It's down to the wire. Comments on the DOI (BLM) proposed PRPA rules will only be accepted until Monday, February 6th, 2017.
Here are the issues in a nutshell:
1 "Casual collecting" is too restrictive
2 "Common" is not defined, and it should be noted that only scientifically valuable specimens are what PRPA intend should be in repositories, not specific taxa. All non-vertebrates s/b considered common until otherwise stated
3 "Reasonable amount" that can be casually collected is too restrictive
4 "Negligible disturbance" guidelines are too restrictive and should just be equated to "low impact" activity
5 "Research" should be allowed on casually collected specimens
6 There needs to be recourse for donating scientifically valuable specimens that were casually collected to repositories without repercussion - this includes vertebrate specimens accidentally collected in matrix, etc.
7 A permit should not be required for non-vertebrate research collecting, unless it exceeds casual collecting expanded parameters
8 Permitting requirements (especially for non-vertebrates) should be expanded to include the non-degreed avocational publishing community
9 A work-around should be figured out for random, incidental and/or co-mingled vertebrate specimens (like shark & fish teeth and vertebras) that are encountered while casually collecting non-vertebrate sites
10 A work-around should be figured out for places with a high proportion of redundant and/or unarticulated vertebrate bones and bone pieces that professional paleontologist have no interest in collecting so they can be salvaged by amateur/avocational collectors
11 DOI should partner with the amateur/avocational community to achieve their inventorying and monitoring goals. Partnering with the FOSSIL Project would be a good start
12 DOI should partner with the amateur/avocational community to achieve their outreach goals. Partnering with the FOSSIL Project would be a good start for this too.
13 Find a work-around for an easier mechanism for locality data to be published, at least for non-vertebrate sites
14 Vertebrates and non-vertebrates are not the same thing - not in scarcity, interest or economic value. Vertebrates require a much more sophisticated style and method of extraction, curation and preparation than do non-vertebrates. Please ensure all the rules reflect this.
If you haven't already, please pick a topic or two and write a comment about it.
Here is the website to post it to: Regulations.gov