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The following is the summarized version of the 200+ letters received from Taffi Fisher Abt. You can view the orignal version here (pdf, 20.6mb).
July 16,2008
Ryan Wheeler, PhD
Chief, Florida Bureau of Archaeological Resources and State Archeologist
B. Calvin Jones Center for Archaeology & the Governor Martin House
1101 de Soto Park Drive
Tallahassee, FL 32301
RE: Comments on Proposed Rule IA-31
Notice 5697700, June 6, 2008
Dr. Wheeler,
I take comfort in knowing that Florida law requires that the agencies of the State obtain the input its' citizens most affected before adopting rules and rule changes. I doubt that you would deny that the rules you propose are designed to regulate commercial historic shipwreck salvors right out of business, but wonder where I might find the legislative mandate that instructs the Bureau of Archaeological Resources to do so. I believe that is the agenda ofthe DHR/BAR and I intend to defend my rights as an American in free enterprise.
Enclosed are 208 letters from other Florida citizens who agree with me, expect many, many more! I am a director of the Historic Shipwreck Salvage Policy Council (HSSPC), I was asked to collect these letters and copy them for our records before they were sent to your offices. All comments posted on your website have also been archived for our records.
I also noted that your website only posted the written and emailed comments and wonder when the court reporters' transcripts of the comments made by people who spent their time, effort, and their own money to personally attend the meeting will be posted? The workshop was held with only two weeks notice to our industry and, as you must have been aware, was in the middle of our short 90-day salvage season window. So those who attended certainly deserve to have their comments published.
As you well know, my family has been salvaging shipwrecks offthe coast of Florida for the last 45 years, and still continues today. We consider ourselves to be an ethical commercial shipwreck exploration and salvage Corporation. I am appalled at the unbridled attempt to take away my family's business and that of others as well. I am adamantly opposed to the proposed rule changes as they are written.
We have always worked fairly with the State of Florida, and our operations have been overseen by United States District Judge James Lawrence King since 1983 to ensure that the State is treating us fairly. It seems a shame that we needed federal intervention to get the State of Florida's cooperation necessary to allow us to work diligently to save the submerged cultural resources we salvage.
My family has found, conserved and documented more about shipwrecks than anyone in the DHR/BAR can imagine. Don't forget the State of Florida has been the overwhelming recipient of 1/5 ofour artifacts salvaged from the 1715 fleet, more than any ofour investors! Our shares of the finds have been on tour around the U.S., Europe, and Canada. We have created more awareness of Maritime and Nautical History than the State of Florida could ever hope to generate. Our explorations have been chronicled in hundreds and thousands of documentaries, books, publications and periodicals, including Florida History textbooks used in the public school system.
We have caused to be donated, through our own donations or those of our investors, millions of dollars of artifacts to both State of Florida Museums as well as several other museums around the U.S. and Europe. We have supplied the State of Florida archives with reams of data. We have created a free public online database for use by researchers and the general public. Because of the private sector participation and donations, the State of Florida has the single most comprehensive collection of Spanish Colonial Historic shipwreck material in the world. In spite of that, the visitation at Florida's museum of History or any Florida Academic Institutions can not compare with attendance of our private museums and exhibitions. The tourism industry dollars we have created for this State and the economic expenditures made to Florida's local businesses due to our endeavors easily reaches into the hundreds of millions of dollars.
From the late 1940's thru the early 1960's, Art McKee and Kip Wagner and Mel Fisher were really the only leaders in this industry. They found their own funds and did their own research. Not one state official was in the business of exploring for or salvaging shipwrecks. This has been an evolution of an industry through trial and error for the State Officers as well as the salvagers themselves. However, the salvagers were the ones who were willing to be the pioneers in the industry and take the risk, financially and physically. They have also spent much more time and effort (and continue to do so) in the research, development, design and use of new and yet undiscovered technologies in survey, salvage, and conservation.
We have presented thousands oflectures for professional, institutional, and community venues. We regularly visit Florida schools and we also provide summer camps for students eager to learn about the history that lies beneath Florida waters. We also work with the local police on their summer programs with local youth.
On the East Coast Shipwreck Project, we participate with, encourage and guide in excess of 20 new salvage companies on an annual basis on how to conduct historical shipwreck salvage correctly keeping in mind the environmental issues, archeological integrity, and the conservation of finds - often exceeding requirements of the law. Some continue to work with us for many years, mainly because, they have not been able to wade through the current bureaucratic and inconsistent rules and requirements to obtain their own salvage permits.
Certain professional archaeologists choose not to follow the standards of RPA simply because they want to participate in private sector salvage. They are forbidden to do so by a recently changed by-law by the RPA that forbids archaeologists working with private salvage industries if any of the collection is going to be sold. Other than that, their training has been exactly the same. In addition to professional archaeologists, we also employ professionals and train others in conservation, photo archiving, database archiving, computerized mapping, remote sensing surveys, general archeological procedures, environmental rules, navigation, and cartography. The various state universities and non-profits use students (free labor) and volunteers, much in the same way, except they don't usually have to pay for it because they get special grant funding from your good offices. In the current economy, those grants are bound to dry up. We, however, have done all that we do spending our own time, money, and efforts at no cost to the taxpayers.
Is the real issue to keep a collection 100% intact in perpetuity? If so, please provide me with a digital list (keeping the reduction of paper act in mind) of submerged cultural resources (artifacts) salvaged by all university projects that used any state grant funding, the amount of funding, the current location of the artifacts, their condition, and the names of the trustees who are in charge of monitoring them.
I await your reply!
Taffi Fisher Abt
President, Mel Fisher Center, Inc., ast Coast Shipwreck Project - Admmiralty Salvage
and Florida Exploration Contract Holder (MFC, Inc.)
Board Member of Historic Shipwreck Salvage Policy Council (HSSPC)
Vice Pres., Motivation, Inc., Florida Keys National Marine Sanctuary Permit Holder
Editor of Institute of Marine Archaeology and Conservation (lMAC)
Board Member ofthe Mel Fisher Maritime Heritage Society 501-C-3 (MFMHS)
Cc Honorable Governor Crist
Honorable Secretary of State Kurt Browning
William Vandercreek Esquire, Professor Emeritus, Florida State University
A. Eugene Lewis, Esquire
James C. Smith, Esquire
Mary Hansen Esquire
Sent Certified, Return Receipt Requested, via FedEx
The following is the transcription of one of the duplicate letters received on July 18, 2008 from Taffi Fisher Abt. Following the letter are the list of handwritten signatures, address and notes that were transcripted from the letters.
To: Department of Historic Resources
Florida Department of State
Re: IA-31 Rule Amendment
Bureau of Archaeologica1 Research
500 S. Boronough Street, MS #8b
Tallahassee, FL 32399-0250
July 04, 2008
To Whom It May Concern:
On this Independence Day it is appropriate that we all remember the reasons why this country was founded. It was a move against overbearing government actions.
I am a citizen of the State ofF lorida aod have been made aware of the attempts by the Florida Bureau of Archaaeologica1 Research to cchange the rules (IA-31) by which private citizens aod corporations can help recover the lost and threatened shipwreck treasures that are in the State ofFlorida's coastal waters.
Florida aod the United States have long enjoyed the results of private sector recovery and documentation of these lost shipwrecks. Private salvors have contributed to this sum of knowledge for the past 60+ years. Museums have benefited here in Florida as well as throughout the USA and the World. Traveling exhibits have promoted not only the knowledge and history of these sites but also the State of Florida and its beauty. Numerous documentaries by National Geographic, Discovery and the History Channel have chronicled private salvors successes. Thousaods of periodicals have done the same. Books have been written about these quests and added to the Florida History textbooks in our schools. The contributions of the private sector far outweigh those of government, institutions and university efforts whose work is rarely heard ot if at all, not to mention, paid for with taxpayer dollars.
I agree that there needs to be in place a plan, rules and guidaoce by the State of Florida in the management ofthese treasures. I stroogly disagree with any proposed changes that would impede or prohibit the involvement of private citizens or corporations. This resource is much too important and wonderful to be left to rot by natural elements or to potential pilfering by non law-abiding persons who encounter these shipwreck sites. A fundamental shift in policy to one of support and guidance is key. This was clearly the Florida legislature's intent in the formulation of IA-31.
I urge the Division of Historic Resources, aod the Department of State to halt this rule change as written and to work closely with the Private Salvage Industry who has contributed the majority of success in rescuing Florida's great wealth of underwater treasures.
Respectfully Submitted,
The following are the transcription of handwritten signatures, addresses and notes for the letters received.