Research Application Procedures and Requirements for Scientific Research and Collecting Permits

 

POLICY AND GENERAL REQUIREMENTS

The National Park Service (NPS) welcomes your interest in considering national parks for your research site. The NPS is responsible for protecting in perpetuity and regulating use of our National Park areas (parks, monuments, battlefields, seashores, recreation areas, etc.). Preserving park resources unimpaired and providing appropriate visitor uses of parks require a full understanding of park natural resource components, their interrelationships and processes, and visitor interests that can be obtained only by the long term accumulation and analysis of information produced by science. The NPS has a research mandate to provide management with that understanding, using the highest quality science and information. Superintendents increasingly recognize that timely and reliable scientific information is essential for sound decisions and interpretive programming. NPS welcomes proposals for scientific studies designed to increase understanding of the human and ecological processes and resources in parks and proposals that seek to use the unique values of parks to develop scientific understanding for public benefit.

When is a permit required?

A Scientific Research and Collecting Permit is required for most scientific activities pertaining to natural resources or social science studies in National Park System areas that involve fieldwork, specimen collection, and/or have the potential to disturb resources or visitors. When permits are required for scientific activities pertaining solely to cultural resources, including archeology, ethnography, history, cultural museum objects, cultural landscapes, and historic and prehistoric structures, other permit procedures apply. The park's Research and Collecting Permit Office or Headquarters can provide copies of NPS research-related permit applications and information regarding other permits. Federally funded collection of information from the public, such as when formal surveys are used, may require approval from the Office of Management and Budget.

NPS superintendents may authorize their staff to carry out official duties without requiring an NPS research and collecting permit. NPS staff must comply appropriately with professional standards and with all conditions normally associated with scientific research and collecting permits issued by the park. All other natural and social science research and data collection in a park requires a Scientific Research and Collecting Permit and will be allowed only pursuant to the terms and conditions of the permit.

Additional required permits, approvals, and agreements

In some cases, other federal or state agency permits or approvals may be required before staff can process an application for a Scientific Research and Collecting Permit. Examples include U.S. Fish and Wildlife Service threatened and endangered species permits and migratory bird permits and approvals by an Institutional Animal Care and Use Committee. It is the responsibility of the principal investigator to provide NPS with copies of such permits when they submit an application. Applicants are encouraged to contact park staff to determine if additional permits may be required in conjunction with a proposed study.

Separate agreements between the investigator and NPS are required when proposed studies or collected specimens are intended to support commercial research activities.

Who may apply?

Any individual may apply if he/she has qualifications and experience to conduct scientific studies or represents a reputable scientific or educational institution or a federal, tribal, or state agency.

When to apply?

We recommend that you apply at least 90 days in advance of your first planned field activities. Projects requiring access to restricted locations or proposing activities with sensitive resources, such as endangered species or cultural sites, usually require extensive review and can require 90 days or longer for a permitting decision. Simple applications can often be approved more quickly.

How and where to apply?

An individual may obtain application materials via the Internet (find “Research Permit and Reporting System” at http://science.nature.nps.gov/research or through www.nps.gov) or by contacting the park in which the work will be conducted. Addresses for NPS areas are listed on the NPS Internet web site (www.nps.gov) or may be obtained by contacting the NPS Public Affairs Office via telephone number 202-208-4747. All application materials must be submitted to the NPS area in which you plan to work. You may submit this information via Internet or traditional postal service.

Study proposals

Applications for Research and Collecting Permits must include a research proposal. Proposals must include, as appropriate, all elements outlined in the separate document Guidelines to Researchers for Study Proposals.

Review of proposals

Each proposal will be reviewed for compliance with National Environmental Policy Act (NEPA) requirements and other laws, regulations, and policies. The superintendent may also require internal and/or external scientific review, depending on the complexity and sensitivity of the work being proposed and other factors. You can expedite review of your proposal by providing photocopies of existing peer reviews, or by providing names, mailing addresses, and email addresses of persons that you wish to recommend to review your proposal. Specific details about the review process may be included with the application materials provided by that park.

Facilitating a favorable decision

The superintendent makes a decision to approve a research and collecting permit based on an evaluation of favorable and unfavorable factors (see examples, below), and on an assessment of perceived risks and benefits. While park managers will work with applicants to arrive at a mutually acceptable research design, there may be activities where no acceptable mitigating measures are possible and the application may be denied.

The time and effort required to review the permit application and accompanying study proposal will be proportional to the type and magnitude of the proposed research. For example, a single visit for a non-manipulative research project will often require a relatively simple proposal and the permitting decision should be relatively fast. A highly manipulative or intrusive investigation, however, with the potential to affect non-renewable, rare, or delicate resources, needing detailed planning or logistics, would receive more extensive review. Some of the predisposing factors that influence permitting decisions are outlined below.

Favorable factors

The proposed research:

• contributes information useful to an increased understanding of park resources, and thereby contributes to effective management and/or interpretation of park resources; provides for scheduled sharing of information with park staff, including any manuscripts, publications, maps, databases, etc., which the researcher is willing to share;
• addresses problems or questions of importance to science or society and shows promise of making an important contribution to humankind’s knowledge of the subject matter;
• involves a principal investigator and support team with a record of accomplishments in the proposed field of investigation and with a demonstrated ability to work cooperatively and safely, and to accomplish the desired tasks within a reasonable time frame;
• provides for the investigator(s) to prepare occasional summaries of findings for public use, such as seminars and brochures;
• minimizes disruption to the park’s natural and cultural resources, to park operations, and to visitors;
• discusses plans for the cataloging and care of collected specimens;
• clearly anticipates logistical needs and provides detail about provisions for meeting those needs; and
• is supported academically and financially, making it highly likely that all fieldwork, analyses, and reporting will be completed within a reasonable time frame.

Unfavorable factors

The proposed research:

• involves activities that adversely affect the experiences of park visitors;
• shows potential for adverse impact on the park’s natural, cultural, or scenic resources, and particularly to non-renewable resources such as archeological and fossil sites or special-status species (the entire range of adverse impacts that will be considered also includes construction and support activities, trash disposal, trail conditions, and mechanized equipment use in sensitive areas);
• shows potential for creating high risk of hazard to the researchers, other park visitors, or environments adjacent to the park;
• involves extensive collecting of natural materials or unnecessary replication of existing voucher collections; requires substantial logistical, administrative, curatorial, or project monitoring support by park staff; or provides insufficient lead time to allow necessary review and consultation;
• is to be conducted by a principal investigator lacking scientific institutional affiliation and/or recognized experience conducting scientific research; and
• lacks adequate scientific detail and justification to support the study objectives and methods.

Park Response

The principal investigator should receive notice of the approval or rejection of the application by written correspondence via mail, electronic mail, or facsimile. If modifications or changes in a study proposal initially deemed unacceptable would make the proposal acceptable, the park may suggest them at this time. If the application is rejected, the applicant may consult with the appropriate NPS Regional Science Advisor to clarify issues and assess the potential for reconsideration by the park.

Permittee response

If your permit request is approved by the park, you will receive a copy of the permit that you must sign and return to the park via mail or fax. Once the park receives a copy of the permit that you have signed, appropriate NPS officials will validate it and return an approved copy to you. You must carry a copy of the approved permit at all times while performing your research or collecting in the park.

Permit stipulations

General Conditions (requirements and restrictions) will be attached to all Research and Collecting Permits issued. These conditions must be adhered to by permit recipients. Additional Park-specific Conditions may also be included that address unique park resources or activities. An NPS permit is valid only for the activities authorized in the permit. The principal investigator must notify the NPS in writing of any proposed changes. Requests for significant changes may necessitate re-evaluation of the permit conditions or development of a revised proposal.

Access permit requirements

Some NPS areas require access permits for off-road travel, camping, and other activities. Access to many areas is limited and popular destinations can be booked several months in advance. Please contact the park’s Research and Collecting Permit Office to obtain information on any needed access permits.

Research products and deliverables

Researchers working in NPS areas are required to complete an NPS Investigator’s Annual Report form for each year of the permit, including the final year. The NPS maintains a system enabling researchers to use the Internet to complete and submit the Investigator’s Annual Report. NPS staff will contact permit holders near the beginning of each calendar year to request the prior year’s report and explain how to access and use the system. Investigator’s Annual Reports are used to consistently document accomplishments of research conducted in parks. Principal investigators are responsible for the content of their reports. NPS staff will not modify reports received unless requested to do so by the principal investigator responsible for the report.

Park research coordinators may request copies of field notes, data, reports, publications and/or other materials resulting from studies conducted in NPS areas. Additional deliverables may be required of studies involving NPS funding or participation.

Privacy Act and Paperwork Reduction Act

NPS regulations (36 CFR 2.1) prohibit possessing, destroying, injuring, defacing, removing, digging, or disturbing from their natural state in any form animals, plants, paleontological, or mineral resources. NPS regulations (36 CFR 2.5) require researchers wishing to conduct research involving acts prohibited by other regulations, such as CFR 2.1, to obtain a specimen collection permit. The National Parks Omnibus Management Act of 1998 (Public Law 105-391) encourages use of parks for science, encourages publication of the results of research conducted in parks, and requires that research conducted in parks be consistent with park laws and management policies. This law also requires that research be conducted in a manner that poses no threat to park resources or public enjoyment. National Park Service Management Policies state that research activities that might disturb resources or visitors, that require the waiver of any regulation, or that involve the collection of specimens may be allowed only pursuant to terms and conditions of an appropriate permit.

The information you submit in your Application for a Scientific Research and Collecting Permit will be used by park managers to determine whether or not to issue you a Scientific Research and Collecting Permit. The information you submit in your Investigator's Annual Report will be used by park managers to inform resource management decision-makers, park visitors, the public, and other researchers about the objectives and progress results of your research.

Parks and park records are public assets. The information you submit in your Application and in your Investigator’s Annual Report is not confidential and will be in the public record and available to the public. If you want to receive and maintain a Scientific Research and Collecting Permit, you must respond to both the Application and Investigator’s Annual Report collections of information. If you do not respond to the request for information in the Application, you will not be considered for a Scientific Research and Collecting Permit. If you have received a Scientific Research and Collecting Permit and do not respond to the request for information in the Investigator's Annual Report, your permit may be revoked and you may be denied future permits.

The Application for a Scientific Research and Collecting Permit and the Investigator’s Annual Report are two parts of one complete process dealing with conducting scientific research and collecting in a unit of the National Park System. The total public reporting burden involved in electronically completing the collection of information process for a single scientific research and collecting activity in a unit of the National Park System includes the burden of reading the informational documents associated with these two information collection forms plus completing and submitting one Application form (approximately 45 minutes), plus the burden of signing and mailing an issued permit back to the park (approximately 15 minutes), plus the burden of completing one associated Investigator's Annual Report form (approximately 15 minutes). Some applicants will experience an additional burden of photocopying and mailing attachments (approximately 15 minutes). Other applicants will experience an additional burden of coordinating with a specimen repository (approximately 30 minutes). The total public reporting burden experienced by a successful permittee for electronically completing this process for a single scientific research and collecting activity in a unit of the National Park System thus is estimated to range between 1.25 and 2.0 hours per year. The total public reporting burden experienced by an unsuccessful applicant for electronically completing this process is estimated to be about 45 minutes per year because the unsuccessful applicant will not be required to complete the Investigator’s Annual Report, mail a signed permit, or respond to other portions of the process. The few applicants who complete these forms manually are expected to experience a somewhat larger annual reporting burden. Direct any comments you may have regarding this burden estimate or any other aspect of this information collection process or of its two forms to the Office of Information and Regulatory Affairs of OMB, Attention Desk Officer for the Interior Department, Office of Management and Budget, Washington, DC 20503; and to the Information Collection Clearance Officer, WASO Administrative Program Center, National Park Service, 1849 C Street, N.W., Washington, DC 20240.