Biodiversity scientists from across California gathered today on Zoom to field suggestions for the California Department of Fish and Wildlife’s (CDFW) Scientific Collecting Permit (SCP) application process. SCPs in California are required for “the take or possession of wildlife, including mammals, birds and the nests and eggs thereof, reptiles, amphibians, fish, certain plants and invertebrates for scientific, educational, and propagation purposes.” Since 2018, applications for an SCP can be done online through a special portal. However, the application process has been plagued by long delays and confusing language, with The Wildlife Society reporting that permit renewals are often only available after negotiation with CDFW staff as direct emails.
The SCP Town Hall, as it was called, was held at the behest of CDFW as an expansion upon two earlier meetings held privately between it and several museums and universities, and was moderated by Shannon Bennett of the California Academy of Sciences, Michelle Koo of the Museum of Vertebrate Zoology, UC Berkeley, and Trina Roberts of the Natural History Museum of Los Angeles County (NHMLA). Attendees included researchers from across California, museum staff, business owners, and California conservation organizations. No CDFW staff were present, though Bennett said that notes from the meeting would be shared with CDFW afterwards.
I had the opportunity to sit in on the event, which was divided into three break-out rooms (covering the permit application process itself, the online application portal, and museum’s unique role in research involving SCPs) to take notes on the key take-aways. All notes and quotes are here taken from the general discussion, from the permit application process break-out room moderated by Trina Roberts, and from supporting documents provided during the event.
This post will be updated as further information becomes available.
One of the most significant pieces of information, shared by Bennett, is that CDFW intends to revamp the application portal over the summer to correct issues raised during the town hall. Some of these issues were cosmetic, such as providing a progress bar on the application, while others dealt with application-breaking errors. The inability to change email addresses associated with an account, application fields being impossible to edit if a mistake is made, and the current need for IT intervention to reopen a permit application to correct errors or make requested amendments were major concerns raised throughout the meeting.
Carla Cicero of the Museum of Vertebrate Zoology, UC Berkeley, and several others also noted how the current application process requires the manual input of a single species at a time across multiple parts of an application. They recommended that there should be an option to upload an entire list of species that is checked against a database, which will then autofill all other places in the application where that information is required.
An overall criticism of CDFW was the general lack of transparency on how permits are processed or what application statuses mean. Several participants pointed out a lack of clarity on how specific taxonomy (species lists vs. encompassing taxons) needed to be for a permit to be approved and questioned whether this could be contributing to wait times that in some cases extend for over four years. One suggestion was to include an easily-accessible dashboard in the portal where all applications could be tracked, errors and emendations fixed/identified, and a place where requests for more information from CDFW officials could be responded to directly.
While specific details on the new portal’s development, what issues it would address first, or when it would be available were not provided, Bennett stated that CDFW intends to open the portal up to user testing before it is presumably made available to everyone. Bennett, speaking later about partnering with CDFW, said, “There is a lot of interest in sort of helping them help themselves by having some really clear policies…[and] we should move forward together to help everybody out, including the state, and we feel like that relationship should be seen in the solutions that we all come up with.”
Another significant criticism of the current SCP system is that it requires everyone interested in collecting or exhibiting protected species to get an SCP, including reptile removal companies, educators, and researchers. Jacob Molieri of SnakeOut pointed out how snake-removal companies are required to get SCPs to remove and release snakes from private property, flooding the portal with hundreds of applications. Trina Roberts summarized the problem, stating that “…those [applications] are all getting funneled into the same permit portal and permit process that’s slowing everything down and frustrating everybody. So maybe CDFW could think about these stakeholder groups and whether the steps have to be the same and whether there are more simplified processes for some of you.”
Brad Shaffer of UCLA also pointed out how the current wait time for SCPs may be negatively impacting professors ability to teach biodiversity in the field. Shaffer suggested perhaps one of the most large-scale changes to the current permitting system, which was to institute place-based SCPs that could be overseen by the administrators of special sites. Shaffer suggested that certain reserves in the University of California Natural Reserve System, or potentially the entire reserve system, could be overseen by a single SCP held by the UCs, thus removing the administrative burden of approving multiple SCPs for each site from CDFW entirely.
The CDFW’s handling of SCPs for insect research drew special attention. Leslie McGinnis, formerly of UC Berkeley, pointed out how many lists for insect Species of Special Concern (SSC) in California were outdated and filled with broken links. Austin Baker of NHMLA shared of the difficulties of conducting insect biodiversity surveys for unregulated species when SCPs are required in case of an encounter with a regulated one. Baker said that, “After collecting a million specimens and DNA sequencing them, I can say that we have, in bycatch, collected one individual of one species on their [CDFW’s] list of invertebrates of conservation concern. So the risk is so negligible as to be kind of ridiculous to require us to get these permits for an insect diversity survey that’s not targeting any of those groups.”
Another point of contention, which Paul Rude of the Essig Museum of Entomology pointed out, was the need for submitting notifications of field activity that costed time and effort and yet seemed to never be reviewed. Rude stated that “I took the steps they required, you know, notified the supervisors of each district that I was going to such and such a park…[and later] I sent them a spreadsheet with, as well as I could determine, the things I collected. And of course, it goes into a black hole.” Baker further questioned CDFW’s apparent inability to process such data and the burden they placed on researchers, saying that “…why are these layers of bureaucracy…just slowing everything down when we could just sort of cut some of that out? It’s common sense kind of stuff.”
Lastly, the role of museums in research and collecting generated significant discussion, with problems such as the inability to know what data to share with CDFW and current restrictions on museums accepting salvaged specimens making it difficult for museums to navigate SCP requirements. Michelle Koo noted how the lack of transparency in what data CDFW needs from museums makes it difficult to know what to send them. CDFW currently appears to be saying “send us what you have,” which in the case of museums with very large amounts of data is not possible. Koo further stated that museums should be given both more autonomy and treated as a special kind of SCP holder, summarizing by saying that “We would request having museums treated…as a special kind of stakeholder, because we are definitely entities, organizations that are not going away. I mean, all of us have been around for…over a century now. And so, can we have some blanket permissions if a museum is applying for their state collecting permit?”
Additionally, it was noted how difficult it was to maintain a legal chain of custody as a museum under SCPs, especially for historical specimens, and it was suggested that museums should be made exempt from such stipulations. Chris Conroy of UC Berkeley and Dean Pentcheff of NHMLA suggested that all CDFW permit collection and location data should be made public to facilitate research and enable researchers coming from outside of California to coordinate with Californian institutions.
The town hall ended with a summary of all the break-out groups discussions. Andrea Williams of Williams Ecological Assessments and Planning (formerly of the California Native Plant Society) capped off the meeting by reiterating ways to help and where further information could be found (linked below). Williams also stated that there would be another private meeting with CDFW in early June to discuss the notes taken from the town hall, and hopefully continue to push forward the process of SCP application reform.
Further information can be found in the below files:
Summary of progress to date 2025/05
SCP Recommendations from biodiversity stakeholders
The California Fish and Wildlife Scientific Collecting Permit Process: Results of a survey on use and utility (from The Wildlife Society)
CDFW SCP staff response to input received from biodiversity science stakeholders
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