Over the last month, the Ornithological Council has provided three different sets of comments to federal agencies on permitting issues. Given that many of the ornithologists who are members of the organizations that make up the Ornithological Council must secure various permits from federal agencies either regularly or from time to time during their career, ensuring that the process of applying for, renewing, and amending these permits is efficient and predictable is of the utmost concern to the OC.
The OC provided comments to the USDA Animal and Plants Health Inspection Service on their import/export permits. Among other comments, the OC recommended that the permit duration be extended from one year to three years. The comments also recommended clarifying how disease categories apply and which countries can be included on blanket permits (i.e. permits that cover all imports and exports over the permit duration).
The OC also provided comments to the U.S. Fish and Wildlife Service on the Form 3-177 and the online eDecs system. Those comments asked that the USFWS add the capacity to upload bulk information on spreadsheets, rather than having to enter each specimen individually within eDecs. The OC also asked that the eDecs system more clearly indicated which permits are needed for each species.
Finally, the OC submitted brief comments on the USFWS Form 3–200–7 (application for a Migratory Bird and Eagle Scientific Collecting permit). The USFWS is proposing to add a question regarding whether institutional animal care and use committee (IACUC) approval is required for the work that a permit is being applied for. The OC comments note that a researcher might be applying for a scientific collecting permit before they apply for or secure approval from their institution’s IACUC, and so recommended adding an additional possible answer to the proposed question, which would allow the applicant to indicate that they have not yet applied for or secured IACUC approval but plan to do so before beginning their field work.