In official comments to the Department of the Interior, the Natural Science Collections Alliance recommended several revisions to the draft rule on paleontological resources preservation.
The proposed rule is intended to address the management, collection, and curation of paleontological resources from federal lands using scientific principles and expertise, including collection in accordance with permits; curation in an approved repository; and maintenance of confidentiality of specific locality data.
Among the concerns expressed are the proposed prohibition on disclosing information about the specific location of paleontological resources and the burdensome permitting process. Under the proposed rule, the National Park Service and other Interior Bureaus would have their own permit application forms. Moreover, although the Bureau of Land Management, the Bureau of Reclamation, and the Fish and Wildlife Service are all using DI Form 9002 (Paleontological Resource Use Permit Application), each bureau has its own instructions for how to complete each field on the form. The differences in the instructions are significant enough that an applicant would have to complete a new application for each permit they seek.
The letter also addresses the financial burdens faced by paleontological resources repositories. “The organizations that house paleontological resources bear a large financial burden in terms of storage, curation, and reporting requirements. Although many federal collections are curated by DOI, many others are located in non-governmental facilities, such as museums and universities. The federal government should do more to defray the associated costs of curation of federal paleontological resources. Ownership comes with financial responsibilities.”