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This is seriously important

Hey folks,

I just received this information from a friend. This is of major importance to all insect enthusiasts in California. although the wording if for scientific collecting it is going impact all insect collect, scientific and hobby. It is vital that Fish and game get a flood of protest so I encourage all members of this forum to send a letter to Calif fish and game. However any emails should be as professional as possible, no cursing or name calling as this will cause them to disregard the input and make as a group look bad.Your email should be addressed as follows.

Subject: Scientific Collecting Permits ATTN: Ona Alminas


To: California Department of Fish and Wildlife
Regulations Unit - Scientific Collecting Permits
Attn: Ona Alminas, Environmental Scientist
1416 Ninth Street, Room 1342-A
Sacramento, CA 95814
Phone: 916-651-9167
Email: SCPermits@wildlife.ca.gov

You might have heard about the draconian regulations that the California Department of Fish and Wildlife is proposing regarding collection permits for insects and other terrestrial invertebrates. There is a public comment period until May 8, I would encourage others to independently protest the proposed regulations. Information about them is here: www.wildlife.ca.gov/Notices/Regulations/SCP. It is really hard to wade through the legalese, but the specific forms and regulations that affect insect collecting are:

Scientific Collecting Permit, General Use – Application (Terrestrial Wildlife)

Scientific Collecting – Mandatory Wildlife Report

Scientific Collecting – Notification of Field Activity

Scientific Collecting – Standard Conditions for all Permits


The inappropriateness of these regulations for insects is self-evident. Read and protest.

Below is a good example of a professional letter sent in by Phil Ward.

I write to express my concern about the broader aspects of proposed regulations of Scientific Collecting Permits (SCP). I am one of many entomologists in the state of California who conducts field work which involves sampling of insects. Such field work can include trapping of insect pests, monitoring of medically important arthropods such as mosquitos, procurement of insects for ecological and behavioral studies, collection of insects during the teaching of entomology classes, and the surveying of insects for taxonomic and biodiversity investigations. We usually cannot predict beforehand what species or quantities of insects will be encountered. Moreover, the decision to engage in field work will often be made on an ad hoc basis, depending on weather, the threat of pest outbreaks, availability of field assistants, etc. Many insect samples, particularly those collected for taxonomic purposes, will remain unsorted to species for months or even years, until taxonomic experts have an opportunity to examine the material. It should also be noted that there are literally tens of thousands of species of insects in California—the exact number is unknown but it could well exceed 50,000, and many of these are not yet described.


Under these conditions the current and proposed SCP regulations, as they concern non-endangered terrestrial invertebrates, are unjustified and intrusive, an example of inappropriate government regulation of a benign scientific activity. Of course, if collecting activity affects endangered or threatened species, or it is occurring on state or federal parklands, there is a need for oversight. But to require a state permit for scientific collection of any insects, anywhere, and to saddle this with unrealistic reporting requirements, is a misguided policy that will only serve to undermine the advancement of education and research in this state. The proposed regulations also impose a burden on California agriculture and public health programs, because comprehensive sampling and monitoring of insects is integral to the development of more sustainable and environmentally friendly pest management technology.


These arguments apply equally to other terrestrial invertebrates such as nematodes, centipedes, millipedes, mites, ticks, spiders, and many others. Collection of these organisms, as well as insects, should not require a scientific collecting permit from CDFW unless they fall under the category of threatened or endangered species, or species of special concern. Except for those species having protected status, terrestrial invertebrates should be removed from the proposed regulations, thereby eliminating an unnecessary provision that serves no useful purpose, and imposes an unjustified burden on entomologists and other scientists. This is just a matter of simple common sense.

Lawyer Up
It seems like this is a topic that requires a lawyer familiar with the current laws and proposals to comment.

I'd be flabbergasted if any such laws are on the books in Washington, as the Forest Service has its own liberal wording for collecting.

What's quoted here sounds like what the National Parks require. I've collected in Olympic National Park under permit, so I've seen such permits.

 
Forest Service Collecting
See this bugguide thread:

http://bugguide.net/node/view/904336

I don't know if the cited document has been superseded, but here's another document that mentions the one I cited in the other thread:

https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fsm91_054415.pdf

Darn I did not verify that th
Darn I did not verify that the links were intact

Scientific Collecting Permit, General Use – Application (Terrestrial Wildlife) https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=141263

Scientific Collecting – Mandatory Wildlife Report https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=141269

Scientific Collecting – Notification of Field Activity https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=141280

Scientific Collecting – Standard Conditions for all Permits https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=141272

Also a further comment from Doug Yanega

>
I will note three things to reinforce Gordon's call for comments:

(1) these laws are already on the books, and while the public comment period is not intended to be an invitation to ask for the regulations to be repealed, that really is what is needed. BY DEFINITION any biologist or high school student in California is breaking the law if they catch insects for scientific or educational purposes without having bought and received a CDFW collecting permit, which comes with a very hefty non-refundable price tag (i.e., if they reject your permit application, they keep 100 bucks of your money anyway).

https://www.wildlife.ca.gov/Licensing/Scientific-Collecting

(2) The appended letter by Phil Ward gets to EXACTLY the main problem, which is worth emphasizing and focusing on: regulations for Threatened & Endangered (T&E) wildlife are absolutely fine, and we should all be willing to comply, but imposing effectively the same level of restrictions on the collecting of arthropods which are *not* T&E taxa is incredibly harmful to both science and education.

(3) note that the agency is California Department of Fish and Wildlife, and NOT "Fish and Game", so don't make that mistake when submitting comments.

For those of you not in California, note that Washington, Kansas, Wyoming, and other states have laws that are similar, if not worse. Hopefully this thread will not degenerate into a massive gripe session; the point is that we do have at least this one present case where public comments might be helpful.

Peace,

--
Doug Yanega

 
What are the laws for Kansas?
What are the laws for Kansas?

 
confused
Doug's comment #1 makes it seem like the law changes are already in effect. Looking at your link https://www.wildlife.ca.gov/Licensing/Scientific-Collecting makes it seem that these are still proposed changes open for comment by May 8.

Hah you can create as much road kill as you want with your ORV, just don't clean up after yourself or you'll get into trouble. ;-)

Does this matter?
I was unable to find a law or regulation that would prohibit me from collecting invertebrates that are not listed as threatened or endangered. If I were to collect, for example, a house fly without a permit, what would I be charged with?

 
better
hide your bug zappers! thats probably felony territory!

 
I don't live in or near Calif
I don't live in or near California, and I'm not at all an expert on California law, but as I read the proposed revised version of Title 14 section 650 (PDF below), it does seem to prohibit the non-permitted taking of invertebrates for scientific, educational or propagation purposes, without any exception for non-threatened, non-endangered species or species on private property. I'd be interested to know if I'm missing something.

PDF of section 650 revision:
https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=141275&inline

 
A permit is required to take,
A permit is required to take, collect, capture, mark, or salvage, for scientific, educational, and non-commercial propagation purposes, mammals, birds and their nests and eggs, reptiles, amphibians, fishes, and invertebrates . These activities require a Scientific Collecting Permit (SCP), and you need to pay a fee for it. The take of some animals may also require a Memorandum of Understanding or other additional written authorization from CDFW.

The collection, possession, transplantation or propagation of rare, threatened or endangered plants or manipulation of their habitat requires a Rare, Threatened or Endangered Plant Collecting Permit or Plant Research Permit. These permits are free and are required for activities conducted on both private and public land.

so based on the information above, the permit is free to collect threatened or endangered species, but for everything else, you have to pay?? that seems a bit odd...or downright outlandish...

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