The total review time (initial receipt of application 

 until final Departmental action) depends on many factors, 

 including: the sufficiency of the information provided by 

 the applicant; special requirements, such as inspection of an 

 applicant's marine mammal holding facilities, that may be 

 warranted before a decision can be reached; and the efficiency 

 and thoroughness of those responsible for the agency review. 



During 1987, the Commission made recommendations on 37 

 applications submitted to the Department of Commerce, includ- 

 ing eight applications that were received in 1986 but which 

 did not receive final action until 1987, and 13 applications 

 submitted to the Department of the Interior. The Commission's 

 average review time for complete applications was 46 days 

 (median, 37 days) . Not included in the preceding statistics 

 are recommendations on eight applications that were awaiting 

 final action by the Department of Commerce and one application 

 awaiting final action by the Department of the Interior at 

 year's end and three applications that were under Commission 

 review at year's end. Also not included are two applications 

 from the Department of Commerce and two applications from the 

 Department of the Interior on which review was suspended at 

 year's end pending receipt of additional information. The 

 Commission, in consultation with its Committee of Scientific 

 Advisors, also made recommendations on 26 requests to modify 

 permits and other related permit actions during 1987. The 

 average time required for Commission review of these matters 

 was 25 days. 



For the 37 applications processed by the Department of 

 Commerce during 1987, it took an average of 139 days (median, 

 112 days) from the date the application was received by the 

 Department until final action was taken. The 13 permit appli- 

 cations submitted to the Department of the Interior were pro- 

 cessed in an average of 107 days (median, 85 days) . If calcu- 

 lated from the date of receipt of a complete application by 

 the Departments, the average processing times for the Depart- 

 ments of Commerce and the Interior were 112 and 72 days, 

 respectively, compared to 92 and 65 days, respectively, in 1986 



Working Group on the Permit System 



In July 1985, the Commission established a Working Group 

 composed of members of the Commission staff and the Committee 

 of Scientific Advisors on Marine Mammals for purposes of 

 preparing a report on how the Marine Mammal Protection Act 

 permit system could be improved. The Working Group was asked 

 to identify problems that have arisen with regard to the 

 review of applications and the issuance, modification, and 

 enforcement of marine mammal permits, and to recommend such 



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