This post is in response to a thoughtful comment left by an invertebrate paleontologist by the name of Phil on my previous post regarding The Paleontological Society's reaction to proposed USFS policy for managing paleontological resources. Read his comment first.
I do appreciate that there is a difference in the scale or scope of some vert vs. non-vert collecting. I have dug several-meter wide quarries and excavated sauropod dinosaurs, disrupting an enormous amount of overburden in the process. I've also certainly spent my share of hours crawling across outcrop collecting tiny nodules hoping for primate teeth. In that case the results of two weeks of prospecting fit into a quart sized baggie. That the fossils were wee, or that my actions were relatively non-invasive does not constitute casual collecting. The method of collection or quantity collected is not the point, and neither is your attitude while collecting. The law speaks to the use of the material. Research collecting vs. hobbyist collecting is the distinction to make, "casual" does not mean "not that difficult."
To reiterate, the land agencies are tasked with resource management, they must balance needs for science, conservation, recreation, and commercialization. Certainly the type of excavation required for megafauna has more potential to impact natural resources and make land managers nervous. However, compliance with laws like NEPA and ARPA is only part of the reason that Federal agencies want to know what researchers are up to in the field- they learn more about the resources in their care through the processes of permitting, annual reporting, and subsequent publication. Also, the agencies have to report to Congress letting them know what kind of job their staff are doing managing that land. They can additionally help coordinate or facilitate research projects, when they know they are going on.
One vertebrate paleontologist collecting and reporting under a research permit will be interacting with agency land managers, communicating about their findings, receiving in some cases material help in the form of volunteers, vehicular support, or funding, and in the process is educating the government employees about the scientific value of their study area. Joint press releases are even released sometimes, highlighting the partnership. One hundred invertebrate paleontologists collecting under "casual use" provisions will receive none of this attention, so maybe it is no wonder that non-vert paleo is underfunded/recognized.
The final and most important point is this- the current USFS proposal is restating past regulations in compliance with the new PRPA law. There is nothing new about the content. I acknowledge that Phil was commenting from his perspective only, but if invertebrate paleontologists feel like regulations about research permitting on public lands is some fresh new hell, then there is certainly more misinformation circulating than I'd feared. In the words of the U.S. Forest Service:
"Failure to obtain a special use permit for research violates Forest Service Policy and Federal environmental regulations, and may jeopardize completion of the research."
Interview with Open Access Nigeria
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