MARINE MAMMAL COMMISSION — Annual Report for 1991 



Applicant 



Application 



Department of 

 Commerce 



Final Departmental Action 

 T 



Department of 

 the Interior 



T 



I 



Department of 

 Commerce 



Complete Application 



Department of 

 the Interior 



T 



Commission Recommendation 



T 



Marine Mammal Commission 



T 



Committee of Scientific 

 Advisors on Marine Mammals 



Figure 2. Process by which requests for permits to take marine mammals are reviewed. 



Department of the Interior processed three permit 

 applications during 1991, completing each in an 

 average of 123 days. If calculated from the date that 

 the application was considered by the Department to 

 be complete, the average processing times for the 

 Departments of Conunerce and the Interior were 118 

 and 88 days, respectively, compared to 131 and 164 

 days, respectively, in 1990. 



Reyiew of the Permit System 



During the 1988 reauthorization of the Marine 

 Mammal Protection Act, considerable attention was 

 given to revising the Act's permit provisions. As an 

 outgrowth of the interest in permit issues and because 

 of the need to update its regulations and implement 



the amendments, the National Marine Fisheries 

 Service undertook a comprehensive review of its 

 permit program in 1988. 



The first formal step in the Service's permit review 

 was publication, in March 1989, of a discussion paper 

 entitled "Permit Policies and Procedures for Scientific 

 Research and I*ublic Display under the Marine Mam- 

 mal Protection Act and the Endangered Species Act." 

 The discussion paper described the applicable law and 

 Service policies with respect to public display permits, 

 scientific research permits, enhancement permits, and 

 the relationship between permits and the National 

 Environmental Policy Act. 



As noted in the Annual Report for 1989, the 

 Commission, by letter of 24 August 1989, provided 

 extensive comments on the discussion paper. Among 



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