Review of the West Dorset Fossil Code Responses to the Consultation March 2012

Review of the West Dorset fossil code Responses to the consultation March 2012

Background to the consultation NOTE: this may change with the revamp of the web site. Responses from the consultation These are the views received as part of the review of the West Dorset fossil collecting code in response to a consultation document We received 32 responses and of those: published in June 2011. The views have been considered by the Science and Conservation Advisory Group and Fossil Code Working Personal views: 15 Group on behalf of the Dorset and East Devon Coast World Heritage Organisational: 9 Site Steering Group. Consideration of the responses and the Academics: 13 consequent actions to improve the code are provided in a separate Geoconservation: 5 document. Landowners: 4 Collectors: 5 The consultation went out to: Others: 2

The Science and Conservation Advisory Network (31 individuals), NOTE: the totals do not add up as some people can respond Geological/Palaeontological socs/associations/societies (13), individually but be academic etc. museums curators (16), Geoconservation organisations (15), UK university Earth science departments (26), fossil collectors (30). We would like to thank all those who took the time to respond and hope that this document is both interesting and informative to those Articles about the review was publicised through: ProGEO newsletter, who read it. Geoconservation UK VOL2 NO3, BGS News, Dorset Coast Forum e- mail magazine, Shoreline (Charmouth community magazine) and Searching the consultation the Western Morning News. Presentations were made to the History Of Geology Group and the Society for Vertebrate Palaeontology & The responses are collated together under each of the questions Comparative Anatomy. asked and listed in the order that they were received so if you want to follow one response through the document, search using the The original consultation documents can be found on the Jurassic number and name with a full stop and space between them, e.g. 29. Coast web site at: http://www.jurassiccoast.com/299/managing-the- ISJS. Several responses did not follow the questionnaire and therefore site-37/whs-management-167/fossil-code-review-803.html these have been included at the back of the document.

1 Responses to the consultation, arranged question by question.

Name/organisation Response Clarifications view/interest Question 1. Overall are the priorities of the code correct or flawed? 1. Ben Brookes I feel that the current priorities of the code remain valid, though I might suggest the inclusion of a Personal priority to “collect data from such finds so as to extend the scientific use/value of the specimens Vert palaeo without requiring their sale or donation.” (see my response to Q6 below). 2. Nigel Trewin Your code seems to me to cover the special needs of the Dorset Coast very well. The fact that you have Aberdeen uni lists of collected material is excellent, some material will ‘escape’, but will not be destroyed by the sea. All interests In the long run it will be available to science. 3. Paul de la Salle I think the priorities are correct and the objectives remain valid. Personal Amateur 4. Dr Paul Barrett Overall, I think that the objectives of the code and clear and appropriate. It strikes a balance between Personal the needs of amateur, professional and academic collectors and is clearly aimed at conserving the site Vert palaeo and promoting education and research. 5. Mark Bradley Responses that lie outside the questionnaire and is included at the end of this paper Land manager Question. 1 I think the objectives and priorities are basically sound and remain valid. 6. Rob Coram Personal Invert palaeo Question. 1 The overall priorities are correct. The only thing certain about fossil collecting on the Jurassic Coast is 7. Chris Paul that if specimens are not collected they will be destroyed, usually quickly. Ones collected by private Personal individuals may eventually reach recognized museums. Therefore we should encourage collecting, but Strat & invert palaeo also encourage people to report what they find. Question. 1 Valid altogether very sensible and realistic 8. Alan Saxon Amateur collector Question. 1 Priorities correct. Important to keep the Code simple and accessible 9. Alan Lord Geol Soc of London

2 Stratigraphy Question. 1 VALID? Yes. NEED REVISION? No, NEED ADDITIONS? No 10. Tony Holmes Unknown Question. 1 The fundamental priorities of the Code appear to be little changed and remain valid. Health and Safety 11. Simon Ford issues may have come further to the fore. Land manager Question. 1 Responses that lie outside the questionnaire and is included at the end of this paper 12. Jurassic Coast Museum partnership Question. 1 As one of the steering group which produced the Scottish Fossil Code I am pleased to see that the 13. Bob Davidson objectives and priorities of your document is in close alignment with ours, and has established a working arrangement that is achieving the required goals. For this reason you have my support for the document as it stands. Question. 1 The West Dorset Fossil Collecting Code review document was discussed. It was felt that the existing 14. Kelvin Huff, code of conduct was working well and we saw no need to restrict collecting by enthusiasts and Dorset GAG amateurs. Secretary Question. 1 OUGS Wessex committee have looked at the proposals you sent and the consensus view of Open 15. Sheila Alderman University Geological Society Wessex Branch of which there are 200 members in Dorset, Hampshire, Wessex OUGS South Wiltshire and South Somerset is that the current code of conduct for fossilling is fit for purpose and we see no need to change it. Question. 1 Responses that lie outside the questionnaire and is included at the end of this paper 16. Claire James Estate manager Question. 1 I think the present scheme, with a few improvements, would work well, though I must admit that I’m 17. John Wright not up to date with problems in West Dorset, as I haven’t done any collecting there for some 20 years Personal now. Strat and invert palaeo Question. 1 Responses that lie outside the questionnaire and is included at the end of this paper 18. Dr Chris King Personal

3 Strat and invert Question. 1 Provided Bristol Museums, Galleries & Archives – Acquisition & Disposal Policy 2010. 19. Roger Vaughan Bristol City Museum & Art Gallery Question. 1 [Response partially corrupted] 20. Mike Simms I think the code works pretty well within the obvious constraints. I'm sure certain aspects might be improved but as a whole I would stick with what is already there. I certainly don't think that the scientific importance of the site is compromised by commercial collecting. I think it would help enormously if there was some world-class, purpose-built museum for the WHS. Sure, it would be expensive to build but could be a real money-spinner. Question. 1 Responses that lie outside the questionnaire and is included at the end of this paper 21. Ian West Question. 1 Responses that lie outside the questionnaire and is included at the end of this paper 22. Charmouth Parish Council Question. 1 Responses that lie outside the questionnaire and is included at the end of this paper 23. Mike Taylor Question. 1 Addition could be: 24. Tim Ewin 1 Important finds are recorded with as much detail as possible: Personal 2 There needs to be some form of control making it beneficial for collectors to record their findings as All interests currently I am aware that there are numerous incidences of where important specimens are not being recorded. Both these points are, I suppose, interlinked as collections go unrecorded owing to the fact that the fossils are fragmentary and collectors do not want others finding the locality from which they came. This is understandable but has resulted in specimens not being recorded. Perhaps there could be a scheme whereby specimens are recorded but the information is not made public for a number of weeks/months/years: 3 An important addition, I feel, is that important specimens should be made available to accredited UK museums. i.e. not only given the first opportunity but that the specimens should be available. This opens a can of worms, however the treasure act has been functioning effectively for a number of years now and provides the perfect model to which the fossil code could follow. This effectively provides a fair price to the collector (if they so desire remuneration) and ensures that the specimen is displayed and properly cared for all with the close collaboration with the original discoverer. To stop people simply not declaring their finds, it should be made illegal for them to offer for sale any unrecorded type

4 1 and 2 specimens without them first being offered to a museum (for sale). I think many museums could also offer a loan back service whereby if the collector wanted to hang onto the specimen then museums should be prepared to consider owning the specimen but loaning it back to the individual (ensuring suitable provision and training is provided for the specimen’s care). This would resolve many of the issues of people wanting to hang on to their prize specimen to show friends etc. but ensuring that the specimen is available for academic study and its long term fate is ensured. This however may result in museums having to change their loans policies and will involve greater demands on their resources. However, in my experience the collectors are as responsible with collections as academics studying them: 4 All specimens recorded on the list must have location details updated if they are exchanged by the initial collector (either swapped, donated or sold). This is imperative so that specimens can be tracked and not lost (does this not already happen?). Question. 1 Correct However they need to be continually reviewed to match changing circumstances and 25. David Ward experiences learned. Unclear Question. 1 The overall priorities of the code would appear to be correct. It appears the objectives are the best that 26. Colin may be achieved with the challenging and complex issues concerning collecting on the Dorset coast. MacFadyen Scottish Natural Heritage Geoconservation Question. 1 Responses that lie outside the questionnaire and is included at the end of this paper . 27. Neil Ellis JNCC Question. 1 Flawed. 28. Kevin Page “In an attempt to address certain concerns about the collection of palaeontological heritage from the area, especially the lack of recorded finds, a local collecting code and recording scheme was established by Dorset County Council in West Dorset in 1999 (Edmonds 2001). The code, however, effectively grants free licence to any collector to remove fossils from the World Heritage site - the only condition being that they report the finds that they (i.e. typically non palaeontologists) considered ‘significant’. The state would then be granted 6 months to raise sufficient monies to meet what would inevitably be an international market price, to secure the future of the specimen as a part of the national heritage. What makes this scenario even more remarkable is that the majority of the fossils effectively already belong to the state by virtue of land ownership by national conservation

5 organisations and that the entire area is also in theory protected by national conservation legislation. The problems associated with the code are compounded by the fact that guidelines are drawn to emphasise primarily vertebrate materials and effectively discard whole classes of other important fossils. Ammonites, in particular, the key stratigraphical tools for Jurassic marine sequences, are considered to be little more than “bread and butter” fossils for these collectors (i.e. providing a basic financial income) and generally not even worth recording in the scheme. The arguments to support this view are spurious and reflect the interests of collectors and not science (Page 2005b).” [Page 2006, ISJS Newsletter] Page cont…… “Analysis of the register of finds provides an indication of the level of this loss, when compared to Correction: Between the end of scientifically gathered records from an adjacent road scheme. These figures indicate that over 1300 2002 up to 2005 there were 20 specimens of particular scientific note should have been recorded from the World Heritage site over records, three of which were the period 1999-2002. The actual figure reported of only 36 specimens over the period, even allowing insects, one of those being a for a few unrecorded academic studies, demonstrates that the code has delivered little scientific collection of 34 specimens. Of those three records, 2 have been benefit. Even with figures up to 2005, only around 40 specimens more are recorded, around 30 of donated to the Natural History which are small insect fragments, most of which are likely to have been discarded as larger fossils Museum; a total of 35 out of 36 were prepared in local workshops (Page 2005, 2006).” [Page and Wimbledon 2009 – see references specimens, at least one of which is below]. considered to be a new species. Results to 2011 as published in the current consultation indicate that only 265 specimens of ‘scientific importance’ have been recorded in the 12 years since the area was listed as a World Heritage site – an average overall of only around 20 specimens a year – if the area if truly of such great international palaeontological importance these figures should be much higher. Again this indicates the catastrophic failure of the current code and its administrators to adequately record and safeguard the rich palaeontological heritage of the WH site. Page cont… “The lack of scientific insight or background to the Code becomes obvious when one reviews its creators, representatives of a range of local governmental organisations.., heritage or ecologically- focused conservation bodies and trusts …, and ‘Local fossil collectors’ (a primarily commercial group). Some input from [local] Museum Services is noted but NO scientific organisation was represented according to Natural England documents).” [Page 2008, ISJS Newsletter]

Page cont… In addition, the Code and procedures in place fail to take into account recent international advances in the philosophy and practice of palaeontological heritage conservation, and do not even fulfil UNESCO’s own stated principles under the World heritage Convention ( http://whc.unesco.org/en/conventiontext), as contradict the principles under which UNESCO Geoparks are managed (www.unesco.org/science/earthsciences/geological_heritage). The Code also contradicts

6 the principles of the Council of Europe’s ‘Recommendation on Conservation of the Geological Heritage and areas of Special Geological Interest’ (2003: https://wcd.coe.int/ViewDoc.jsp?id=740629&Lang=en ) and the spirit of the International Union for the Conservation of Nature’s Motion CGR4.MOT055 on the Conservation of geodiversity and geological heritage (2008: http://www.progeo.pt/pdfs/iucn_geod.pdf ). To be acceptable in a global context, the code must reflect these internationally agreed principles and guidelines. Page cont…… Conclusion: The existing Code should be replaced by one which truly reflects the scientific and heritage value of the palaeontological heritage of the area and be administered with a relevant scientific panel and guarantees that specimens will be deposited in local and national institutions to be safeguarded for the benefit of all global societies (which is of course the primary aim of the WH designation). Fortunately a guide to the scientific value of fossils with recommendations for their conservation has been produced by the Geoconservation Working Group of the International Subcommission on Jurassic Stratigraphy and it is strongly recommended that this framework of 4 categories (as reproduced below under Question 4) is applied within the World Heritage site. These principles are fully compatible with recent international statements (Council of Europe, IUCN, etc) and anything less should place the Dorset WH coast in the ‘World Heritage in danger’ category and require UNESCO intervention… Question. 1 The priorities of the Dorset Code are flawed as they reflect the requirements of fossil collectors, rather 29. ISJS than science (Page 2006) and have led to significant underreporting and hence loss of palaeontologically important specimens from the area (Page 2006, Page and Wimbledon 2009). The Code, therefore, requires revision to better represent objective scientific priorities in both its categorisation of finds and the conservation measures taken to ensure the safeguard of such finds – in particular deposition in an appropriate institute where they will remain available for future study. Such a categorisation and guide to appropriate conservation measures was developed by the Geoconservation Working Group of the ISJS in 2002 (Page 2002, 2004) and is reproduced in Question 5 below. It is recommended that this classification and guide is adopted in Dorset to ensure that the conservation of the area’s rich palaeontological heritage is adequately scientifically informed.

In addition, the Code and procedures in place fail to take into account recent international advances in the philosophy and practice of palaeontological heritage conservation, and do not even conform to UNESCO’s own stated principles under the World Heritage Convention 1972 (http://whc.unesco.org/en/conventiontext), including in Articles 4 and 5:

“Each State party to this Convention recognises that the duty of ensuring the identification, protection,

7 conservation, presentation and transmission to future generations of the cultural and natural heritage referred to in Articles 1 and 2 and situated on its territory, belongs primarily to that State. It will do all it can to this end, to the utmost of its own resources and , where appropriate, with any international assistance and co-operation, in particular, financial, artistic, scientific and technical, which it may be able to obtain” [Article 4].

29. ISJS cont….. “To ensure that effective and active measures are taken for the protection, conservation and presentation of the cultural and natural heritage situated on its territory, each state Party to this Convention shall endeavour, in so far as possible…: [including] 3.To develop scientific and technical studies and research and to work out such operating methods as will makew the State capable of counteraction the dangers that threaten its cultural or natural heritage; 4.. To take the and appropriate legal, scientific, technical, administrative and financial measures necessary for the identification, protection, conservation, presentation and rehabilitation of this heritage…” [Article 5, extracts]

[...whilst noting that] “…the deterioration or disappearance of any item of the cultural or natural heritage constitutes a harmful impoverishment of the heritage of all nations of the world.” [introductory text to the convention].

…as well as contradicting the principles under which UNESCO Geoparks are managed (www.unesco.org/science/earthsciences/geological_heritage), e.g.:

“No loss or destruction, directly or via sale, of the geological values of a European Geopark may be tolerated”. [European Geoparks Network Charter: Against trading in geological objects, 2000] 29. ISJS cont…… The Dorset Code is also an odds with the principles of the Council of Europe’s ‘Recommendation on Conservation of the Geological Heritage and areas of Special Geological Interest’ (2003: https://wcd.coe.int/ViewDoc.jsp?id=740629&Lang=en), in particular Appendix 4:

“Protecting moveable geological heritage

The legal protection of areas of special geological interest (geosites, geoparks, geotopes, etc.) will provide protection from a variety of damaging activities, including protection from damage due to

8 removal (collecting) of materials of scientific interest. Moveable geological materials may be collected for various reasons, such as: – scientific study; – commercial sale; – educational use; – curiosity value.

In certain circumstances, collection from areas of geological importance may be damaging to the area itself, or cause loss of valuable scientific information, for various reasons: – physical damage may be caused to rock formations by excessive, inexpert or careless collecting; – specimens may be destroyed or damaged during the act of collection; – collection of rare/unusual specimens by non-specialists or commercial collectors may result in the disappearance of important scientific specimens into private collections; – specimens collected in one country may be exported to collectors or museums in another country, with a perceived loss of "cultural" heritage for the country of origin.

29. ISJS Many European countries make use of wildlife legislation, nature conservation legislation, monument protection legislation or other legal instruments to protect areas (sites) from damage through collecting. In other cases control is exercised by educational programmes and voluntary codes of conduct.

Proposed action Governments of member states should review their existing legal and voluntary supervision methods to ensure that moveable geological heritage is protected by appropriate legal means, in the national and international context.” [Appendix 4, 2004]

…and the essence of the International Union for the Conservation of Nature’s Motion CGR4.MOT055 on the Conservation of geodiversity and geological heritage (2008: http://www.progeo.pt/pdfs/iucn_geod.pdf ), including in recalling both the World Heritage Convention and the Council of Europe statement, as cited above. Question. 1 ProGEO accepts the fact that the management of collectable (moveable) geoheritage resources is 30. ProGEO difficult and that the balance between strict Geoconservation and collecting (both for commercial and private interests) may be difficult to obtain, especially in areas where commercial collecting has a long and locally strong tradition. The arguments about all the collectors that for 200 years have contributed are relevant, but must not override the concern for the geoheritage itself. It is of vital importance to

9 focus on Geoconservation. The ultimate test if this is obtained will be that the defined geoheritage value is not reduced, but preferably enhanced in all protected and managed areas with a geological conservation aim. On a general basis, the overall geodiversity of any area (protected or not) should not be reduced. This means that the fossil content (any type), the stratigraphic geoheritage, as well as landscapes (landforms and recent processes) have their place in this discussion. Excavations or collecting should not be dealer led, i.e. be biased. There should be the strong input, guidance and leadership from the scientific community. By that we mean specialists who have actively made a contribution to geological science on this coast.

One main concern with the code is the significant underreporting of collected specimens (stated by the ISJS – see under “any other comments”), and hence a loss of knowledge about this geoheritage. This represents a challenge for the management and it is important that this information is integrated in the discussion of the strategy. If the information is challenged, it is important to seriously test the alternative information with enough detail. Independent of management strategies, this monitoring of the management effects must always be a central element. Monitoring must feed the management with updated information. This information must be open for criticism and adjustments from research. In this way the management can be knowledge-based and able to adjust and to respond to the need of the conservation aims of the area. Question. 1 BIGC [British Institute for Geological Conservation] is concerned that the ‘Code’ has leant too far in 31. BIGC the direction of commercial collectors, and that a proper balance has to be struck between commercial requirements and scientific work. We are well aware that some calls for a science-based policy may betray the professional collectors if the scientific research is not carried out and published in timely fashion, or if promises of museum display and educational development are not met. Equally, there is a

risk that the situation could tip the wrong way when the HLF money runs out, and that collectors would lose any incentive to report anything and materials might disappear into the private and overseas market. The missing element at present is confidence from the scientific side that collectors really are adhering to the reporting aspects of the Code, and that this aspect will improve in future. We realise the answer is not a ‘big stick’, and indeed current laws might be hard to extend to discipline exploitative collectors.

Other responses give chapter and verse on UNESCO and other international geoconservation codes, and we entirely support those, and recommend them as a basis or foreword to the revised Dorset Code. The key such international commitment is given by UNESCO in the World Heritage Convention 1972 (http://whc.unesco.org/en/conventiontext), Articles 4 and 5:

“Each State party to this Convention recognises that the duty of ensuring the identification, protection, conservation, presentation and transmission to future generations of the cultural and natural heritage referred to in Articles 1 and 2 and situated on its territory, belongs primarily to that State. It will do all it can to this end, to the utmost of its own resources and, where appropriate, with any international assistance and co-operation, in particular, financial, artistic, scientific and technical, which it may be able to obtain” [Article 4].

“To ensure that effective and active measures are taken for the protection, conservation and presentation of the cultural and natural heritage situated on its territory, each state Party to this Convention shall endeavour, in so far as possible…: [including] 3. To develop scientific and technical studies and research and to work out such operating methods as will makew the State capable of counteraction the dangers that threaten its cultural or natural heritage; 4. To take the proper and appropriate legal, scientific, technical, administrative and financial measures necessary for the identification, protection, conservation, presentation and rehabilitation of this heritage…” [Article 5, extracts]

Many European countries make use of wildlife legislation, nature conservation legislation, monument protection legislation or other legal instruments to protect areas (sites) from damage through collecting. In other cases control is exercised by educational programmes and voluntary codes of conduct. We recommend these actions by the Jurassic Coast team (JC):

1. Lead into the revised code with the appropriate sections of the UNESCO code, so that people can see that the requirements to exercise restraint and to cooperate fully with regulatory and scientific agencies is not just a draconian peculiarity, but has real international standing. 2. Establish an urgent review with English Nature of the potentially damaging operations (PDOs) indicated in the legally binding SSSI statements for al GCR sites along the relevant coast, and consider each in turn with a view to using the regulatory powers of EN to restrict or stop certain kinds of large- scale excavations everywhere, and prevent any kind of digging at other sites. The coast section can be

11 zoned according to erosion rate (see below) and PDOs, and those aspects translated to an easy-to- understand form: these areas area no-go; these are for retrieval of eroded specimens only, and these for current styles of collecting. 3. Bid for additional funds to enhance the liaison role and the development role within JC. The JC organisation has to have eyes and ears everywhere (possibly involving volunteer helpers) and be in constant discussion with all known collectors, but also show stronger project management and an ability to make one-off fundraising efforts for particular key specimens. Turning exciting new finds into scientific research effectively is key – we acknowledge failings on the scientific side here, and stronger project management from JC can help drive projects to completion. 32. Kevin Dermody [NOTE: This response was received in June but misplaced when collating all the responses] I think you have a great system. I mentioned it to some people I know at the SVP meeting, and they agreed.

Question 2. What are the barriers and issues relating to acquisition and how can they be overcome?

1. Ben Brookes The elephant in the room when it comes to the problems of acquisition is obviously the state of science and arts funding in the United Kingdom, where almost all of the funding gained under the previous Labour government has been removed, this is unlikely to change in the near future.

A problem alluded to in your report is the reticence of many museum curators and similar to value palaeontological specimens for reasons relating to legal risk and the resulting inability of many British museums to be able to afford said specimens once valued. Whilst this is not something that can be easily overcome through the Fossil Code, this is something that could be very easily fixed through the extension of the 1996 Treasure Act (http://www.legislation.gov.uk/ukpga_1996/24/contents) to include natural history specimens, as the enactment of this act provides a valuation system/protocol for anything that qualifies under the act, which would remove the responsibility from individual curators for the valuation. Extension of the act would also introduce some element of control over the destination of the specimen by requiring it to be offered first to National Museums, then progressively to Local Museums, Foreign Museums and institutions, and finally to retention/public or private sale by the finder of the specimen (http://en.wikipedia.org/wiki/Treasure_Act & http://en.wikipedia.org/wiki/Treasure_Valuation_Committee). Though any lobbying for such changes would need the full support of professional collectors and would need to require some consideration of their work, as under the current Treasure Act, the landowner retains sole legal claim to all finds made

12 on their land. Question. 2 Individuals from any interest group must continue to be able to collect from fallen material, and make 2. Nigel Trewin private collections. This is the way the majority of palaeontologists (like myself) start careers. The vast majority of collectors are proud to have finds valued and put in museums, provided the museum actually does some work on the find, rather than stick it in a drawer and forget it! Thus museums must be more than a storage facility. I have no issue with private ownership, good private collections are a valuable resource. Maybe there could be a register of private collections of Dorset material. Question. 2 Need better database info. including high res. photos and more attribution. 3. Paul de la Salle Question. 2 In the case of many museums, there are two main problems. Firstly, museum staff generally lack the 4. Paul Barrett time and resources to make their own collections from the site, at least not on a regular basis or for a useful single period of time. As noted in the report, most accredited museums are some distance from the West Dorset coast and cannot be on hand to collect regularly, or even irregularly. Spontaneous visits in response to storms and landslides are almost impossible to arrange for reasons of finance, planning, etc. Second, UK museums lack large acquisition budgets and so cannot meet the prices proposed by professional collectors. Purchases of major finds might require substantial periods of public fund-raising, by which time the collector may find another private, or overseas, buyer. Question. 2 Response outside questionnaire 5. Mark Bradley Question. 2 It’s important that academics communicate constructively with collectors, emphasising how valuable 6. Rob Coram their contribution to science is, and how much it is appreciated. Something that’s worked for me in the past is the offer of either paper co-authorship or having the species, if new, named after the collector, in exchange for study and deposition of an important specimen. If necessary, it can be emphasised what a rare privilege it is to be immortalised in such a way… that it’s something even film stars can’t buy…. etc. etc. Admittedly, these are usually insect specimens of low or indeterminate commercial value, so money is not a real factor. Many fossils are worth money, though. I’ve nothing at all against responsible commercial collectors making a living that way (done it myself), but the one decidedly grey area, where I share the concerns of academic critics of the code, is in the disposal of ‘Category 1’ material. Much as the collectors would no doubt prefer to see their rare finds end up in museums, the fact is that the best prices are often achieved through sales to private individuals, which museums can’t match. If I were to see, say, an important Lias insect fossil up for grabs at an international fossil fair I would become very disillusioned with the collecting code as it stands. Similarly, for a landowner to hand over in good faith ownership of an exceptional specimen (say, a new species) that ends up in some foreign private

13 collection after the exchange of large sums of money would be a damning indictment of the scientific management of a World Heritage site. There’s no easy solution to this, other than perhaps landowners relinquishing ownership of specimens only on condition that those of truly exceptional scientific value have to go to recognised museums at whatever price can be raised. Question. 2 I suspect that apart from the obvious barrier of lack of funds (and museum space) this assessment may 7. Chris Paul well be premature. If professional and amateur collectors wish to retain specimens during their lifetime, but are prepared for their collection to be donated or sold to a museum after their death, then a long-term view of the eventual destination of many specimens needs to be taken. We should be encouraging those with valuable collections to leave explicit instructions in their wills. Question. 2 Better funding for Museums, perhaps a vision to create a world class museum at Lyme Regis. If local 8. Alan Saxon people could be proud of and had such a facility, then public subscriptions might be forthcoming to help to purchase that must have fossil to be displayed locally, where it belongs. Question. 2 Potential conflicts between amateur and professional collectors and those of landowners and the 9. Alan Lord/Geol scientific community are clearly discussed. The light touch approach combined with publicity for the Soc of London Code and public education seems the best approach. Question. 2 • Unprepared fossils cannot always be recognised as important until they are cleaned. Then it 10. Tony Holmes may not be practical to return it/them to the Heritage Centre for recording, if collectors live elsewhere. • A remote system of recording is required, possibly via the internet/emails. This would require monitoring or administration to ensure correctness • Potential lack of knowledge of the code and how to implement it by collectors. Seminars could be held for those known to collect and notice boards for adhoc/tourist collectors • A simple dedicated photographic display of finds both at Lyme Regis and Charmouth would encourage people to come forward. • Misleading monetary valuations make people think finds are more valuable than reality dictates. This could make them reluctant to donate, of course the opposite is also true. • Museums requesting specimens and not writing reports quickly. I was told by NHM that a specimen I found would not be written up for at least 10 years+ • Acknowledgements of finders are not always forthcoming by academics, when writing papers. A little kudos goes a long way to encourage donations Question. 2 Not applicable here 11. Simon Ford Question. 2 Summary: Capacity within local museums, both physical and staff, is a major issue 12. Museums

14 partnership 13. Bob Davidson No response to this specific question 14. Dorset GA No response to this specific question 15. Sheila Alderman/ No response to this specific question Wessex OUGS 16. Claire James No response to this specific question 17. John Wright No response to this specific question 18. Chris King Complex response that lies outside the questionnaire 19. Roger Vaughan No response to this specific question 20. Mike Simms No response to this specific question 21. Ian West No response to this specific question Question. 2 It is gratifying that collectors make a number of donations and collectors are willing to continue this if 22. Charmouth the opportunities are right. We have a lot of sympathy with their vision for a museum to house a Parish Council collection locally. To me a museum should be able to provide a history with local finds of the diverse species in the Palaeontology of this coast; at present no local museum has the space to demonstrate this. Question. 2 To my mind the key problem is the imbalance of museums and funding (especially in geology) versus 23. Mike Taylor the potential of the area. Summarised: Inheritance tax might be one area to encourage some collectors to consider. Question. 2 See above. 24. Tim Ewin 1 Site secrecy is one issue: 2 Lack of direct benefit to the collectors to either record the specimens: 3 There is no publically owned local repository (e.g. a museum) that will both accept fossils for a collection or display them. 4. Existing museum’s attitudes to acquiring fossils. This is mostly due to museums lacking the right skills and resources which gives the collectors a perception of museums that they lack of willingness to work effectively with the collecting community. This makes museums appear aloof and is compounded by the fact that many museums now refuse to enter into agreements with collectors as a matter of “best practice”. This in turn makes collectors feel they do not have sufficient influence with regards to what happens to their specimens once they are given to a museum. This is unfortunately not an unfounded concern. As is evidenced by the attitudes of regional museums such as Exeter, Bristol, Dorchester etc. Something legal needs to happen to force the heritage sector to provide proper provision for the care of natural heritage. The portable antiquities scheme run for archaeological finds is a good potential model:

15 5. There is no way to force collectors to part with scientifically important finds – as happens with certain parts of archaeological finds. A treasure act for fossils would do this: Question. 2 Basically a problem of level of funding. Use the tax system to encourage donation, as in the USA. 25. David Ward Question. 2 Human nature – simply people wishing to collect and retain material, or gain financially. May be 26. Colin overcome by a reward of sorts that in itself does not lead to further irresponsible collecting. MacFadyen Question. 2 No specific response to this question 27. Neil Ellis Question. 2 As with other aspects of the system currently in place in Dorset, the assumption that ‘market forces’ Correction: The lottery money: 28. Kevin Page will deliver palaeontological conservation is deeply flawed. The high value of many fossils on the Collecting Cultures fund was international market means that inevitably greed will take over from altruism and it will be impossible £230,000, 60% of which was used for adequate resources to be made available to purchase collected specimens. And with a global crisis in acquisition and preparation with and severe cuts taking place to health services and education, promoting the use of increasingly large the remainder used to support interpretation and education in amounts of public money is at best inappropriate at worst cynical exploitation (for instance the local museums. Nearly half of the £250,000 of lottery money used to buy specimens from the World Hertitage Site from local collectors acquisition budget went on the for Dorset museums). Indeed many of the specimens come from publically owned or managed land purchase and preparation of the with associated conservation designations, and simple actions by the likes of the National Trust and Weymouth Bay Pliosaur skull. Natural England in enforcing conservation legislation and bylaws would ensure specimens would arrive in institutions without requiring purchase (indeed one could argue that the current system in Not so: Many of the specimens do place in Dorset forces the nation to ‘buy back’ what it effectively already owned). Such monies would not come from publicly owned or be much better used to support genuine scientific research on the coast- by both professional and managed land. amateur geologists and palaeontologists – and any specimens collected would then come with ‘added value’, i.e. proper documentation, published descriptions, etc. Question. 2 The Dorset Fossil Collecting Code relies on a significant financial input by the state to facilitate the 29. ISJS purchase of collected specimens. As such it establishes and promotes a market place for fossils which can only adversely affect scientific and heritage concerns as ‘ability to pay’ takes priority over scientific importance. This approach is short sighted and ultimately highly damaging, as few institutions or researchers are able to compete in this marketplace – indeed its highly unlikely that research grant awarding organisations, especially in the current global financial context, would even consider funding the purchase of research materials. What makes the situation even more remarkable in Dorset, setting aside the World Heritage listing of the area, is that existing conservation legislation and land-ownership rights could be invoked to make any such market-led approach unnecessary and ensure deposition in appropriate institutions. It is recommended that the later approach is adopted and that the

16 managers of the World Heritage site in future seek to work closer with a scientific community rather than a commercial fossil collecting community. Question. 2 It is important that the scientific interest of the area is acknowledged. Important specimens should be 30. ProGEO open for research and display. The existing system seems to include a reporting element and a compensation element if the specimen is of scientific interest. The comments of ISJS are concerned with the effect of the commercial element of the code. This has two dimensions: The need to secure the report procedure and a relevant monitoring of the development and policing of existing rules. The problems linked to lack of resources to obtain relevant specimens and the general effect of accepting commerce in the management. The first point is commented above. The second point is more complex as there is a market already functional that it is difficult to ignore. It is, however, important to take this seriously, keep the debate open and take into account new research on the effects of different strategies. In any case, it is vital to budget with enough resources so that this scientific important heritage can be secured. Such funding is necessary either in securing these specimens from collectors and (or) policing conservation rules and fund a relevant monitoring of the area. Question. 2 The Dorset Fossil Collecting Code has relied on a significant financial input to facilitate the purchase 31. BIGC of collected specimens. This worked well through the recent HLF funding, but we are very concerned about what happens when that budget disappears. Having established a precedent that the Jurassic Coast agency can purchase fossils, some collectors may expect this to continue.

As noted on the JC web site, professional palaeontologists have mixed views about paying for fossils, but many vertebrate palaeontologists at least see this as an inescapable part of the field, and it has been since the days of Mary Anning. Palaeontologists who paid for fossils, or worked on purchased fossils include Buckland, Mantell, Owen, Huxley, Marsh, Cope, and many more.

It is unlikely that the JC programme can expect renewal of this HLF budget, nor is it likely that national or local government will step up to pay (cf. Baden-Württemberg). Therefore, ways must be found to foster trust between collectors and scientists so that materials can be acquired by registered museums with no cash transfer, but that collectors recognise their contribution is valued through museum exhibits, scientific research, publications, and press coverage.

In this case, the JC has a key role in maintaining the relationships it has built with collectors, and making them aware of the cash constraints. A key role for the JC may be to have a Development

17 officer who spends time bidding to charities, foundations, and government art purchase schemes in the case of exceptional fossils that must be purchased.

Question 3. QUALITY OF THE SITE: The West Dorset coast is a robust site subject to high erosion rates. Ex situ collecting effort is high but the coast remains in ‘favourable condition’ and research can be undertaken. Do you agree or disagree with that statement? What is the evidence to support claims of damage to the scientific interest within this site? 1. Ben Brookes I agree with the above statement. 2. Nigel Trewin I agree, on basis of collecting at Charmouth in 1955, and many visits since. Anything that can be rescued from erosion is good news. 3. Paul de la Salle Damage due to human activity is miniscule compared to that due to the elements 4. Paul Barrett I can’t really respond to this as I do not visit frequently enough. However, given the unstable nature of the coastline I would suggest that it’s unlikely current levels of collection are harming the site – indeed, many fossils are probably being lost to active erosion all of the time. 5. Mark Bradley No specific response to this question Question. 3 Agree generally, although there are circumstances in which research opportunities can be hampered. In 6. Rob Coram my own field, for example, the Flatstones are the best known and historically most productive source of fossil insects, but due to their popularity for ammonites it is usually difficult to obtain material to process for insect remains, most of which (often generally small and unpigmented) are almost certainly not spotted or put aside by collectors, and hence lost to science. Encouraging collectors to keep more of an eye open for such specimens (which are often of equal, or even greater, scientific importance than the more eye-catching wings) would be a partial solution in this case. Question. 3 Indeed the coast is in an extremely favourable condition with little or no indication of becoming 7. Chris Paul ‘worked out’. Scientific interest in the coast is more likely to suffer from the lack of time professional scientists have to exploit the fossil (and other) heritage than due to activities of collectors. That said, encouraging visitors to report finds will enhance the chances of relevant scientists becoming aware of important specimens. 8. Paul Saxon No response Question. 3 Agree. I have nothing to add to the thorough discussion in the review document 9. Alan Lord Question. 3 • Agree 10. Tony Holmes • Winter storms quickly redress any potential difficulties. Even saw marks made during the extraction of starfish relatively quickly soften out. They could be helped along if the edges were partly chiselled.

18 What is the evidence to support claims of damage to the scientific interest within this site? • I collect mainly from between Eype and Seatown and collecting has always been very variable. There has been no change in recent years. Even the effects of Tourist Fossil Collectors using heavy hammers are relatively short lived. Statements, views or opinions will be of more value if supported by evidence. Evidence about gradual degradation is difficult to quantify as it is based on personal experience, with nothing specific that could be measured scientifically. 11. Simon Ford No specific response 12. Museums No specific response partnership 13. Bob Davidson No specific response to this question 14. Dorset GA No specific response to this question 15. Sheila Alderman/ No specific response to this question Wessex OUGS 16. Claire James No specific response to this question Question. 3 “Collecting effort high” - I think it is important that well preserved Category 2 specimens – bivalves, The Samphier collection was 17. John Wright ammonites, nautiloids, etc, should be properly recorded on the List. These will often be in the hands of offered to local museums but local collectors. I’ve nothing against such collectors – as you say, specimens would have been lost to we could not find one that had the sea if they had not been picked up by local collectors – but we need to know who the local the space to take it on, or find collectors are. For instance, I only heard of the Nick Samphier (Weymouth) Collection by chance, yet the money. As a result we never it turned out to be a real Alladin’s Cave – a better collection from these particular Upper Jurassic beds got down to seriously valuing than the British Museum, Oxford, Cambridge and BGS put together. Nick was delighted to show me it. round his collection. The point is that until a chance meeting I knew nothing about the collection. A different collection, the Perhaps a recording scheme for East Dorset, based at Dorchester Museum, might have helped. Harvey collection was donated to the Natural History Museum early in 2011. 18. Chris King Response appended at the end of the document 19. Roger Vaughan No specific response to this question 20. Mike Simms No specific response to this question 21. Ian West No specific response to this question 22. Charmouth No specific response to this question Parish Council 23. Mike Taylor No specific response to this question

19 Question. 3 In general I do agree with this statement. I welcome collecting (amateur and professional i.e. not just 24. Tim Ewin research collecting) along the coast however, meaningful research is severely curtailed by a lack of specimens entering into publically accessible collections. This is very frustrating and hard decisions need to be taken as to how to rectify this issue without alienating the various stakeholders. As said above a treasure act for fossils would go some way of resolving these issues and has not alienated the majority archaeological amateur collectors, quite the opposite in fact. Question. 3 Agree. Active collecting Must be promoted on actively eroding 25. David Ward Question. 3 Given the nature and extent of the interest feature, I agree with that statement. 26. Colin Macfayden Question. 3 No specific response to this question 27. Neil Ellis Question. 3 This is another of the grossly misleading statements which are used in Dorset to justify what is 28. Kevin Page effectively a de-regulation of fossil collecting on what is, in theory at least, a nationally and internationally protected site. Some areas such as the cliffs and undercliffs between Lyme Regis and Charmouth do experience periodic rapid erosion, but other areas such as foreshores and cliff east of Stonebarrow erode much slower – many are even protected by high storm beaches or boulder shores – and therefore at much greater risk from intensive fossil collecting as is promoted in Dorset. The high level of collecting of shore areas also means that compared to around 25 years ago it has become increasingly difficult to collect in-situ material which is essential for scientific research – the result is that many areas of the Dorset coast are now inferior to other areas of the UK and continental Europe for primary biostratigraphical, etc study – the former are certainly NOT in ‘favourable’ condition in this context (and arguably not now of genuine ‘World Heritage’ value. Unfortunately scientifically- informed views and opinions such as this have been consistent ignored by the Dorset WH Group and Natural England, claiming that more ‘evidence’ is needed. With this attitude to informed scientific comment it is difficult to move on…

Page continued…. Examples used in the documents distributed to support the current collecting system in Dorset are and demonstrate that features are not at risk are often misleadingly and not independently scientifically informed – including the example of a Bathonian ammonite welded into a thick band of limestone at Watton Cliff (Plate 11). This specimen would never have been at significant risk from commercial collectors as it is virtually impossible to prepare, and the quotes used from private email correspondence are misleadingly in this context.

Page continued… One scientific study, however, which Dorset WH Group and Natural England have repeatedly The presentation of the Charmouth attempted to discredit, typically using spurious, un-scientific and un-informed arguments, genuinely Bypass analysis is published in the demonstrates the high level of loss of palaeontological heritage from the World Heritage site and was International Subcommission on first presented in 2005-6: Jurassic Stratigraphy Newsletter 33 pages 22-25. Our concerns about the validity of the work are “This recording scheme [i.e. the West Dorset Fossil Code], however, provides a valuable way in which expressed in Newsletter 34/2 by D. to assess the scientific and heritage management ‘effectiveness’ of an entirely voluntary, collector- Sole on pages 24-27 and J. focussed approach without any legislative back-up regarding moveable heritage. Comparison with the Larwood on page 33 and the records of scientifically collected total faunas from a palaeontological recovery project on an adjacent response to those concerns is highway bypass site (Page 1991) provides the necessary ‘control’. Based on the relative abundance of provided in ISJS Newsletter 35/2, different fossil groups collected during the latter scheme, the level of recovery of scientifically pages 22-27. important specimens from the World Heritage site can be estimated. As reptile specimens are well recorded by the collecting Code, they can become a standard for estimating the recovery of other In summary, it is our view that groups. For instance as 3 fragmentary reptile skeletons were found on the bypass site and 14 on the there are substantial and crucial coast during the first 3 years of the recording scheme, a multiplier of 4.7 can be derived (e.g. 3 x 4.7 = differences between the circumstances relevant to 14) and expected numbers of scientifically important specimens for the coast so derived. The results of collecting, recording and retaining this analysis are illustrated by Table 1. specimens on the Charmouth bypass compared to those on the FOSSIL Charmouth West Dorset Expected No. of Estimated loss West Dorset coast including GROUP Bypass Site Coast, Register specimens of from the coast stratigraphical extent, volumes of (specimens of (i.e. World particular (No. of available material, method of particular Heritage site) scientific specimens) exposure, collecting approach, the scientific importance on degree of control that was possible importance the coast and the categorisation of recorded fossils considered to be of bracketed) scientific importance. Reptiles 3 (3) 14 14 [e.g. 3 x 4.7 = 0 14] These differences in our view Fish 18 (10) 4 (10 x 4.7 =) 47 (47–4 =) 43 challenge whether the collecting Insects 106 (106) 4 (106 x 4.7 =) 498 (498-4 =) 494 approach adopted for the Teuthids (squids) 8 (8) 1 (8 x 4.7 =) 38 (38-1 =) 37 Charmouth bypass could possibly Ammonites 2215 (140) 4 (140 x 4.7 =) 658 (658-4 =) 654 provide a valid analogy to be of Miscellaneous 71 (10) 7 (10 x 4.7 =) 47 (47-7 =) 40 any use in calculating the numbers of key scientifically important

21 TOTALS 2420 (277) 36 1304 1268 specimens that should have been recorded from within the code area Table 1: Comparison of the records of Jurassic fossils from the scientific recording scheme of the in the chosen three year study Charmouth Bypass site (1989-1990) and the West Dorset Coast Fossil Collecting Code register (1999- period. We would urge people to follow the articles and discussion 2002). The number of reptile records in the latter scheme is assumed to be the most reliable and is in the ISJS newsletters as outlined therefore used as a “standard” to help estimate the number of records of scientifically important above and form their own opinion. specimens which would be expected on the coast, and the potential loss through collector failure. This table is slightly modified from previous versions (e.g. in Page 2005b) and now includes records of specimens released to fossil collectors permitted access to the bypass site.

The results suggest that over 1300 specimens of particular scientific note should have been recorded by the World Heritage collecting scheme over this period. The actual figure of only 36 reported specimens over the study period, even allowing for a few unrecorded academic studies, demonstrates that the Code has spectacularly failed to deliver its original aims. These figures clearly demonstrate that entirely voluntary approaches to conserving palaeontological heritage are unlikely to succeed, not least as the private interests of some collectors, especially commercial, are likely to conflict with the scientific aims of natural heritage protection. The irony of the West Dorset scenario is despite an impressive collection of site-focussed designations, a primary interest of the area, its fossils, effectively have no protection.” [Page 2005]. Page cont….. “ Even with figures up to 2005, only around 40 specimens more are recorded, around 30 of which are Correction: between the end of small insect fragments, most of which are likely to have been discarded as larger fossils were prepared 2002 and the end of 2004 there in local workshops” (Page 2005, 2006). were 20 records, three of which [Page and Wimbledon 2009 – see references below]. were insects, one of those being a collection of 34 specimens. Of those three records, 2 have been Results to 2011, as noted previously, suggest that only 265 specimens of ‘scientific importance’ have donated to the Natural History been recorded in the 12 years since the area was listed as a World Heritage site (an average overall of Museum; a total of 35 out of 36 only around 20 specimens a year) – if the area if truly of such great international palaeontological specimens, at least one of which is importance these figures should be much higher. Again this indicates the catastrophic failure of the considered to be a new species. current code and its administrators to adequately record and safeguard the rich palaeontological heritage of the WH site. Question. 3 Some areas of the coast, in particular cliffs between Lyme Regis and Charmouth, do erode rapidly but 29. ISJS elsewhere, foreshore exposures can be relatively stable and cliffs protected by high storm beaches, boulder shores and landslip/talus platforms. This statement is therefore highly misleading and in reality the coast could be zoned as to effective erosion rates. Unfortunately many scientifically informed

22 statements about loss of palaeontological heritage and damage to the site have been consistently ignored by the administrators, whilst promoting the contradictory and unscientifically–informed views of others such as commercial fossil collectors. This is to be regretted.

One case history has been described, however, and demonstrates the level of palaeontological loss through the application of the current fossil collecting code:

“Analysis of the register of finds provides an indication of the level of this loss, when compared to scientifically gathered records from an adjacent road scheme. These figures indicate that over 1300 specimens of particular scientific note should have been recorded from the World Heritage site over the period 1999-2002. The actual figure reported of only 36 specimens over the period, even allowing

for a few unrecorded academic studies, demonstrates that the code has delivered little scientific As with response 28 above benefit. Even with figures up to 2005, only around 40 specimens more are recorded, around 30 of which are small insect fragments, most of which are likely to have been discarded as larger fossils were prepared in local workshops (Page 2005, 2006).” [Page and Wimbledon 2009]

Even up to 2011 as recorded in the documents supplied with this consultation, only 265 specimens’ of scientific importance’ have been recorded in the 12 years since the area was listed as a World Heritage site – an average overall of only around 20 specimens a year – if the area if truly of such great international palaeontological importance these figures should be much higher. Again this indicates the failure of the current code to adequately record and safeguard the rich palaeontological heritage of the WH site, with potentially great consequences for science. Question 3. The robustness stated for the area is linked to its size and its exposure to erosional processes, but the 30. ProGEO degree of vulnerability for the geoheritage to human activity such as collecting, is variable as should be expected in an area of this size. It is important that the existence of robust parts do not cause mismanagement of less robust areas. A relevant tool would be to include a management plan that not only divides between different fossils and their need for conservation, but also divides the area into zones with different conservation needs according to their vulnerability. One aim of the code should be to promote the idea that geological material should be possible to be viewed in situ. The culture of collecting is in this respect problematic and cannot be argued to be sustainable if it results in the loss of important geoheritage. The practice will then not conform to the norms of geoconservation good practice. It would be good also to see promotion of no collecting, but only looking as a part of the code. The loss of material and data in the form of invertebrate fossils is reported to be a concern. In some

23 places, the index species for zones or a typical fossil fauna may be absent and they consistently cannot be demonstrated to a visiting educational group. On a coast famous as a classical standard for the Jurassic and Cretaceous, the reason it is a WH Site, this is indeed regrettable. Question. 3 Some areas of the coast, in particular cliffs between Lyme Regis and Charmouth, do erode rapidly, but 31. BIGC elsewhere foreshore exposures can be relatively stable and cliffs protected by high storm beaches, boulder shores and landslip/talus platforms. This statement is therefore misleading and the coast section should be zoned according to typical erosion rates.

Concerns have already been expressed about the rather low rate of reporting of ‘scientifically

important’ fossils:

“Analysis of the register of finds provides an indication of the level of this loss, when compared to

scientifically gathered records from an adjacent road scheme. These figures indicate that over 1300 specimens of particular scientific note should have been recorded from the World Heritage site over the period 1999-2002. The actual figure reported of only 36 specimens over the period, even allowing for a few unrecorded academic studies, demonstrates that the code has delivered little scientific As response 28 above. benefit. Even with figures up to 2005, only around 40 specimens more are recorded, around 30 of which are small insect fragments, most of which are likely to have been discarded as larger fossils were prepared in local workshops (Page 2005, 2006).” [Page and Wimbledon 2009]

Even up to 2011 as recorded in the documents supplied with this consultation, 265 specimens ’of scientific importance’ have been recorded in the 12 years since the area was listed as a World Heritage site – an average of around 20 specimens a year. It is impossible to know what the true figures might be, were palaeontologists able to review everything that is collected. 32. Kevin Dermody No specific response

Question 4. Is there an alternative, more effective, practical and affordable way to achieve the objectives set out in the code or alternative objectives that you have identified? 1. Ben Brookes So far as I am able to comment on this question, I think that the codes objectives as they stand work well, and as far as I see it the current system is effective and practical. 2. Nigel Trewin I think you have it correct already. 3. Paul de la Salle No

24 4. Paul Barrett Probably not. Other solutions would require major increases in museum funding to allow purchase of specimens or draconican legislation to limit the sale of scientifically important specimens. 5. Mark Bradley No response to this question 6. Rob Coram Generally, I think the code, rather like democracy, is the best of the obvious options, none of which are ideal. It is certainly better than a total lack of restrictions, and the other extreme, total control, is undesirable and unworkable for reasons explained in the review notes. 7. Chris Paul The fossil walks run through Lyme Regis Museum are an excellent example of good practice, at least as far as ‘casual’ collectors are concerned. In effect, they harness the search effort of many people, but filter the finds for anything significant or important. Paddy Howe and Chris Andrew are adept at persuading anyone who finds something important to swap it for a similar specimen. In two recent papers in which I was involved with them, several of the specimens we used were found on fossil walks. All are now in Lyme Regis Museum. 8. Paul Saxon No response to this question 9. Alan Lord Difficult to see any other approach. Objectives sensible 10. Tony Holmes • Both professional and amateur collectors could ensure the code is implemented by monitoring what is happening on the beaches. • Ensure the recording system can be accessed remotely by those who have left the area, so that specimens can be recorded remotely • Monitor other fossil internet sites, such as UKGE Discussions. 11. Simon Ford No response to this question 12. Museums partnership 13. Bob Davidson No response to this question 14. Dorset GA No response to this question 15. Sheila Alderman/ No response to this question Wessex OUGS 16. Claire James No response to this question Question. 4 “Affordable” - this is something that is of deep concern to academics – the seemingly exorbitant prices 17. John Wright paid for some ammonites and similar fossils in the List. People in universities are paid to collect and prepare fossils, and everyone accepts that eventually these specimens will be donated to a museum. I’m sure that the average amateur, coming across a significant find, would be happy enough to donate the specimen to a local museum in return for he specimen being displayed and labelled as donated by the finder. This is the scheme that Woodend Museum in Scarborough operated successfully for many

25 years. The problem is the local collector, who will often have put in a lot of work preparing the specimens, and expects to be paid for this. Tens of hours of work can be involved. I feel that it should be made clear that under the scheme the sum paid is principally for the preparation rather than the actual specimen. If the idea got around that ammonites are very valuable, worth hundreds of pounds, it will be increasingly difficult to get anyone to donate specimens to museums, and as museums will be unable to pay he sums demanded, the specimens may well end up with dealers, sold to persons who just want the specimens for ornaments, and lost to science for good. 18. Chris King Considered in letter 19. Roger Vaughan No specific answer to this question 20. Mike Simms No specific answer to this question 21. Ian West No specific answer to this question 22. Charmouth No specific answer to this question Parish Council 23. Mike Taylor No specific answer to this question Question. 4 A treasure act for fossils. 24. Tim Ewin Question. 4 No, but the Danish system of "Danekrae" could be beneficial. 25. David Ward Question. 4 Currently I do not see any alternative approach that may be taken. 26. Colin Macfayden 27. Neil Ellis No specific answer to this question Question. 4 Yes – revise the Code to reflect scientific principles (see below) and enforce existing conservation and 28. Kevin Page landowner related legislation and bylaws. Establish genuine scientific working groups and develop and train volunteer groups to monitor the coast and report/ recover key finds without sale. This use of ‘voluntary wardens’ and ‘site curators’ has worked well in many other countries and there is no reason, why it should not work in Dorset…

In addition, the excellent, scientifically informed and adequately consulted Fossil Collecting Code and guidance produced by Scottish Natural Heritage in 2008, should be consulted as its principles can inform good practice in Dorset:

SCOTTISH NATURAL HERITAGE 2008. Scottish Fossil Code. Scottish Natural Heritage, Edinburgh

26 (available from www.snh.org.uk/pdfs/fossilcode) Question 4. Yes – revise the Code to reflect scientific principles (see below) and enforce existing conservation and 29. ISJS landowner-related legislation and bylaws. Establish genuine scientific working groups, for instance including representatives from the ISJS and other national and international scientific organisations, and develop and train volunteer groups to monitor the coast and report and recover key finds without sale. This use of ‘voluntary wardens’ and ‘site curators’ has worked well in many other countries.

In addition, it would be useful for the Dorset WH management group to reform procedures based on existing scientifically informed and adequately consulted guidance such as the excellent fossil collecting code produced by Scottish Natural Heritage in 2008:

SCOTTISH NATURAL HERITAGE 2008. Scottish Fossil Code. Scottish Natural Heritage, Edinburgh (available from www.snh.org.uk/pdfs/fossilcode) Question. 4 See points above concerning monitoring and management plans with zonation according to robustness 30. ProGEO and vulnerability.

It is reported doubt to us if the nature of consultation on the E.D/D WH Coast is effective enough. There may be a need for improved direct and concerted liaison and involvement of researchers on the coast. It is important to secure mechanisms for assaying the activity of geologists on the coast keeping up-to-date with their research, and effectively canvassing their views when developments and threats arise. A small research budget (and a small research committee) for investigation and research in the WH site may prove useful in this respect. This can be used to cover, amongst other things, rescue digs, excavations and collecting where some conservation and scientific imperative exist. This has been suggested before and we think it is a good suggestion that can counteract some of the problems and worries expressed comments. Question. 4 Yes – revise the Code to reflect scientific principles (see below) and enforce existing conservation and 31. BIGC landowner-related legislation and bylaws. Establish genuine scientific working groups, for instance including representatives from the ISJS and other national and international scientific organisations, and develop and train volunteer groups to monitor the coast and report and recover key finds without sale. This use of ‘voluntary wardens’ and ‘site curators’ has worked well in many other countries.

SCOTTISH NATURAL HERITAGE 2008. Scottish Fossil Code. Scottish Natural Heritage, Edinburgh (available from www.snh.org.uk/pdfs/fossilcode) 32. Kevin Dermody No specific comments

Question 5. Defining scientific importance. Are the categories defining scientific importance correct and if not why not? What is missing?

Question. 5 Whilst I think that the Category 1/Category 2 system works well, I agree broadly with recommendation 1. Ben Brookes 6 in appendix 9 of your consultation documents provided that suitable recording does not swamp the servers/staff working on the Collecting Code. Especially if it encourages more collectors (Tourist, Amateur and Professional) to record more of their important finds. Question. 5 I agree with the criteria, they are comprehensive, without becoming nit-picking, 2. Nigel Trewin Question. 5 Probably correct but need to improve database and images and keep up to date so that people visit the 3. Paul de la Salle website often and want to report their finds. Give more credit to the individuals who find these things. Question. 5 Most of the specimens mentioned in the list are voucher specimens or specimens of peculiar 4. Paul Barrett importance. However, in a strict sense all specimens are of some importance as large collections of microfossils and/or invertebrates are useful in stratigraphical studies, studies on populations, etc. Nevertheless, many of these fossils are so abundant at the site, I don’t see that any additional guidelines would be necessary for informing their collection. Mark Bradley No specific response to this question Question. 5 Yes, in that they focus on the material that is in highest demand from collectors and most likely to 6. Rob Coram produce rare or spectacular specimens that should be in museums and are unlikely to be encountered in the course of routine academic research. It would be fairly pointless, for example, to attempt to register important bivalve remains: firstly, a non-specialist is not likely to recognise a new species or otherwise unusual specimen (I couldn’t); secondly, because they are of relatively little interest to collectors I would imagine that opportunities to research and collect them on site are no worse now than they were in Victorian times. As with ammonites, however, it should be recommended that unusual examples of any fossil group should be registered, and the academic community should be encouraged to fine-tune categorisation of particular fossil groups. Question. 5 There is a substantial bias towards what may be called the biological aspects of fossils, i.e., what 7. Chris Paul species, unusual morphology, but less on their geological significance. The possibility of common

28 fossils being important because they are rare at a particular stratigraphic horizon is mentioned. Yet, how do you know that common fossils are rare at a particular horizon if their precise stratigraphic position has not been recorded systematically and in detail? Unusual stratigraphic occurrences often indicate incursions of different water masses (e.g., Boreal versus Tethyan waters) or may indicate unusual conditions of preservation, such as articulated skeletons, aragonitic preservation, or event beds such as the starfish bed. These are all scientifically important. 8. Paul Saxon No comments Question. 5 Categories and logic behind seem fine 9. Alan Lord Question. 5 • Generally yes. One of the problems for the public is the recognition of ‘names’, 10. Tony Holmes supplementary day to day names and diagrams or photographs would help enormously • Defining scientific importance is very difficult as different fossils are important on different beaches, even some serpild tubes can be rare. Knowing what is rare can be difficult. What is missing? Nothing 11. Simon Ford No specific response to this question Question. 5 With relation to the above, JCMP strongly believes that the phrase “Category 1 fossils must first be 12. Museums offered to a UK accredited museums for a period of six months” needs to be re-worked. With relation partnership to the cost of a significant fossil it would take more than six months from the formal identification of a find (not its initial discovery) to prepare and submit a bid to HLFSW and possibly longer if approaching other grant-giving trusts. Whilst respecting the Collectors’ economic imperatives, JCMP feels a less time constrained clause, perhaps relating to ‘a serious expression of interest from an Accredited museum’ needs to be inserted. 13. Bob Davidson No specific response to this question 14. Dorset GA No specific response to this question 15. Sheila Alderman/ No specific response to this question Wessex OUGS 16. Claire James No specific response to this question Question. 5 Would like these a little wider – important specimens could slip through the net at present. 17. John Wright 18. Chris King Separate response 19. Roger Vaughan No specific response to this question 20. Mike Simms No specific response to this question 21. Ian West No specific response to this question

29 22. Charmouth No specific response to this question Parish Council 23. Mike Taylor No specific response to this question Question. 5 I think I could do a better job of defining the echinoderms. I thought I’d done a rewrite but maybe that 24. Tim Ewin was it and if it is then I think I’d like to do it again! Question. 5 Yes 25. David Ward Question. 5 I have no issue with the existing categories. 26. Colin Macfayden 27. Neil Ellis No response Question. 5 The categories used in the current West Dorset Fossil Code reflect the interests of collectors and not Not so; the criteria were originally 28. Kevin Page science, as previously discussed. A scientifically based categorisation and guide for conservation is, drawn up in consultation with the therefore, absolutely essential to ensure that UNESCO’s principles for WH listing are maintained – scientific community and they such a categorisation has been produced by the Geoconservation working Group of the ISJS and first actually reflect the Geological published in 2002 (Third Circular for the 6th International Symposium on the Jurassic System, Conservation Review sites; the scientific assessment of the site. Mondello, Sicilly, Italy (September 12-22) (MARTIRE, L. ed.) ) and later in 2004 (Rivista Italiana di Paleontologia e Stratigrafia 110, 373-379 (2004). It is recommended that this classification and recommended mechanisms are adopted in Dorset:

Category 1: Specimens of typological importance for the definition of fossil species as regulated by the International Commission on Zoological Nomenclature (a UNESCO project), including holotypes, lectotypes, neotypes and syntypes. • Every type specimen is a global reference for the species it defines, it is therefore irreplaceable. The type specimen of even the smallest oyster species is more important, in heritage protection terms, than a skeleton of a large dinosaur, if the latter has no typological significance. • Scientific method therefore dictates that all Category 1 fossils must be deposited and protected in nationally recognised scientific and cultural institutions and legal systems should aim to achieve such ends. • Specimens only become types, however, after scientific study, which can only be facilitated by free and open access to palaeontological localities for bone fide geological study. • Legal systems should on the one hand ensure that such access can take place and on the other hand seek to guarantee that institutional deposition and full protection of the relevant specimens is achieved once study is completed.

30 Category 2: Specimens figured or cited in scientific papers or unique, rare or exceptionally complete specimens or assemblages of specimens of fundamental importance to actual or future scientific studies. • Specimens belonging to Category 2 are fundamental to the science of palaeontology, both as the evidence for published studies and as the raw material for ongoing or future studies. • Conservation and legal systems or practice should, therefore, ensure, including through the use of expert advisors or assessors, that such specimens are deposited and protected within nationally recognised institutions, where they will remain accessible for future study and appreciation.

Category 3: Key specimens of stratigraphical or palaeobiological significance, material complementary to ongoing scientific studies, specimens of especial suitability for museum display or educational use, by virtue of completeness or other features of instructive value. • Category 3 specimens are not only important for ongoing scientific research, they are also important for scientific education. They would include rare records of important taxa better known at other localities and assemblages of ecological or stratigraphical importance in place in natural outcrops. Specimens of high educational value are included, even if their research potential is more limited. • Conservation and legal systems or practice should aim, therefore, to promote the wise management of this resource by preventing the over-exploitation of Category 3 fossils and ensuring that the needs of educational and research are not prejudiced by activities such as commercial or unregulated recreational collecting. • Wherever possible, these procedures should encourage the deposition of Category 3 fossils in national or regional institutions, to maximize availability for future scientific study or educational use.

Category 4: Common and representative species and specimens, well represented in national museums and other institutions, or sufficiently abundant that any non-scientific collecting or removal will not prejudice future scientific work; specimens collected loose, for instance from scree, rubble or beach material, where the lack of stratigraphical information significantly reduces scientific use. • Such specimens can be very abundant, even rock-forming and may even become part of a commercial mineral resource, such as limestone or coal. The use of such specimens for teaching, public education and personal enjoyment provides opportunities to promote a respect and understanding for geological heritage, without prejudicing its long-term conservation. • Category 4 fossils do not normally require legal protection, especially when they lie outside of protected areas. It is therefore recommended that legal systems adopt a degree of flexibility to allow

31 more public experience of palaeontological heritage belonging to Category 4, but at the same time providing guarantees, guidelines and statutes to ensure that any new finds assignable to categories 2 and 3, or potential to Category 1, can be fully protected. • Categories 1-3 would be considered to be of “significant scientific importance” in the context of palaeontological heritage management with only Category 4 specimens considered to be as “not of significant scientific importance”. Question. 5 The recommendations of the Geoconservation Working Group of the ISJS which provide a scientific 29. ISJS context for the wise management of palaeontological heritage (first published electronically in the Third Circular for the 6th International Symposium on the Jurassic System, Mondello, Sicilly, Italy (September 12-22) (MARTIRE, L. ed.) (2002) and subsequently in Rivista Italiana di Paleontologia e Stratigrafia 110, 373-379 (2004). It is recommended that these principles are adopted in Dorset.

From here on this response duplicates the text in response 28 above starting with ‘Category 1: ....’ Question. 5 It seems that the categories are very linked up against collectors and the specimens themselves and As response 28 above 30. ProGEO perhaps lack links to scientific importance of stratigraphy etc. A better link to other systems such as commented by ISJS may be useful. Question. 5 The recommendations of the Geoconservation Working Group of the ISJS which provide a scientific 31. BIGC context for the wise management of palaeontological heritage (first published electronically in the Third Circular for the 6th International Symposium on the Jurassic System, Mondello, Sicilly, Italy (September 12-22) (MARTIRE, L. ed.) (2002) and subsequently in Rivista Italiana di Paleontologia e Stratigrafia 110, 373-379 (2004). It is recommended that these principles should be adopted in Dorset.

From here on this response duplicates the text in 28 above starting with ‘Category 1: ....’

Question 6: Quality of the records. Is the level of detail enough? Suggestions are welcome.

Question. 6 The records currently available are good as a record of what is found, but unfortunately in most cases 1. Ben Brookes no meta-data is available. For example I undertook a study of the Blue Lias’ Macroecology as part of my Masters Dissertation at the University of Southampton. This required me to obtain body length measurements of fossil vertebrates collected from the coast. In the case of the Fossil Code the lack of meta-data (measurements taken from the fossils and included in the records) and the fact that most of the photographs associated with the vertebrate records included no usable reference scales meant that without access to the fossils themselves (which I did not have due to time constraints) I could not

32 conduct a full survey of the collected specimens.

I would suggest two things could be done to vastly improve the quality of the records. Firstly the inclusion of a usable scale on all photographs associated with records even if this is only a simple geologist’s grain-size card with ruler as available from any geologist’s supply website for a few pounds.

Secondly, if it is at all possible to do so, optional fields could be added to the reporting system to allow collectors/reporters to add descriptive measurements to the record (for example, body or total lengths or lengths of individual bones in vertebrates). I would think that given that many collectors are professionals with knowledge of the anatomy of the animals they are collecting, such meta-data would be easy to include. Question. 6 Can current depository of specimens be recorded? e.g. ‘The x collection’, sold to ‘Y’? 2. Nigel Trewin Question. 6 No. More info. and photos please. 3. Paul de la Salle Question. 6 It would be useful to keep lists up to date to know ownership of specimens in private hands. It might 4. Paul Barrett also be useful to know the authority that made the identification. 5. Mark Bradley No answer to this question Question. 6 Insects: no, except where identified at least to ordinal level by a relevant specialist. I’ll happily make 6. Rob Coram myself available for this, being actively involved in Mesozoic insect research, and being conveniently ‘local’. If the collector is agreeable, I could also borrow the specimens to take some decent photos for everyone’s records. Some more basic information on locality/horizon would be useful in many cases. Is lobster claw 101 from Lias or Greensand? Echinoid 63 could be from anywhere. The academic community should offer its services with regard to identifying specimens, assessing their scientific importance and establishing their likely provenance; it is certainly too much to expect whoever is entering and collating the records to be an expert on all fossil groups. Academics should make it clear that they themselves take the recording scheme seriously and are genuinely appreciative of collectors who have made their specimens available for scientific scrutiny through recording them. This will probably seem like nit-picking, but bad spelling and grammar will lower the credibility of the records and should be minimised. E.g. ‘visable’ should be spelt ‘visible’. Question. 6 I have not seen the full database. However, following the comments above, I am inclined to suggest 7. Chris Paul that gathering more information about the occurrences of even the common fossils is important. It may

33 be that such a scheme should be run in addition to, rather than as part of, the current scheme. 8. Paul Saxon No comments Question. 6 Yes – but please continue to keep it simple 9. Alan Lord Question. 6 • An OS National Grid reference should also be recorded, BUT should not be generally available 10. Tony Holmes unless needed for scientific research. This could in the longer term be used, as supplementary information, to monitor beach erosion rates • If a fossil is completely extracted from the surrounding stone a brief description of the matrix should be included or preferably named (if possible) 11. Simon Ford No specific comments 12. Museums No specific comments partnership 13. Bob Davidson No specific comments 14. Dorset GA No specific comments 15. Sheila Alderman/ No specific comments Wessex OUGS 16. Claire James No specific comments Question. 6 If the specimen is judged Category 1, it says the specimen will be photographed. Where are the photos? 17. John Wright - I couldn’t find them on the Charmouth web site. Question. 6 Extracted from letter: Better quality records are required 18. Chris King 19. Roger Vaughan No specific comments 20. Mike Simms No specific comments 21. Ian West No specific comments 22. Charmouth No specific comments Parish Council 23. Mike Taylor No specific comments Question. 6 The more information the better and specimens without locality or stratigraphical information become 24. Tim Ewin significantly reduced in their usefulness. I worry that this information is being withheld owing to the need for the collectors to keep localities secret whilst they wait for other pieces to become exposed. This information, as said above, could be kept secret for an amount of time before appearing on the publically accessible list. Question. 6 Inadequate level of detail in records

34 25. David Ward 26. Colin Macfayden No specific comments 27. Neil Ellis No specific comments Question. 6 No – the records have generally been made by amateurs and fossil collectors without or with minimal 28. Kevin Page scientific knowledge – as such they generally state incomplete or inaccurate stratigraphical, taxonomical and locality information. Proper scientific input is, therefore, essential at all levels, from categories for recording and conservation measures to identification! Question. 6 No – the records have not been scientifically reviewed and are often incomplete or potentially 29. ISJS inaccurate. In addition, the failure if the Code to record many types of specimen means that the listings are of limited use, except perhaps to vertebrate palaeontologists, as the recording of such specimens is better promoted by the Code.

Question. 6 No specific comments 30. ProGEO Question. 6 No – the records have not been scientifically reviewed and are often incomplete or potentially 31. BIGC inaccurate. In addition, the failure of the Code to record many types of specimen means that the listings are of limited use, except perhaps to vertebrate palaeontologists, as the recording of such specimens is better promoted by the Code.

Question 7. Awareness of the code. Have you used the recording scheme? Are you aware of it? Comments are welcome.

1. Ben Brookes YES. I have used the records as part of my Masters Dissertation at university (see Question 6) but have yet to find anything worthy of recording in my personal amateur fossil collecting. 2. Nigel Trewin I have not used the recording scheme since I have not been to Dorset recently (or found anything worth recording) 3. Paul de la Salle No/yes. Nothing significant found since the scheme was running. 4. Paul Barrett YES. I’m aware of the scheme, but haven’t collected from the coast so haven’t used it. 5. Mark Bradley No specific comments Question. 7 Haven’t used the scheme, since vast bulk of interesting stuff, mostly insect, comes from Monmouth Question. 7 Beach (presently not covered by scheme). I have an independent photographic record of this material- 6. Rob Coram several hundred specimens- which I’ll be pleased to forward to academically interested parties.

35 Question. 7 I haven’t personally used the recording scheme because I don’t actually do much collecting and so far 7. Chris Paul haven’t found any category 1 or 2 fossils. I am broadly aware of the code. Question. 7 No specific comments 8. Paul Saxon Question. 7 I have not used the scheme (being a micropalaeontologist) but am aware of it 9. Alan Lord Question. 7 Have you used the recording scheme? We will look into this question. 10. Tony Holmes • Yes, but some years ago I found that staff did not recognise the importance of some fossils Some specimens were and therefore not making records reassessed as not of category 1 • I was surprised that fossils that I had listed and photographed are no longer on the list! I will or 2. have to have to enter them again Are you aware of it? Yes, but cannot view the records over the internet as hyper links are not obvious. 11. Simon Ford No specific comments 12. Museums No specific comments partnership 13. Bob Davidson No specific comments 14. Dorset GA No specific comments 15. Sheila Alderman/ No specific comments Wessex OUGS 16. Claire James No specific comments Question. 7 My understanding of the present scheme is that persons finding good fossils are encouraged to take 17. John Wright them along to the Charmouth Centre, where they are identified and assessed. Do people know about the Scheme? – I didn’t, though admittedly it doesn’t affect my research much, as I work in East Dorset. The Scheme should be much better publicised, and the existence of the List on the Charmouth web site needs to be much more widely known - ?via the Heritage Coast Newsletter, etc. 18. Chris King No specific comments 19. Roger Vaughan No specific comments 20. Mike Simms No specific comments 21. Ian West No specific comments 22. Charmouth No specific comments Parish Council 23. Mike Taylor No specific comments Question. 7 Yes, I have looked at it and it is better than nothing. If the review does nothing other than maintain the

36 24. Tim Ewin status quo then this is preferable. I do feel however that there is insufficient impetus for important specimens getting into museums. My feeling is that the collectors have it very very good at the moment. They collect what they like, they sell to who they like at a price they demand. I feel that there are some exemplar collectors along the coast however, the key specimens are still not being made available to public bodies. Too often the “art market” is used as an example as to how culture is dealt with, however I would like us to use the archaeology model of dealing with objects that are recovered from the ground as this is much closer to the scenarios we face in Palaeontology. Question. 7 Perhaps more publicity is needed. Paid beach wardens education visitors and keeping an eye on 25. David Ward professional collectors akin to a village bobby. Question. 7 No 26. Colin Macfayden 27. Neil Ellis No specific comments Question. 7 Yes – but see above[question 6]; information recorded is generally too vague or incomplete to be 28. Kevin Page useful and as specimens have no guaranteed institutional future, they cannot be used for most palaeontological research, in particular taxonomical (it is a requirement for most scientific journals that cited specimens are deposited in an appropriate institution an available for others to study). Question. 7 Yes – but see above[response to question 5]. Scientific review / input essential. 29. ISJS Question. 7 No specific comments 30. ProGEO Question. 7 Yes – but see above. [question 6] Scientific review / input is essential. 31. BIGC

Any other comments

1. Ben Brookes No other comments 2. Nigel Trewin I chaired the SNH committee that produced the Scottish Fossil Code for the Scottish Government. That code has a broader remit than yours, but we agree on the basic philosophy. I will probably be visiting the Dorset Coast for a few days in September. Happy to chat about experiences if you think it would be of use. 3. Paul de la Salle The current regime has been working well in terms of preserving and enabling significant fossils to be studied for several hundred years. “if it aint broke don’t fix it”. A more interventionist approach will a) lead to less fossils being found, reported and studied b) spoil peoples’ enjoyment of fossil hunting.

37 4. Paul Barrett No other comments 5. Mark Bradley No other comments 6. Rob Coram 1. Following on from above, can the code and scheme be expanded to include the coast up to Pinhay Bay? I know this is technically East Devon rather than West Dorset, but it still seems somewhat arbitrary to include, say, the Blue Lias east of Lyme, but not the more extensive exposures just to the west. 2. Could there also be a voluntary recording scheme that includes the whole Jurassic Coast? There is, for example, interesting vertebrate material turning up quite regularly from the Otter Sandstone, Kimmeridge Clay and Purbeck beds, and if even only some of this was recorded and listed in some way, it would be very useful information. 3. Would it be possible to invite researchers to submit details of any newly published papers dealing with the geology of the Jurassic Coast? A periodically updated bibliography would be an invaluable guide to what’s going on research-wise and also help emphasise the on-going scientific importance of the coast. 7. Chris Paul No other comments 8. Paul Saxon No other comments 9. Alan Lord No other comments 10. Tony Holmes No other comments 11. Simon Ford No other comments 12. Museums Response appended in the next section of the document partnership 13. Bob Davidson No other comments 14. Dorset GA No other comments 15. Sheila Alderman/ No other comments Wessex OUGS 16. Claire James 17. John Wright No other comments 18. Chris King Response appended in the next section of the document 19. Roger Vaughan No other comments 20. Mike Simms No other comments 21. Ian West The present scheme seems satisfactory. No need for any change. 22. Charmouth No other comments

38 Parish Council 23. Mike Taylor No other comments 24. Tim Ewin I also think that important specimens not being made available to museums is not a problem restricted The ichthyosaur (record No. 4) to Dorset. I think that this should be made a national scheme. This would have enormous benefits for was one of two new species the science as it would encourage the heritage sector to provide resources to preserve and develop our found by a collector (the first Palaeontological heritage. I do not however want to alienate the collectors or drive their activities pre-code) and it was agreed underground. They make a fantastic contribution (as do metal detectorists) so long as they act or are between the Royal Ontario forced to act responsibly. I was surprised to see that a new species of ichthyosaur was sold to a Museum and the Natural Canadian institute – was this specimen offered to a UK museum? If not then why not? History Museum that they would acquire one each. Record 4 went to the ROM. 25. David Ward 26. Colin Macfayden If a specimen of outstanding importance is eroded from a cliff and becomes part of a private collection, despite all efforts to accession within an Accredited collection, it may be suggested that this is preferable to the specimen being abandoned to erosion. At least as part of a private collection, there is a chance the specimen in due course ending up in an Accredited museum. 27. Neil Ellis A couple of little things maybe: if there has been a storm and landslide, perhaps the event should be recorded and linked to new finds (so proving the no-intervention against erosion tactic is best for the Site). And maybe there should be some monitoring of fossil trade (to prove the commercial value of the specimens coming from the Site, and thereby demonstrating its value in sustaining a local trade/community). 28. Kevin Page Bibliography/references

PAGE, K.N. 2002. Geoconservation Working Group: proposed statement on the conservation of palaeontological heritage and stratotypes. In: MARTIRE, L. (ed.), 6th International Symposium on the Jurassic System, Mondello, Sicilly, Italy (September 12-22, 2002): Third Circular. International Subcommission on Jurassic Stratigraphy: Appendix (electronically published).

PAGE, K.N. 2004. The protection of Jurassic sites and fossils: challenges for global Jurassic science. Rivista Italiana di Paleontologia e Stratigrafia 110: 373-379.

PAGE, K.N. 2005. Reconciling science and heritage protection: Recommendations from the Geoconservation Working Group of the International Subcommission on Jurassic Stratigraphy In: Hanzo, M. (coord.), Colloque Hettangien à Hettange, de la science au patrimoine, Hettange, 1-3 avril

39 2005: 129-123. Unversité Henri Poncaré, Nancy. PAGE, K.N. 2006. Report of the Geoconservation Working Group. International Subcommission on Jurassic Stratigraphy, Newsletter 33: 21-25 (electronically published).

PAGE, K.N. 2008. Report of the Geoconservation Working Group. International Subcommission on Jurassic Stratigraphy, Newsletter (electronically published).

PAGE, K.N. and WIMBLEDON, W.A. 2009. The conservation of Jurassic heritage in the UK – a critical review of current practice and effectiveness. Volumina Jurassica 6: 163-173.

PAGE, K. 2010. World Heritage ‘For Sale’ – state supported trade in global palaeontological heritage in Dorset, UK – and its consequences. (Abstract). In: Mügge-Bartolovíc, V., Röhling, H.-G. and Wrede, V. (eds), Geotop 2010: geosites for the Public, Palaeontology and the Conservation of Geosites. Schriftenreihe der Deutschen Gesellschahft für geowissen schaften 66: 29. ISJS Identical to response 28 above 30. ProGEO ProGEO considers that, as a unique World Heritage Site (WHS), the Geoheritage and the Geoconservation of the Jurassic Coast must be in the forefront when developing its management strategies. As an international site, it is also clear that the management of this unique World Heritage site is of international interest. It is therefore reasonable to express content over the open process to collect opinions about the code. ProGEO have received the comments issued by the International Subcommission for Jurasic Stratigraphy (ISJS) of the International Union of Geological Sciences and have on this basis some general remarks that we think are of great importance. Many of the questions in the questionnaire are very detailed and it is difficult for ProGEO as an European Association to answer them specifically. We have therefor made our comments more general. Our comments do not necessarily mean that these aspect are forgotten in the code, but it important never the less to highlight the principles necessary to develop a sustainable management of such an unique heritage.

To achieve the necessary level of geoheritage conservation and management, it is important to take into account recent advances in the philosophy and practice of this heritage such as the Council of Europe’s ‘Recommendation on Conservation of the Geological Heritage and areas of Special Geological Interest’ and the International Union for the Conservation of Nature’s Motion CGR4.MOT055 on the Conservation of geodiversity and geological heritage. It is also interesting to note that the principles under which UNESCO Geoparks are managed goes far in establishing quite different principles concerning geoheritage management and put up central management questions for

40 relevant discussions also for a WHS.

ProGEO continued However much local or national authorities want to support collectors and an established collecting tradition, the point must be to see that when the scientific loss is greater than the gain, management does not function effectively. We want to stress two things about the outcome of the management of the area. It must reflect the principles, intentions and decisions of a WHS. The effective management must be a consequence of the decision to designate the area as a WHS. We feel that there should be a short and very clear statement that the aim of the WH site's management is the conservation of the site and its scientific materials, and that this aim should always involve consideration of scientific and heritage gain first, before any individual's or group's financial gain. Plans on management must be pro-active to include collectors in the process to conform to the principles of WHS management. We appreciate the problem of locally sensitive issues, but such issues should not override this main principle. 31. BIGC Reference PAGE, K.N . and WIMBLEDON, W.A. 2009. The conservation of Jurassic heritage in the UK – a critical review of current practice and effectiveness. Volumina Jurassica 6: 163-173.

Responses outside the questionnaire Response number 5. I think the Dorset code is a great piece of work. Something lacking in Yorkshire! Mark Bradley I came down to Dorset a couple of years ago to look at the code in practice and meet some of the folk Coast & Countryside that seemingly made it work. Manager North York The meeting was based around Charmouth and included NT staff, councils and collectors. Moors, Coast & Your survey raises the question of whether the code is flawed. From a laymen's take on it, what I saw Durham properties, on my visit and through discussion, I though it was quite inspiring with everyone signed up to it. National Trust I would be very interested in the outcome as to whether the various interested parties do believe it is working. We in the Yorkshire region need a similar resource if only to be able to record what fossils are being taken, but it would be great to create a team of joined up thinkers from all interested parties as in the Dorset programme. I have asked my staff to comment also, given their position at the coal face as it were, dealing with the public, fossil collectors etc. but with little structure in Yorkshire to compare, their initial feelings are that your code is a way forward that we should be following. I would much appreciate any

41 updates/comments on the outcome. Response 12. Present Mary Godwin, Dr Stephen Locke, Chris Andrews, Paddy Howe (All Lyme Regis Museum), Dr Jurassic Coast Jenny Cripps (Dorset County Museum), Emily Hicks (Bridport Museum), Dr Bob Symes (Sidmouth Museum Partnership Museum), David Tucker (Dorset County Museums Adviser). David Tucker, Coordinator, Jurassic The Jurassic Coast Museums Partnership would firstly like to thank Richard Edmonds, Earth Science Coast Museums Manager for the Jurassic Coast and Dr Vince May, Chair of the Science and Conservation Advisory Partnership Group for inviting us to participate in the review of this valuable and timely document. The observations made below by the Jurassic Coast Museums Partnership (JCMP) refer to both specific issues raised within the document and where relevant, the wider strategic issues it raises.

Page 3 Para 4. The feeling of the JCMP was that the word ‘local’ should be inserted into the phrase “Should be offered to local Accredited museums”. The JCMP fully recognises that there are issues relating to finance, collections care, display and expertise that arise from this statement and that a degree of flexibility will always be necessary.

Page 3 Para 5 The JCMP acknowledges that the system of fossil collection, dependent on the actions of the collectors is the most effective system of ensuring that fossils are collected. As a group the JCMP acknowledges that from a museums perspective sanctioning a system that could be loosely described as ‘finders, keepers’ may be counter-intuitive, but the JCMP also recognises the reality of a rapidly eroding coast. JCMP also recognises that the current code is largely dependent on the maintenance of a ‘gentlemen’s’ agreement’ and it is essential that lines of communication are kept open with the collectors, not just between collectors and the Earth Science Manager, but also between collectors and other interested parties.

Acknowledgement of the Key Role of Collectors The JCMP is very pleased to note that so many of the local collectors wish nothing other than to see their discoveries on display within museums, either by purchase or donation. JCMP applauds the public-spirited stance taken by the local collectors.

Page 3 Para 6 The JCMP does not feel there is a significant problem with less than 15% of fossils recorded as having

42 ‘key scientific importance’ being located within Accredited museums. Accepting comparisons are inaccurate, museums as a body accept that many works of fine art (for example) reside in other forms of ownership.

Record of Discoveries Indeed, the JCMP believes the essential point is not necessarily ownership of fossils, but that discoveries are recorded, identified and traced. There is a current concern that this is not happening to the extent it perhaps should do. JCMP suggests that the existing Jurassic Coast website is used to make data about recent finds available with images, enabling the global palaeontological community to access this material. The maintenance of a database at Charmouth Heritage Centre does not currently seem to resolve the issue and that more resources need to be channelled into this area.

Wider Dissemination of the key Messages of the Code to the General Public Related to this, JCMP also believes that if the Code is to be strengthened more work needs to be done to publicise the Code, not just with collectors and landowners, but also with the wider public. It is not necessarily a logical position to expect visitors to the Jurassic Coast to appreciate that they are able to collect and that the wider dissemination of the fascinating principles that underpin the Code would be of great educational value. In general, the JCMP feel that the existence of the Jurassic Coast website and the benefits the internet brings are a tool that might be better exploited.

The Process of Ensuring Significant Fossils reach Accredited Museums JCMP applauds the emphasis placed on the depositing of significant Jurassic Coast fossils in Accredited museums. However, JCMP recognises that irrespective of where the Accredited museum is located, there are serious capacity issues. On the Jurassic Coast many local museums have severe storage and display issues and there is (within museums themselves) a lack of geologists able to commit the significant time the subject deserves. Although the dislocation between the discovery of fossils and their display in local museums is perhaps beyond the core purpose of a review of the Fossil Code, JCMP is grateful that it is acknowledged within the document and would request this dislocation is made even more apparent in future documents.

Page 6: 4. The Core of the Code, bullet 3. The JCMP are very pleased to see that the Code recognises that Accredited museums should have the first opportunity to acquire specimens of ‘Key Scientific Importance’. As emphasised above, there is a concern that this statement potentially disguises a whole range of issues related to funds and capacity.

Page 6: The Core of the Code, bullet 6. With relation to the above, JCMP strongly believes that the phrase “Category 1 fossils must first be offered to a UK accredited museums for a period of six months” needs to be re-worked. With relation to the cost of a significant fossil it would take more than six months from the formal identification of a find (not its initial discovery) to prepare and submit a bid to HLFSW and possibly longer if approaching other grant-giving trusts. Whilst respecting the Collectors’ economic imperatives, JCMP feels a less time constrained clause, perhaps relating to ‘a serious expression of interest from an Accredited museum’ needs to be inserted.

Landownership The JCMP applauds the generosity and support of those landowners who have chosen to allow collecting on their land by collectors following the Code. The JCMP noted with some concern that the experience of the acquisition of the pliosaur (outside of West Dorset) did not follow this laudable model and that within West Dorset the Crown Estate have recognised the potential revenue stream that fossil discoveries offers.

The Relationship with Academics The JCMP notes that there is sometimes a feeling of disappointment amongst collectors that university and museum based academics are very often unable to respond immediately to potentially significant finds. The JCMP recognises that this is a problem that is common across science. To this end (as identified above) JCMP believes the use of ICT to research, record and track finds is essential. Although beyond the scope of this study, there is a clear challenge here to researching institutions and their attitude to collections held by private individuals. If museums acknowledge their inability to purchase and collect to the level that they would like to, it follows that universities and research based museums accept that they may need to work with a wider set of interests (a fine local example being the collection held, stored and conserved by Steve Etches).

Other Geological Specimens Recognising the pre-eminence of Dr Symes within the world of mineralogy, the JCMP would suggest that the Code is covered to identify the collection of minerals of scientific importance. It was recognised that this is more likely to be an issue in East Devon, but that this area too is part of the Jurassic Coast with its own fascinating and unique geological stories.

44 Page 17 Para 3. The review document is now Particular concern was raised by JCMP concerning the content of this paragraph and its referral to published so this amendment proposed developments at Lyme Regis or other sites as well as the general issue of the future collection cannot be made. The paragraph and display of fossils. The strong feeling was that as this does not specifically relate to the Code, and was simply attempting to that because there is a multiplicity of views as to how this major issue be tackled, that it is deleted from explore the issues which the document. include a diversity of views as to the best option for a fossil Conclusion museum/display. The JCMP thanks the Science and Conservation Advisory Group for the opportunity to comment on this process and wishes to emphasise that it is very enthusiastic to work with the full range of partners to address the issues raised within the document, irrespective of whether they relate specifically to the Code or to the wider strategic issues. 13. Claire James I have had a chance to review the Fossil Code. As the Devon CLA Rep it obviously does not affect our Clinton Devon members, however I think on a general note there are a couple of issues that need to be reflected in the Estate code, which I am sure James [Weld] can provide more detail on as the Dorset Rep. My concerns would be that of controlled access and insurance to ensure that landowner liability is not compromised. It is also essential that landowners are part of the whole process if a valuable fossil is found or one where extensive work is required. As I stated not me field of expertise but these issues need to be looked at in relation to public access. 18. Dr. C. King The ‘boxes’ for answers and the questions don’t permit a full reponse, so I have added these comments separately. Also, please note that the questions often include an either/or which cannot be answered by a yes/no response!

My standpoint: I’m a locally resident professional geologist, with research interests in the biostratigraphy and lithostratigraphy of the Lower Lias. I’m fairly familiar with much of the local geology, literature and collecting conditions, and the activities of commecial collectors.

As I see it, the procedures in the fossil code can be divided into sequential stages. So I’m discussing each in turn, commenting on their relationship to the objectives of the Code.

Stage 1: Pre-collection. The code is primarily aimed at Public awareness: Are casual visitors, amateur collectors and professional geologists aware of the Code the local collectors. Indeed ? there is some confusion because I cannot comment as a whole, but here cite two examples: there is a more general ‘code’

45 In the recently published ‘Lower Lias Fossils’ Pal Ass Guide, there is a whole chapter on the WHSite, for everyone (along the lines of but the Collecting Code is only mentioned on the last line, with a reference to the Jurassic Coast the GA code) and then the more website. This is quite amazing, considering that this book is intended to a significant degree for those detailed code, much of which collecting fossils !. This is an opportunity missed. largely applies to collectors However on going to the Jurassic Coast website, there is no explicit section on the Collecting Code. On who know what they are doing. inputting ‘Fossil Code’ ‘Beach safety and the Fossil Code’ is link No. 17, and it is necessary to go thru another two links to actually find the full Collecting Code !.

Recommendation: All practical measures should be taken to ensure that casual visitors and amateur collectors understand that collecting is a privilege, not a right, and that in response to that privilege they have the responsibility to observe the Code and report unusual finds. Information explaining the code and illustrating kinds of rare fossils and what to do with them could be made more widely available (e.g. a sign at Charmouth beach: ‘Do you know the collecting code: get a leaflet at the Heritage centre’). Are existing leaflets adequate and explicit in this respect?

The collecting Code needs to be more visible and more explicit both in the geological community generally (amateur and professional), both in the UK and elsewhere. A mid-level version of the code, on a website and in leaflet form, illustrating key fossil types, emphasising the restrictions on collecting, and encouraging donating, needs to be readily available.

Stage 2: Collection: We have two categories here: ex situ and in-situ collecting.

Ex situ collecting We have to start from the point that collecting would not normally be permitted at all, or only under stringent conditions, from a World Heritage Site. From this point of view, any collecting is a privilege which should not be abused and which cannot be taken for granted.

However, from a practical point of view ex situ collecting is important for several reasons:

1. It is good for the tourist industry 2. It is likely to encourage some young visitors to become geologists (or associated professions) 3. Specimens would otherwise be destroyed by erosion

46 4. Most of the specimens are of well-known species and their collection by private individuals does no harm 5. Rare forms are flagged up by the Fossil Code and the Heritage Centre and if collectors are made aware of these categories they are likely to be brought to the attention of the Centre. 6. Commercial collectors are well aware of the categories and will (presumably) bring them to the Centre’s attention.

Two key factors are important here: : All those collecting should be aware of the Code (see Stage 1 above) : Commercial collectors should observe the Code. I cannot comment on the level of observance, as I have no personal knowledge of this aspect, but from the Heritage Site reports, it seems to be good. I guess that responsible commercial collectors would probably report others breaking the rules !. : In situ collecting A contentious issue. Does this impede scientific research ? Probably not..the number of professional palaeontologists collecting here is relatively limited, and in most cases material would be lost to erosion before any came along. As a researcher collecting ammonites in situ (mostly from the beach platform, not from the Flatstones, I have to say !) I have no problem with this. It is certainly much preferable for ‘professional’ (essentially commercial) collectors to be permitted to extract fragile vertebrate specimens, likely to be damaged by casual collectors.

However: stratigraphic context.

I emphasise the importance of ensuring accurate location of in situ specimens. It is well-known that almost no older museum specimens of vertebrates have adequate stratigraphic context. And I note that the recorded in-situ specimens mostly don’t seem to have any information. One aspect where the recent ‘Lower Lias Fossils’ fell down badly, in my opinion, was the almost total absence of any lithostratigraphic context for those unfamiliar with the section, with no way to record finds accurately ! For ammonites, this is essential.

The role of commercial collectors: Commercial collectors have a key role: : They are the most likely to find rare specimens and recognise them from fragments or limited exposure

47 : They are the most likely to collect them and prepare them without damage

But they also have the responsibility: : to report them : to record and report the location and stratigraphic position of in situ material.

Recommendation: It is important that commercial collectors are encouraged to record in situ occurrences adequately, and also to collect, report and donate fragmentary or damaged specimens, with no commercial value, if they are of rare or unusual species.

Stage 3: Preparation and conservation A rare specimen can be rendered useless by poor treatment, either at the point of collection or later. There is no doubt that commercial collectors and preparators are the best for this.

Stage 4: Reporting and documentation What happens when casual or amateur collectors bring specimens into the Centre ? Is there an effective mechanism for reporting and documentation ? Recommendations: In view of the proportion of specimens disappearing into private collections, I would strongly recommend that a (high-resolution) photographic record should be made of all recorded specimens, accessible via a dedicated website along with other relevant details. This should be publicised to the palaeontological community. This would provide a permanent record and enable relevant specialists access to the specimens..and in all probability increase the proportion of specimens ending up in museums.

Allied to this, I would encourage commercial collectors to provide images of relatively common species to add to a website. Documentation of the fossils is still relatively limited..its possible to easily find photos on commercial websites of specimens much better preseved than those in ‘official’ publications. A recent example of this is the rather dilapidated ammonites in the ‘Lower Lias Fossils’ publication. In some cases, I could collect better specimens myself in an hour or two…

Also, there is very limited documentation of the knowledge and information gained recently, particularly by some professional collectors. I note a coment in the SCAN report about exceptional new information from a slip in the Shales with Beef. What is this ? Will it be documented ? And what of the knowledge on the nodule levels in the Black Ven Marls and their contents ? None of this is in the

48 public domain. Is it a trade secret ? Its really hardly acceptable to have the last detailed record of parts of the sections dating largely from the 1920s. How about a proper stratigraphic report useful for both collectors and the scientific community. ‘That everyone has access to information about what is being found’ is a key aspect of the Code. Im not sure it is fully achieved..

Stage 5: Final destination of specimens

Relatively few specimens seem to find their way into a permanent and publicly accessible collection. This is of course partly a question of funding, partly because some major museums probably think that yet another ichthyosaur is not necessary for their collections !

However I (and I would suspect most professional palaeontologists) would think that it is entirely inappropriate that specimens collected from a WHS, registered as such and regarded as of some scientific importance, should simply disappear into private hands.

Recommendations: At the very least, the ultimate owner should be recorded as a requirement for sale of material, this information to be kept as part of the recording scheme, and documentation required to be sent with the specimen, including suggestion for ultimate donation to a permanent institution.

The recording scheme should be beefed up as recommended above. I have no inside knowledge of the situation, but it seems to me amazing that the relevant authorities have been unable to agree a site and funding for a dedicated Jurassic Coast Museum. With the Olympics coming up, a major opportunity has been missed. The new displays in regional museums are a great step forwards, but the region badly needs somewhere modern where there is adequate space to display the full range of fossils. This would be an ideal place for the display of recently collected recorded specimens and a showcase for the commercial collectors, as well as a major tourist attraction. And should include (eventually) comprehensive fossil collections of the region which could be used by specialists.

I hope the above is helpful, please let me know if there are any questions arising from these points. 19. Roger Vaughn, Bristol Museums, Galleries & Archives – Acquisition & Disposal Policy 2010

5.11 Geology

Existing Collection

5.11.1 The Geology section holds approximately half a million rock, mineral and fossil specimens, mainly collected from the Cambrian to Cretaceous and Pleistocene strata of the Bristol region, with significant comparative material from elsewhere in the British Isles and the rest of the world. The collections are Designated in their own right.

5.11.2 The collections were founded in 1823 (Bristol Institution) although a public collection of geological material in the city began with the bequest of the Catcott Cabinet in 1775. Other components, such as the collection of G W Braikenridge, date from the end of the eighteenth century.

5.11.3 The Curators of the museum during the nineteenth and early twentieth centuries were all geologists of note:

• J S Miller, author of perhaps the earliest palaeontological monograph (1821). • Samuel Stutchbury, geologist and naturalist • Robert Etheridge, later palaeontologist to the Geological Survey of Great Britain and Keeper of Geology at the British Museum.

• William Sanders, pioneer in large-scale geological mapping. • W J Sollas, successively Professor of Geology at Bristol, Trinity College Dublin and Oxford University. • E B Tawney, subsequently Curator of the Sedgwick Museum, University of Cambridge. • Edward Wilson, Jurassic stratigrapher and palaeontologist. • Herbert Bolton, Coal Measures invertebrates. • F S Wallis, President of the Museums Association.

5.11.4 The strengths of the collection lie in Lower Palaeozoic fossils from the Tortworth inlier, Carboniferous fossils from Bristol and the Mendip Hills, Coal Measures insects and arachnids (possibly the largest collections in the world of some groups), late Triassic vertebrates from Bristol, the Mendip Hills, Sidmouth and especially of the Severn Estuary, Jurassic marine vertebrates from Somerset, Wiltshire and Dorset, large holdings of Jurassic invertebrates from the south-west in general, Pleistocene bones from cave sites in Bristol and the Mendips, minerals of Bristol and the Mendip Hills

50 with large holdings of minerals from Devon and Cornwall. Large collections have been made from temporary exposures, many in areas were no exposure had been previously or subsequently available.

5.11.5 The collections were developed by some of the leading figures of geological science such as W D Conybeare, J S Miller, W Buckland, S Stuchbury and H T De la Beche and later palaeontologists like S S Buckman and J W Tutcher. They provide the most comprehensive and detailed material evidence for the geological and biological evolution of the south-west within the region.

5.11.6 The section holds numerous collections of international standing. The largest are those of J Chaning Pearce, J W Tutcher and T R Fry which provide a regionally important reference material for the Jurassic of the South-West. Over the last few years the Department has received internationally important collections of Jurassic fossils from Dr Hugh Torrens, Mr Simon Carpenter and Dr Kevin Page for example.

5.11.7 The collections include approximately 700 recognised type, figured and cited specimens, some dating back to seminal monographs of the early nineteenth century (figures by Parkinson, the Sowerbys, Agassiz, J S Miller, Owen, Darwin, Kidston, J and SS Buckman, Arkell, Torrens). Other such specimens undoubtedly lie currently unrecognised amongst the collections.

Future Collecting in Geology:

5.11.8 Given its historic role as a regional centre, collecting will continue within the area formerly known as Avon and further afield into Gloucestershire, Somerset, Wiltshire, Dorset and Devon, given close collaboration with other relevant museum services. These other services holding significant geology collections are currently University of Bristol Earth Sciences Department, Gloucester City Museum & Art Gallery, North Somerset Museum Service, Somerset County Museum Service, Devizes Museum, Bath Royal Literary & Scientific Society Institution, Dorchester Museum, Dorset County Museum Service and Royal Albert Memorial Museum, Exeter although the majority of these services do not employ professional specialist staff.

5.11.9 Specific areas to bolster existing collections and areas of responsibility are listed below:

• Lower Palaeozoic of the Tortworth Inlier, S. Glos. • Carboniferous limestone of Bristol and the Mendips.

51 • Bristol region Triassic and Jurassic vertebrate fossils. • Bristol and Somerset Coal Measures fauna and flora. • Bristol region Pleistocene mammalia. • Bristol and Mendip minerals. • Jurassic fossils of the West of England in general. • Local and locally used building materials, industrial raw materials, products and waste, worked decorative stone and minerals, tools and abrasives. • Instruments, tools and ephemera relating to geologists, masons, quarrying and surveying. • Lithological samples and records from sites in the Bristol region [taken as the former county of Avon, Somerset, Gloucestershire, Wiltshire and Dorset]. • Specimens from Devon and Cornwall, especially minerals to complement the existing collection. • Non-local British material as individual specimens or small groups to complement the existing collection and illustrate general geological concepts. • Well documented historical orphan collections will be considered, in part or as a whole if more appropriate repositories are unwilling or unable to acquire them, provided they meet other criteria specified here. • Where appropriate, archives, photographs, ephemera and oral history relating to geologists, quarriers, stone masons and so on. • Non-British material as individual specimens or small groups to complement the existing collection and illustrate general geological concepts. • British and worldwide fine-quality pieces for display. • Extra-terrestrial: meteorites and samples from non-terrestrial sources, if available.

5.11.10 In addition, no material will be acquired which has been collected illegally in this country or abroad unless appropriate permission has been obtained from the relevant authorities.

5.11.11 Voucher specimens to complement geological records held by the Bristol Regional Environmental Records Centre (BRERC) will be encouraged or collected by staff.

5.11.12 Geological recording to complement the collections will be encouraged through the work of BRERC and the Avon RIGS (Regionally Important Geological & Geomorphological Sites) group.

5.11.13 Collecting will be active and passive and may include field work by Museum staff, contract

52 staff, students and volunteers, and also purchase.

5.11.14 Associated ephemera to place the collections and the local history of the study of geology in context will be acquired where appropriate. 21. Ian West Congratulations on your dealings and organisation of the great Pliosaur discovery! .

I am sending a reply by post to your Fossil Collecting Enquiry. In truth I am very happy with the present situation, although I am not a fossil collector now (I was when I was a boy, and was collecting vertebrates at Kimmeridge long ago). I do not really wish to see a change and I am very much in the middle ground. I am slightly concerned that the enquiry might lead to lead to heated debate amongst the people that have strong vested interests in the subject matter (in either direction) and very little response from other geologists. I do not want to see the devastation of fossil footprints, large ammonites and fossil trees (the people who do this actually provide support for strict conservationists); nor do I want to see harsh and restrictive fines and warnings that hinder research, enthusiasm and the gain in knowledge. I am sure that there are many middle ground like me; I am not sure that they will all respond to the questionaire.

I fear that some polarisation may arise as a result of the questionnaire, and hope that you can retain the sensible middle ground in terms of fossil collecting on the Jurassic Coast. All that has happened so far is very good and I am very happy with the Jurassic coast organisation and schemes and it has suited me and my website very well over almost a decade! 22. Charmouth I have been asked to make comments for the review of the Fossil Code on behalf of the Parish Council Parish Council However, I don’t think I or any other member of the Council are qualified to make comment on Mike Hendrick scientific issues relating to palaeontology or how best to resolve issues that have already been highlighted in the review.

• From a landowners perspective we still view the fossil code as a positive contribution to the management of the Heritage Coast (World Heritage Site). We never anticipated that the code would be perfect, that is what makes period reviews necessary.

• Of cause we are disappointed in the low acquisition by our national museums of key scientifically important specimens. Funding, it would appear for the foreseeable future, will be strained with the demand on resources, which contributes to the sale of such specimens to foreign or private bodies. Specimens in their possession may still yield valuable knowledge to the science but it does

53 unfortunately in some way make us complicit in the disposal of our Earth Heritage.

• It is gratifying that collectors make a number of donations and collectors are willing to continue this if the opportunities are right. We have a lot of sympathy with their vision for a museum to house a collection locally. To me a museum should be able to provide a history with local finds of the diverse species in the Palaeontology of this coast; at present no local museum has the space to demonstrate this.

• I may be naïve, but I have always assumed that experts on the varies species within the local palaeontology are already in situ to define the importance of the fossil and their finding projected within journals, papers and web to interested bodies who may be interested in acquisition. If that is not the case then this surely needs to be done, and recording should be as accurate as possible. I think a third category and an annual report would be a very positive move to maintain enthusiasm. However, one thing I think will bother us is the increasing pressures this may put on the Heritage Centre.

• I do not know where one distinguishes between a tourist collecting fossils and a fossil collector. However, to find a fossil collector that has no knowledge of the Fossil Code, I find difficult to believe. There is now so much information that one can source on the web about the Code, I can only suggest that ignorance is not a plea for innocence.

• In general most tourists seek fossils as a part of their holiday and if they have children, act responsibly in their enthusiasm and curiosity. Unfortunately we do always have a minority who act irresponsibly and seem to get pleasure in waiting for the helicopter. I do not think we ever assumed that we would stop all the cliff climbers, so we do need to act positively to discouraged them. 23. Mike Taylor It seems a very thorough job and I found it very hard to improve on what you and your colleagues have done and very interesting reading - notably on the shifting focus depending on what the landslides bring down. Prersumably this controlled past collecting as well ... on that vein, on the impact of quarrying, I've also been reading the booklets produced by Richard Bull and available as downloads from the Lyme Museum and the new book 'Ebb and Flow', in the light of our little walk th eother week - I have a much better sense now of the amount of quarrying there was at what times. (Too much ...).

To my mind the key problem is the imbalance of museums and funding (especially in geology) versus the potential of the area ……..] - I did wonder if the collectors need to be more realistic about the museum scene and their wish for Dorset displays given the new climate of public spending.

One point I would make, however, from my involuntary additional homework of the last few months, is that if the collectors don't make provision in their wills, if anything happens then the specimens are quite likely to be sold for the maximum legal price irrespective of whether they end up overseas (and indeed have to be to fulfil the executor's duties, especially if there are children involved who by definition are legally incapable of agreeing to anything less - adult beneficiaries might, but need not, be willing to accept a discount to ensure Dorset displays, but children cannot). Having said that, there is also some provision for inheritance tax relief either on the usual…….. SOME TEXT MISSING

I do also wonder how many of the collectors have even made wills etc. In my experience - and I am not thinking here of Lyme as such - not every collector enjoys dealing with bits of paper particularly if they are official or legal (which makes it a relief to work with the businesslike ones!).

I find it difficult to suggest what else you could do about ownership. On the matter of compulsory ownership, you're probably still about right in your approach. In Scotland we do of course have the Bona Vacantia scheme for antiquities but the finder/(?landowner) is always compensated 100% and museum coverage is rather better.

There are now a lot more marine reptile researchers than there were in the 1970s and 1980s but it's still a fragmented profession - Lez Noe for instance has gone off to a job in Colombia (lots of K plesios, and he is still VERY interested in the Dorset pliosaurs, mind you) and continuity is a problem. So you and your colleagues may well have to be matchmakers as you suggest ... The draft also made me think back to the situation then and now. I did have in the 1980s to actually act as matchmaker on oiccasion - once John Fowles had introduced me to the collectors then I could spot key specimens and bend the ear of the right curators nd the associated researcher to confirm the specimen was important. This last bit, whom to pick on, is somethijng John wouldn't have known. But then the researchers wouldn't have known that specimens of interest were at Lyme and couldn't have justified coming down on spec. (I well remember how surprised Ryosuke Motani was when he visited Chris Moore's workshop on the Street meeting field trip of 2009 and saw the new beasties.) For instance Dave Costin's Excalibosaurus no. 1 went to Bristol, with Micky Curtis and Chris McGowan, and Peter Langham's big Kimmeridge icky and also rthbe partial theropod (that last went to Oxford - I recall bringing Phil Powell of OXFUM and David Norman down to Lyme for the day. But that took time and also Stephen Locke's support or at least tolerance. And Peter Crowther maintained the links once developed with Micky at Bristol. But your point of a new generation of collectors is a good one.

But it's also harder to keep up with the lit. I'm myself getting increasingly out of touch with Jurassic marine reptiles as a result of the differing priorities of the last few years, and will soon have to make a decision either to really work hard to bone up on them, esp. the ickies, or bow out gracefully ... no doubt the former, but I have too much to do at the moment! 27. Neil Ellis, JNCC If corroboration of the existing code from JNCC is helpful to your work, then I can certainly attest to JNCC's wholeheatered support of the fossil Code, and we continue to endorse the principles it contains. Evidence shows that very little 'abuse' (concerning collecting) is posing a threat to the integrity of the site, and that therefore the Code is working and not in need of major revamping. I do not see a need to modify it in a major way, and am sure other commentators will provide feedback as to how any current systems that operate might be improved a little (e.g., perhaps, how major new finds are notified to you/ academia; whether the 'important finds' database system is working and whether specimens are being 'lost' to science through trade as some unqualified comments from academia believe [e.g. the NHM has 3 unstudied Scelidosaurus and yet there was uproar about the sale of a fourth, if memory serves). There may well be detractors out there who see the fossil trade as damaging to research, but the truth is that researchers are simply not doing the collecting/ preparation (or specimen study).

My feelings remain the same that encouraging co-operation between collectors and researchers rather than attempting any kind of heavy-handed regulation is going to be far more productive in maintaining the conservation value of the site, because you simply cannot police 90 miles of coast. Therefore self- regulation and voluntary collaboration remain a key part of the code. Any more restrictions will lead to more-damaging clandestine collecting, I think.

So I have nothing major to add to the scheme. A couple of little things maybe: if there has been a storm and landslide, perhaps the event should be recorded and linked to new finds (so proving the no- intervention against erosion tactic is best for the Site). And maybe there should be some monitoring of fossil trade (to prove the commercial value of the specimens coming from the Site, and thereby demonstrating its value in sustaining a local trade/community).

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