19 2o J Notes and News. bio 



results of which have been published by him in the 'Proceedings' of the 

 Linnaean Society of New York, No. 31, 1919, pp. 23-55. It is planned 

 to enlist the interest and services of volunteer workers, who will under- 

 take to operate and maintain trapping stations throughout the year, 

 banding new birds and recording the data from those previously banded. 

 The results from a series of stations thus operated will undoubtedly give 

 new insight into migration routes; speed of travel during migration; 

 longevity of birds; affinity for the same nesting-site year after year; and, 

 in addition, furnish a wealth of information relative to the behavior of 

 the individual, heretofore impossible because of the difficulty of keeping 

 one particular bird under observation. 



The details of operation are now receiving close attention, and as soon 

 as possible the issue of bands will be announced, with full information 

 regarding the methods to be followed and the results expected. In the 

 meantime, the Biological Survey will be glad to receive communications 

 from those sufficiently interested and satisfactorily located to engage in 

 this work during their leisure time, for it is obvious that a considerable 

 part must be done by volunteer operators. It is hoped that a sufficient 

 number will take this up to insure the complete success of the project. 



Everyone interested in the protection of birds will rejoice in the opinion 

 of the Supreme Court of the United States upholding the legality of the 

 Migratory Bird Treaty Act. The action came in connection with an 

 appeal from the District Court of the United States for the Western Dis- 

 trict of Missouri, in a case already mentioned in these columns and seems 

 to settle once for all the right of the United States to supersede the indi- 

 vidual States in legislation regarding migratory birds. 



The last paragraph of the opinion is worth quoting: 



"Here a national interest of very nearly the first magnitude is involved. 

 It can be protected only by national action in concert with that of another 

 power. The subject matter is only transitorily within the State and has 

 no permanent habitat therein. But for the treaty and the statute there 

 might soon be no birds for any powers to deal with. We see nothing in 

 the Constitution that compels the Government to sit by while a food 

 supply is cut off and the protectors of our forests and our crops destroyed. 

 It is not sufficient to rely upon the States. The reliance is vain, and were 

 it otherwise, the question is whether the United States is forbidden to 

 act. We are of opinion that the treaty and statute must be upheld." 



The Permanent Funds of the A. O. U. — From time to time the Union 

 has established several permanent funds for special purposes. In every 

 case the principle with such contributions as may be received is invested 

 so as to remain intact and the interest only is used for furthering the 

 objects of the fund. The most important of these funds are: the Brew- 

 ster Memorial Fund, the Research Fund, and the Publication Fund. 



