Protesting Proposed Regs
09-Apr-94 19:05:57
Sb: #127580-Protesting Proposed Regs
Fm: Doug Mitchell 70621,702
To: Nathan A. Schachtman 75010,61
Hi, Nathan–
The new USFS chief (assuming the same address as was given for the previous
one) is:
Jack Ward Thomas Chief (5300), Forest Service, USDA, P.O. Box 95090,
Washington, DC 20090-6090
Other than him, any and all Congressmen should hear about the proposed
regulations that could stop all mineral collecting on vast lands, I figure.
I wonder which has the most weight to an official receiving many letters: many
copies of one particularly well-thought letter, or a lot of different letters
all expressing the same concern about the regs?
Anyway, for a starting point, here is what I have sent; any and all are invited
to quote from or paraphrase it in writing the officials yourselves. Did I miss
anything? I cribbed the NAS stuff from an ALAA newsletter.
–Doug
Dear Chief Ward:
I am upset by and opposed to the regulations of mineral and fossil collecting
on U.S. Forest Service lands proposed in the Federal Register (Vol. 59, No.
32, pp. 7880-7892, Feb. 16, 1994).
These rules would effectively ban mineral and invertebrate fossil collecting on
large amounts of land. There is no need for such a broad restriction, and it
will harm the causes of science and education.
While some specific sites and types of fossils may need protection, most types
of fossil and mineral specimens are effectively inexhaustible and will be
pulverized by the elements if not collected soon after they are exposed by the
elements. Their removal by any but the largest-scale commercial operations
rarely makes any significant change to the landscape.
Amateur collectors help scientists by rescuing specimens from destruction by
the elements, and often bring the more interesting ones to the attention of
scientists. Paleontology, mineralogy and related sciences owe a great many of
their discoveries to this unpaid army of finders and sorters. This army will
shrink, and become less able to recognize the scientifically valuable finds, if
too many collecting sites are taken from us.
Amateur collectors often are happy to make their expertise and collections
available to children, schools and anyone interested in learning about them.
There will be fewer and poorer collections to show, and much less opportunity
to obtain expertise, if too many restrictions are imposed on us.
While commercial collectors may sometimes cause noticeable damage to public
lands and sites of scientific interest, please remember that they make
specimens available to those unable to collect (the aged, the infirm, those far
from collecting sites, those who do not know where and what to look for). They
made it possible for my grandfather to buy me a collection of minerals when I
was young (he knew little about minerals himself), an important starting point
in my lifelong interest in the sciences. That collection would have been more
expensive and contained less variety (perhaps causing him to choose something
else) if commercial collecting on public lands had been banned. Children learn
more from specimens they can own or at least handle daily than from those
behind glass in a museum visited maybe once a year. Push this matter too far,
and you may find paleontologists and mineralogists on the endangered species
list while depriving many children of something more worthwhile to do than
watch TV.
To require licenses be obtained is to hamper the collector and expend
government manhours. Without rules specifying that a license must be issued
under reasonable circumstances (and a clear definition of those circumstances)
and/or a mechanism for appealing denied licenses, collectors are left to the
whims of officials who may be overzealous about protecting the lands or
unwilling to take chances with a vague law. An overly aggressive licensing law
would sooner or later become as bad as a ban of collecting.
Attached you will find excerpts from a National Academy of Sciences report
concerning fossil collecting on public lands.
These proposed regulations require substantial revision. I strongly recommend
that non-commercial collecting be allowed to continue without licenses at
almost all locations on public lands (vertebrate fossils and perhaps other
special types excepted), and that reasonable conditions under which a license
must be issued for commercial or special site/type collecting should be set
forward.
Yours truly,
Doug Mitchell
cc: USFS Chief Thomas, Senator Boxer (CA), Senator Feinstein (CA), Rep. Cox
(CA), President Clinton
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