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 1988, the Commission made recommendations on 29 

 applications submitted to the Department of Commerce, includ- 

 ing 14 applications that were received in 1987 but which did 

 not receive final action until 1988, and two applications 

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

 average review time for complete applications was 43 days 

 (median, 36.5 days). Not included in the preceding statistics 

 are recommendations on 11 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 one application that was under Commission 

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

 from the Department of Commerce 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 27 requests to modify 

 permits and other related permit actions during 1988. The 

 average time required for Commission review of these matters 

 was 26 days. 



Processing of the 29 applications by the Department of 

 Commerce during 1988 took an average of 148 days (median, 132 

 days) from the date the application was received by the 

 Department until final action was taken. The two permit 

 applications submitted to the Department of the Interior were 

 processed in an average of 114 days (median, 34.5 days). If 

 calculated from the date of receipt of a complete application 

 by the Departments, the average processing times for the 

 Departments of Commerce and the Interior were 116 and 87 

 days, respectively, compared to 112 and 72 days in 1987. 



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 

 statutory, regulatory, and administrative changes as might be 

 appropriate to address the problems. 



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