comments are exactly why agencies are required to solicit public comments on proposed regulations. The main issue here is balancing agency accountability for specimens with appropriate scientific and educational purposes that may occasionally damage that property. The alternative of the agency having jurisdiction for the specimens but no oversight is simply not a tenable solution, nor is complete control over specimens collected from Forest Service land. So, these regulations are clearly an attempt to find an appropriate tradeoff between resource protection and use.

    As a current Forest Service employee with some experience in interpreting our regs (though not this one in particular), I suspect that the proposed rule will not actually restrict very much legitimate scientific activity for the following reasons:
    1. Paragraph 291.24(f) does not state that institutions cannot reproduce or conduct destructive sampling on specimens, only that the language in that section will describe “when repositories must obtain approval from the authorized officer before allowing certain uses that may subject the specimens to damage.” i.e., it may not be required in all cases.
    2. Institutions should be able to incorporate language regarding appropriate use of speciments into their MOUs with the agency.
    3. The proposed rule defines an authorizing official as the person to whom authority has been delegated by the Sec. of Agriculture. My guess is that this would be a higher-level person in the Washington Office minerals and geology staff rather than at the forest or district level, so the chance that a qualified geologist or paleontologist would review the agreement is actually pretty good.
    4. The opportunities for comments should allow resolution of at least some potential problems. I take public comments on my projects very seriously, and the team reviewing comments on these proposed regulations are required to consider substantive comments regarding the effects of the proposed language as well as suggestions for alternative language. So, I encourage those interested to carefully review the proposed language and the directions for comments provided in the original post.

    • Andrew Farke says:

      Matthew–many thanks for your detailed comment! It is excellent to get perspective from someone “on the inside”, who understands how the USFS works.

      One small comment–your note on 291.24(f) is, I think, referring to the explanation of the regulation, not the regulation itself. The reg does state that an authorized official must give approval. . .in any case, hopefully this will get worked out in the revisions.

      And I completely agree that the ability for the public to provide comments is a wonderful thing! I hope many interested folks take advantage of this.

  13. Chris Honeycutt says:

    Something else to be considered: what about fossils that constitute a major percentage of the rock? Two examples include bioturbation and shell deposits from storms.

    Would people need permission to perform “consumptive analysis of specimens” such as these?

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  15. Lee says:

    If they’re worried about damage, they should rest assured that curation facilities usually have glue. Fossils suffer damage as soon as the wind and rain uncover them. A paleontologist’s job is to control and prevent excessive damage. The inevitability of excavation if that fossils will break without you touching them. I have meticulously exposed perfect bones only to watch them crack as the moisture from burial evaporated. You can’t add consolidant while a bone is still “wet”, so you control the inevitable damage in the field and trust that the preparators can stabilize and reassemble everything back in the lab. If these USFS rules acknowledge that museums are the best places for collected fossils to reside, that trust should extend to the research and seeking methods conducted therein. These proposed rules are fraught with ignorance.

  16. Scott Foss says:

    Under the law federal bureaus must manage publicly owned paleontological resources. That responsibility may not be delegated to the public or a non-federal partner. Therefore, partners should help bureaus to incorporate scientific best practices into policy that is consistent with the law.

    I have attached a link to the Paleontological Resources Preservation Act (PRPA) of 2009:

    • Andrew Farke says:

      Thanks for the comment, Scott! You are absolutely correct that these partners must provide input (particularly because they’re often the ones doing the day-to-day of collections care, fieldwork, etc.). . .we need to take advantage of this commenting process, otherwise we have no right to complain if we don’t like the end result.

  17. Fred Barmwater says:

    I am a volunteer at the Denver Museum of Nature and Science and work in the Paleo Lab prepping fossils for the last 7 years.
    One has to wonder what problem has arisen that invites these new proposed regulations.
    In Andrew Farke’s blog, he writes: “Right now, every single museum that is allowed to hold federal specimens (including those from the USFS) has to pass stringent criteria. They are held to high standards for specimen security, storage, and record keeping. If a museum has already jumped through all of the hoops to become a federal repository, it is certainly capable of being trusted to make decisions about scientific use and reproduction of specimens!”
    This process seems to address any issue of unqualified people making decisions about fossils in their care and how they can be used: storage, prep, research, duplication and loan-outs.
    I offer one suggestion. Museum personnel does change over time as well as the Government people who turn the fossils over to the approved museums. We hope that all the new folks on both sides are at least as qualified and as well versed in fossil issues as the present staffs. But that may be wishful thinking.
    When staffs change, maybe periodic review and continued approval of the museum repositories is appropriate. The front-line BLM, USFS, etc. folks that work directly with their respective repositories know when museum staff changes have occurred. Only they would fill out a form that either affirms the institution is maintaining the same high standards it had when approval was given initially or notes a red flag if they suspect care is deteriorating.
    In my opinion, with continued approval after a staff change, the facility should not be second-guessed in how it decides to curate, prep, conduct research or copy the fossils in its care. Additional delay for more approvals or further review of procedures is unwarranted and will have a chilling effect on moving the science forward.
    Fred Barmwater

    • Andrew Farke says:

      Thank you for your input, Fred–you are absolutely correct. Federal agencies certainly need to do their due diligence when it comes to making sure repositories are holding up their end of the deal…in my tenure at the Alf Museum, we have had periodic visits from California BLM staff, to make sure we are doing everything properly. These inspections are generally pretty painless, and I view them as a good thing because it lets the BLM staff see what we’re doing. They can better assess our needs, and have even been able to send some support (internships, curatorial supplies) our way. It’s not a lot (specimen boxes here and there, ethafoam, etc.), but every bit helps.

  18. Dr. Larry Bradley says:

    I am inclined to support these new regulations. My research deals with how museums like the American Museum of Natural History will not allow an American citizen, inner-city minority, dis-abled American veteran, who was raised by Oglala Lakota (describing myself) to study fossils collected off of Native American land and reservations from the last 160 years. I think my lobbying efforts and research are finally paying off. Finally, museums like AMNH brought this upon themselves by not allowing the Great Plains Tribes to study specimens housed there.

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  21. Martin Lockley says:

    As a professional paleontologist who has collected fossils on federal and state land for 30 years, with permits to reposit in three musuems in Colorado, all acredited, I am mainly concerend that the Federal agencies do not give these institutions discretion to distribute replicas to other bona fide institutions without additional bureaucratic, and often very time consuming obstacles. For example I know of one written request that has received no reply for a full year. Often these proceedures are managed, as other bloggers point out, by non-paleontologists. It seems a rather obvious contradiction to recognize an accredited repository as a respnsible institution, and then not allow it to act as such without another whole round of paperwork and permissions or authorizations, which may take ages and get lost or misinterpreted in the cracks.

    I have been privy to a number of communications (verbal and email) where curators and collection managers have asked federal and state agencies what their policies are regarding relication and distribution of specimens (I am only refering here to replicas, of course). The almost universal unoffiocial response is that agencies want to give the museums (repositoiries) a free hand in making these decisions, and that they even endorse sale of replicas if the proceeds go back into research, educational or curatorial programs, which they always seem to do anyway. [The less-desirable alternative seems to be to encourage gift shops etc, ., in the commerical sales of material, often from unverified sources].

    So if this trust-our-museums and repositories philosophy makes sense, why not implement it? Simply ask repositories to provide a list of any specimens they replicate and disttribute to other institutions (or replicate for their own exhibits, outreach and educational programs). In my experience the collections I have amassed have been greatly enhanced by mutually beneficial donations and exchange of replicas with other institutions. I don’t even know of a case where the distribution of a replica from one bona fide institution to another has met with an admonishment or query from an agency… [tho’ perhaps there have been cases?] So if it ain’t broke, is there a need to fix it?

    Keep is simple to expedite the flow and exchange of scientific information. If not surely scientists will be put off by the bureaucracy and have less time or inclination to do science and help the agencies with the documentation, protection and sensible management and interpretation of resources.

    If I understand correctly, and colleagues from Federal agencies tell me this is so, PRPA allows Joe public to still collect invertebrates and plants from many federal lands without a permit, but not researchers. Is this a fair and balanced or necessary approach?