Ridgehiker Posted January 24, 2017 Share Posted January 24, 2017 10 minutes ago, Sagebrush Steve said: You might have missed it but I specifically said I didn't think BLM should administer the courses. They should be taught by museums, fossil clubs, or even be on-line. The only thing BLM would do is issue the license. As a similar example, the FAA charges only $5 for a drone license. You take the required training from a licensed training center. My proposed license should be similar. 8-12 hours was just a guess on my part. It might be a lot less. While I understand your point about how collecting is permitted in Alberta, we need to be realistic and propose solutions that actually have a chance of being accepted. However, I strongly encourage you to write up your comments and submit them. Feel free to refer to my submission and say you don't agree with it and recommend the Alberta model instead. I am under no illusion that mine is the perfect solution. I just want to see something enacted that is much less restrictive than the current proposal. Curious,. What is a licensed training centre? Is this a drone club that applies for teaching credentials? How are they initially certified? Link to comment Share on other sites More sharing options...
Sagebrush Steve Posted January 24, 2017 Share Posted January 24, 2017 1 hour ago, Canadawest said: Curious,. What is a licensed training centre? Is this a drone club that applies for teaching credentials? How are they initially certified? I don't fly drones so I don't have a lot of first-hand experience. Do a Google search on "Drone Licenses." But don't take the analogy too literally. Fossil hunters are unlikely to accidentally bring down an aircraft if they don't know what they are doing. I just wanted to point out there are other areas where this kind of public-private training/licensing partnership already exists. For fossil hunters, the training could be as simple as watching some YouTube videos. The videos could be produced by a university's paleontology department under a grant from the National Science Foundation. The grant could also include responsibility to develop and disseminate other kinds of training materials that could be used by fossil clubs, museums, etc. That's just an idea, there may be better ones. The point is that I think the idea of having a way to train amateurs will help loosen the BLM's rule. It may also help convince the vertebrate community that it is OK to have more liberal rules for hunting invertebrate fossils than for vertebrates. Any universities out there that would be interested in leading this kind of activity? Link to comment Share on other sites More sharing options...
Sagebrush Steve Posted January 30, 2017 Share Posted January 30, 2017 No new public comments have been posted on the regulation's website for a week. The number of comments submitted continues to grow, it now says that 230 comments have been submitted, but the number that you can actually view has been stuck at 194. The web page does say that all comments must be reviewed by staff before they are posted. Anyone know what is going on? Has the staff member who reviews them been out sick or is this fallout from Trump's order to restrict government employees from posting on government websites? Of the 194 comments you can read, all but about 3 or 4 express strong reservations about the proposed rule. Link to comment Share on other sites More sharing options...
Olenoides Posted January 30, 2017 Share Posted January 30, 2017 4 minutes ago, Sagebrush Steve said: No new public comments have been posted on the regulation's website for a week. The number of comments submitted continues to grow, it now says that 230 comments have been submitted, but the number that you can actually view has been stuck at 194. The web page does say that all comments must be reviewed by staff before they are posted. Anyone know what is going on? Has the staff member who reviews them been out sick or is this fallout from Trump's order to restrict government employees from posting on government websites? Of the 194 comments you can read, all but about 3 or 4 express strong reservations about the proposed rule. I highly suspect the lack of reviewed comments in nearly a week, has to do with the departments dealing with internal changes. In particular there are mandates around reviewing and axing as many new regulations as possible. I've got to imagine there is some disarray on how to proceed right now. Link to comment Share on other sites More sharing options...
FossilDAWG Posted January 30, 2017 Share Posted January 30, 2017 I suspect Olenoides is correct. It may take some time before the process resumes, especially considering the "axe 2 regulations for every new one enacted" executive order. Nevertheless it would not be wise to presume the comments period will be extended, so go ahead and submit comments now. Don Link to comment Share on other sites More sharing options...
Olenoides Posted January 30, 2017 Share Posted January 30, 2017 13 minutes ago, FossilDAWG said: I suspect Olenoides is correct. It may take some time before the process resumes, especially considering the "axe 2 regulations for every new one enacted" executive order. Nevertheless it would not be wise to presume the comments period will be extended, so go ahead and submit comments now. Don Yes, I doubt the comment period will be extending. But with the increased oversight and new administration I think the comments will be much more effective. Previously they were pretty good at ignoring them, but I think they will get a lot more scrutiny now. Link to comment Share on other sites More sharing options...
Sagebrush Steve Posted January 30, 2017 Share Posted January 30, 2017 14 minutes ago, Olenoides said: Yes, I doubt the comment period will be extending. But with the increased oversight and new administration I think the comments will be much more effective. Previously they were pretty good at ignoring them, but I think they will get a lot more scrutiny now. I agree. And if the proposed rule does not get enacted, I assume the current law is more liberal and will allow amateurs more freedom to collect. Is that true? Link to comment Share on other sites More sharing options...
FossilDAWG Posted January 30, 2017 Share Posted January 30, 2017 Olenoides, I hope you are correct, but although the heads at the top may change the bureaucracy will remain. At the end of the day it may be a case of "meet the new boss, same as the old boss". Don Link to comment Share on other sites More sharing options...
Sagebrush Steve Posted January 31, 2017 Share Posted January 31, 2017 If you want to get their attention someone should point out how the proposed rule will hurt American small business and help China. It will hurt small businesses that collect fossils to sell and make a profit and will help China because If we can't collect and sell American fossils we will have to import more Chinese fakes. That will keep thousands of people employed there. If Trump hears about this he will nix the rule immediately Link to comment Share on other sites More sharing options...
Pemphix Posted January 31, 2017 Share Posted January 31, 2017 Discussion on german websites turns into the same direction as the government was set up a similar law in germany. In fact, all interested (hobby and professional) parties (paleontologist, archeologist, Museums, collectors,..) used the possibilities to discuss the draft-paper with government and politics. At least, the law has been set alive - but with less impact for each and more effect in the way/sense it was created. In my opinion it was helpful to use the possibilities - maybe it will help here, too ? Best regards, Pemphix Link to comment Share on other sites More sharing options...
jpc Posted January 31, 2017 Share Posted January 31, 2017 I just posted comment No 237, but indeed, the comments are still stuck at 194. Here is what I had to say. PRPA 2017 comments.pdf Link to comment Share on other sites More sharing options...
Sagebrush Steve Posted January 31, 2017 Share Posted January 31, 2017 2 hours ago, jpc said: I just posted comment No 237, but indeed, the comments are still stuck at 194. Here is what I had to say. PRPA 2017 comments.pdf Excellent comments, JP. Question: you say you don't have the time to check out all the reports of something interesting. I am sure you are not the only museum with that problem. If there were a licensing system in place that included training of amateurs on how to collect fossils and you had access to the list of trained individuals, do you think they might be resources you could call on to help check things out when a report comes in? Link to comment Share on other sites More sharing options...
jpc Posted February 1, 2017 Share Posted February 1, 2017 20 hours ago, Sagebrush Steve said: Excellent comments, JP. Question: you say you don't have the time to check out all the reports of something interesting. I am sure you are not the only museum with that problem. If there were a licensing system in place that included training of amateurs on how to collect fossils and you had access to the list of trained individuals, do you think they might be resources you could call on to help check things out when a report comes in? Yeah, something like that... an army of potential volunteers. Link to comment Share on other sites More sharing options...
TNCollector Posted February 1, 2017 Share Posted February 1, 2017 The craziest rule in my opinion is the 100lb limit per year. Just one single cubic foot of limestone weighs approximately 150 lbs on average... Link to comment Share on other sites More sharing options...
danthefossilman Posted February 4, 2017 Share Posted February 4, 2017 I posted a "public comment" in response to NEW proposed fossil collecting rules and regulations on BLM land. My problem, is I DONT UNDERSTAND what the terminology means: "casual collecting" (hiking and you accidently trip on a fossil?) "reasonable amount" (1, 2, 3 pieces, 1 pound or 100 pounds?) "common invertebrate species" (who decides what is common or less common?) And finally, if the BLM has rights of area closures "at will" how in the heck do you know (at any given time) what areas are "legally" open? Best, Dan The Fossil Man Link to comment Share on other sites More sharing options...
deutscheben Posted February 5, 2017 Share Posted February 5, 2017 On 1/30/2017 at 3:31 PM, Sagebrush Steve said: I agree. And if the proposed rule does not get enacted, I assume the current law is more liberal and will allow amateurs more freedom to collect. Is that true? Not really. The regulation up for comment here is actually going to tell the agency how to implement and interpret the current law, which was passed in 2009. The law says that the agencies must allow "casual collecting" of "common plants and invertebrates", so they need this regulation to define what exactly those vague terms (and many more) from the law mean. Some kind of regulation will be going into place, probably largely similar to what is up for comment, but hopefully the BLM will clear up some of the contradictory and illogical restrictions people are pointing out in their comments. Link to comment Share on other sites More sharing options...
FossilDAWG Posted February 7, 2017 Share Posted February 7, 2017 On 2/4/2017 at 11:07 AM, danthefossilman said: I posted a "public comment" in response to NEW proposed fossil collecting rules and regulations on BLM land. My problem, is I DONT UNDERSTAND what the terminology means: "casual collecting" (hiking and you accidently trip on a fossil?) "reasonable amount" (1, 2, 3 pieces, 1 pound or 100 pounds?) "common invertebrate species" (who decides what is common or less common?) And finally, if the BLM has rights of area closures "at will" how in the heck do you know (at any given time) what areas are "legally" open? Best, Dan The Fossil Man You have to read a lot of "legalese" to get to the proposed definitions, but: "reasonable amount" is defined as 25 lbs/day (maximum 100 lbs/year) of common invertebrate or plant fossils. The weight includes matrix of course. "casual collecting" is defined as collecting within the "reasonable amount" limits, as long as it is for personal use and not for sale, education, or research. Collecting for teaching or research will require a permit. "common invertebrate species": this is a problem as it is not defined (or definable). Supposedly there is/will be a list of species you can/cannot collect eventually but this is very unclear. To find out if a site is open/closed you will have to check with the local BLM office. I wonder how you were able to comment on the proposed rules if you did not know what the proposed rules are? Don Link to comment Share on other sites More sharing options...
jpc Posted February 7, 2017 Share Posted February 7, 2017 OK.. so the deadline for comments has passed... what now? Link to comment Share on other sites More sharing options...
FossilDAWG Posted February 7, 2017 Share Posted February 7, 2017 We get to wait. Eventually a response will be posted to the comments (not to each one individually, but to any issues raised), and a final rule will be announced. It may take a long time, especially considering the current hold on new regulations. I don't recall how long it took for the Forest Service process, but it was several months at least. In the case of the Forest Service, I don't recall that the comments resulted in any change to the proposed rules. I hope it is different this time. Don Link to comment Share on other sites More sharing options...
danthefossilman Posted February 18, 2017 Share Posted February 18, 2017 Anyone have a scale that accurately measures 25 lbs? I guess 25 lbs. is better than 2 quarts. There will be a lot of "chipping" as fossils become reduced in weight in field. Too bad we cannot subtract the matrix. Is the matrix really a fossil or maybe we can? Good thing the proposed guideline (rule) changes are not in effect yet... The bureaus considered defining ‘‘reasonable amount’’ as equaling two quarts instead of 25 pounds, but decided that the use of a weight limit, rather than a size limit, is more consistent with existing collection standards that are already understood. Link to comment Share on other sites More sharing options...
Sagebrush Steve Posted February 18, 2017 Share Posted February 18, 2017 1 hour ago, danthefossilman said: Anyone have a scale that accurately measures 25 lbs? I guess 25 lbs. is better than 2 quarts. There will be a lot of "chipping" as fossils become reduced in weight in field. Too bad we cannot subtract the matrix. Is the matrix really a fossil or maybe we can? Good thing the proposed guideline (rule) changes are not in effect yet... The bureaus considered defining ‘‘reasonable amount’’ as equaling two quarts instead of 25 pounds, but decided that the use of a weight limit, rather than a size limit, is more consistent with existing collection standards that are already understood. Well, in my submission to them I recommended that the 25 pounds be defined as only the fossiliferous material not including the matrix. I also proposed a quick way to estimate the weight of the fossils that could be performed in the field. So at least that idea has been put forth. But even that may be considered to be too much math for collectors or officers in the field. Other submissions have recommended increasing the daily limit to 250 lbs, which would be equivalent to saying the fossils typically comprise 10% of the total. That might be a more practical approach. Link to comment Share on other sites More sharing options...
Sagebrush Steve Posted February 18, 2017 Share Posted February 18, 2017 And per Trump's executive order I am waiting to see which two rules they remove in order to be able to issue the new one... Link to comment Share on other sites More sharing options...
danthefossilman Posted March 1, 2017 Share Posted March 1, 2017 Hope someone figures it out sooner than later. Can't imagine having a obtuse discussion in the field while collecting fossils with a BLM rep. I wonder how long "I didn't know" or "I wasn't clear" will work if the rules do not become clarified? Link to comment Share on other sites More sharing options...
Sagebrush Steve Posted March 1, 2017 Share Posted March 1, 2017 1 hour ago, danthefossilman said: Hope someone figures it out sooner than later. Can't imagine having a obtuse discussion in the field while collecting fossils with a BLM rep. I wonder how long "I didn't know" or "I wasn't clear" will work if the rules do not become clarified? Well, if I were questioned, I would show them this BLM memo from 2009 regarding the PRPA description of casual collecting: https://www.blm.gov/style/medialib/blm/ut/natural_resources/cultural/paleo/Paleontology_Documents.Par.59216.File.dat/IM2009-113 Casual Collecting of Common Invertebrate and Plant Paleontological Resources under the PRPA.pdf I would point out the following sentences in this document: "Title VI, Subtitle D, does not change the Bureau of Land Management’s (BLM’s) basic policy for allowing casual collecting of reasonable amounts of common invertebrate and plant fossils from public lands for personal use without a permit. The PRPA requires that the Secretary develop regulations implementing the legislation. These regulations will likely include definitions of certain commonly used terms." Then I would ask them to show me the definitions of commonly used terms. When they can't produce it, I would say that until they come up with the terms, I have defined myself as a casual collector and will continue collecting because "casual collecting" is allowed. When they throw me in jail I will post to this forum asking for you all to bail me out. Link to comment Share on other sites More sharing options...
aerogrower Posted March 1, 2017 Share Posted March 1, 2017 2 hours ago, Sagebrush Steve said: When they throw me in jail I will post to this forum asking for you all to bail me out. Link to comment Share on other sites More sharing options...
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