What I sent...
Sirs:
Regarding your proposed changes to rule 1A-31:
I am against any rules or regulations that would hinder Florida’s responsible historical shipwreck salvors from their continued recovery of treasures and artifacts, such as the current proposed rules. “Commerce” here, is the key word, and commerce is guaranteed under every doctrine of free trade in these United States, and particularly in Florida where each person is guaranteed a right to work, without interference from unions and/or government. We are each entitled, under Federal and State law to create wealth through our labor where no transgression of criminal law or civil infringement occurs. Heretofore, no such crime is inferred by commercial salvage and the nature of marine salvage is such that, in and of itself, it is a profession long recognized as a common trade in Florida. You do not have the authority to declare commercial salvage as anything other than what it is, to wit: the right of free men to profit from the spoils of shipping.
I know that Florida’s private sector salvors have done an excellent job of recovering and preserving our maritime heritage, to the direct benefit of the public and at little cost to the taxpayers and should be allowed to continue with as little interference as possible. Rule 1A 31 does not do this, and, in fact, is plainly nothing more than a bureaucratic ruse to make law where none exists, a function reserved for our legislators, not the charge of our various enforcement agencies, such as the BAR/DHR.
I do not want my tax dollars used by state archaeologists to dive on shipwrecks. The private sector salvors have done a great job, using their own money, with Florida getting the benefits by receiving 20% of the conserved artifacts and treasures recovered. Your new rule changes would seek to replace free enterprise with opportunities for artisans who would practice their craft at my expense, when it is impractical and unnecessary. While Amendment One may have left your agency high and dry financially, now is not the time to redirect contracts and wealth to your friends and colleagues. In view of recent examples on the national stage as I write this, I think it is abundantly clear to all that government can not run private enterprise without subornation to one degree or another. I would have you recall your difficulties in the past with NAGPRA as one instance where government overstepped itself with an eye toward self-interests. You, the BAR/DHR, would be “government” in this case. Frankly, if you insist on pursuit of this effete, snobbish, and thinly disguised plot to fill your own pockets under the cover of your office, you may well destroy the very agency that provides your welfare. You are here to serve us, not the other way round.
The new rule is, on its face, a snub to working men and women because it treats commercial salvors as unworthy to receive the same due course of attention as would be afforded to universities and nonprofit organizations. For example, the turnover or response time to get permits for 1A 32 is two weeks for those entities, while commercial groups have waited months and in some cases, years. Also 1A 32 uses students, who are by definition simple neophytes as excavators while commercial enterprises must use experts (read “your recognized affiliates”).
This remark is easily proven before any arbeiter you would care to name as an independent referee in the matter. Furthermore, without any sustainable logic, you would permit university applicants to obtain search, recovery and salvage rights in their first singular application while the disparity you exercise regarding tradesmen is apparent when the process is doubled for the commercial enterprise. And, let’s not forget the obvious…NO recovery & salvage permits (unless already grand fathered in by Federal Admiralty Claims) have been issued to commercial groups in Florida for over 15 years.
Your insistence that an archaeologist be on board each salvage vessel during each and every survey and excavation is a testament to your obstinate desire for control where no control is called for. I ask you now, why I have not seen a State Agent of any sort for the last six years while engaged in salvage? Is it because the people of Florida have yet to appreciate what this expense in oversight has brought to them as taxpayers in past years? Salvors create wealth for themselves and others while, in your view, archaeologists are satisfying their own curiosity and therefore creating an interest in the public at large. You are overestimating the worth of your dogma. It generates nothing but intellectual property for your selves in the marketplace.
You now also propose that we, as private business, furnish you with more information that you can use at your leisure, without any consultation, or concern. Once again, our data is acquired at our own expense, and is not something that you can use to benefit others who are not entitled to that benefit as a favor from yourselves. Information is valuable, as you well know, seeing that your entire profession hinges upon it. The salvor’s information is a private resource, developed by the salvor, and not the property of the State, nor any person acting under color of his authority to infringe upon it. Perhaps you would consider approaching the legislature to see if they would consider buying our information outright rather than having you involved in some form of quasi-extortion.
Tyrrell L Armstrong
of
New Channel Historical Survey Group
Real 8 Co.
Doubloon Salvage
A.L. Jolly Salvage
Oceaneering Intl.
Karrwinall Diving & Salvage
Packer Diving & Salvage
Deep Sea Divers of Belle Chasse
Southern Cross
Signum Ops
Tradewinds Salvage
In Aussie land, the law on Salvage is wrong !!!! I thought you may be interested? so you didn't feel
