Remember the public commenting deadline for the proposed Paleontological Resources Preservation Act regulations is Feb 6th.  Please lease a comment on the regulations themselves to make your voice heard.  Below is an exceptional comment just posted on the regulations by Craig Stevenson. — RE: Federal Register Number 2016-29244 To Whom It May Concern: I wish to comment on the Department of the Interior’s proposed regulations for Bureau of Land Management’s (BLM) lands for the Paleontological Resources Preservation Act (PRPA) of…

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Here is another great comment on the proposed PRPA regulations that was written by Carlton Brett.  He is world renowned for his work in stratigraphy and invertebrate paleontology.  His comments focus on how the enormous, negative impacts these regulations would have on research and the relationship between amateur collectors and professional researchers.

Petrified wood represents a stone of unique interest in the hearts and minds of the many collectors found in virtually every part of the world. It is prized both as a gemstone by lapidary and jewelry artists, and as a fossil by amateurs and professionals alike. The most prized specimens are highly silicified and easily polished into magnificent display pieces. Many texts have been published for the petrified wood collecting community to celebrate the incredible diversity of both aesthetic beauty…

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This is part of a series of posts drilling into some of the most unworkable parts of the proposed regulations.  It seeks to demonstrate not just where the issues are, but also propose workable solutions. The actual law (Paleontological Resources Preservation Act) interpreted by the regulations provides a casual collection exception.  This exception allows amateurs to collect certain types of fossils without a permit.  This is how casual collecting is defined: 49.810 – Casual collecting means the collecting without a permit of a reasonable amount of common…

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Below is the text of an exceptionally well written comment to the regulations by Linda McCall, President of the North Carolina Fossil Club.  It may provide some inspiration and talking points for your own comments but  please do not resubmit as your own comment or copy & paste.  Remember we need as many constructive, public comments as possible, please post your own on the regulations.

Walter W. Stein PaleoAdventures January 17th, 2017 RE: The Paleontological Resources Preservation Act (PRPA) and the Proposed Rule “Paleontological Resources Preservation” for BLM, BOR,NPS, and FWS Dear committee members, government officials, members of the paleontological community and concerned citizens: I am writing to express my concerns regarding the new proposed rules for the management of paleontological resources on our shared federal lands. While I thank the scientific community and the various bureaus for their hard work, dedication and passion for…

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Note: The author of this article has chosen to remain anonymous because their job requires daily interactions with the BLM, Forest Service and other agencies involved. — Some of you may already know me. I am a citizen scientist. I have stacks of rocks and dirt in bins and bags. I geek out on crinoids. I love pulling my hand lens out to show someone the wonder of serrations. I have a rock hammer in every vehicle and shale chips…

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Language regarding “reasonable amount” is found in Supplementary Information and in the draft rule. The Supplementary Information section states (starting on page 88182): Proposed § 49.810(a)(2) would establish ‘‘reasonable amount’’ for casual collecting as 25 pounds per day per collector, not to exceed 100 pounds per year per collector. This proposed definition would also clarify that pooling of multiple daily amounts by one or more collectors to obtain pieces in excess of 25 pounds is not allowed. The bureaus determined that the 25 pounds…

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The law says casual collecting results “in only negligible disturbance to the Earth’s surface and other resources” and the term negligible disturbance “shall be determined by the Secretary.” The proposed rule imposes a one yard square limitation on ground disturbance citing a long standing practice of BLM which is arbitrary and has no foundation in regulation and is in fact contrary to existing regulations nor is it practical in the field where rocks don’t always come in one yard square blocks. Language regarding “negligible disturbance” is…

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​Things to consider when commenting on the rule The law uses the word “common” when it references what invertebrate and plant fossils can be casually collected. Common is a vague word and an unfortunate choice in light of the requirement (Executive Order (EO) 12866) for agencies to use scientific and technical information when writing regulations. Wording the regulation is further complicated by the requirement (EO12866) to write it in a simple and easy to understand manner. In the talking points below you will find the…

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