Because most of the jade in the Jade Cove area is present in smaller pods and nodules, not in veins, it is difficult to assess or measure the exact amount of jade in the Sanctuary. Collection of jade should require reporting of the amount taken to determine if there are any impacts of casual collection on the environment. The amount of jade removed pursuant to a permit issued by NOAA will be required to be reported. The amount of jade removed under the general exception, however, may be difficult to assess given the isolation and exposure of the area, the transitory nature of many visitors to the area, and the lack of NOAA or other personnel to monitor jade collection activities. NOAA should consider an alternative of seasonal closures on jade collection, if only for safety reasons.
People collect jade at their own risk.
NOAA's action only removes a restriction on a previously prohibited activity. The proposed rule is not clear on what restrictions, if any, exist on the commercial use of jade collected under the conditions of the proposed rule. If a stone is not removable under the conditions outlined in the general exception for limited, small-scale jade collection under this rule, including an individual being allowed to remove only what he can carry himself, then a permit will be required to remove the stone. Hand tools are only allowed to aid in maneuvering and lifting loose stones, and scratching the surface of a stone as necessary to determine if it is jade. Hand tools are not authorized to be used to break or chip stones under any circumstances.