Perhaps we should take up a collection to buy The Paleontological Society a dictionary. They seem to be very confused. Look, I’m never surprised by the inability of scientists to critically evaluate data on issues that hit close to home. We’re human, after all. But I’d hope that an international scientific association would take the time to do some basic homework before sending out a message to its membership recommending comments on draft Federal policies.
Let me back up.
There has been a great deal of debate in recent days over proposed policy for paleontological research on US Forest Service land, most of it measured and well thought out (e.g. here, here, here). By contrast, I’m going to pick on one group here, setting aside measured commentary. The Paleontological Society calls out several sections of the policy that “could have significant implications for research practices.” One of those is centered on a policy requiring that "common invertebrate and plant paleontological resources collected for research purposes . . . would need to be authorized under a permit in accordance with Sec. 291-13 through 291.20." The Paleontological Society says “This would seem to place a higher burden on professional paleontologists… than on casual collectors of fossils…”
Well, no shit. I’ll also set aside the snark from the intro regarding donations of dictionaries, and I won’t bother pointing out that collection for research is by definition NOT casual collecting and violates both Federal regulations and scientific standards (see the law: Subtitle D, Sec 6301(1), and an example of how it would be implemented in policy: 291.11 (c)). Instead, I’ll speak to those standards. It would seem to me that scientists, through a system of research ethics, inherently bear a higher burden of documentation and rigor than a casual collector or hobbyist. Isn’t that what makes the whole show science to begin with? The USFS already has policy in place regarding research permits; this FAQ does a great job of explaining many of the reasons that such policies exist. To sum it up though, Federal agencies bear the responsibility of resource management, and have to balance numerous competing needs as custodians. Additionally, they know quite a bit about the resources under their control, and are interested in learning more through reciprocal exchanges of information with content specialists. Permits are one of the best mechanisms for agencies to understand how their resources are being used and studied, as well as tools to track the location of the specimens THAT THEY OWN. This information is necessary for the agencies to manage their resources properly. Unwillingness to ask permission from the custodians of the land to collect specimens and complete reports on the work done on that land and with the resources is both selfish and unethical. If a scientist can't plan their work in way that complies with law and ethics, and if they can't communicate that work to stakeholders, they probably aren't doing very good science to begin with.
As an example, let's randomly select an organization responsible for promoting the science of paleontology, say, The Paleontological Society, and examine their core documents. Turns out, the first two tenets in their Code of Fossil Collecting state:
"The Society therefore adopts the following practices associated with the collection and curation of fossils:
1. Prior notification will be made and permission or appropriate permits will be secured from landowners or managers of private or public lands where fossils are to be collected.
2. All collections will be in compliance with federal, tribal in the case of Native American lands, state, and municipal laws and regulations applied to fossil collecting."
I support the Society’s instruction to members that “comments on both draft regulations should be constructed carefully, keeping in mind that the agencies are required to prepare these regulations in conformance with their mandates for resource protection and in compliance with the wording of the PRPA law.*” I would also suggest that they read the Society’s own policies, and maybe their notes from junior high regarding the nature of the scientific method.
* Emphasis mine