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 1989, the Commission made recommendations on 22 

 applications submitted to the Department of Commerce, including 

 five applications that were received in 1988 but which did not 

 receive final action until 1989, and two applications submitted 

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

 review time for complete applications was 43 days (median, 42.5 

 days) . Not included in the preceding statistics are recommen- 

 dations on eight applications that were awaiting final action by 

 the Department of Commerce and two applications awaiting final 

 action by the Department of the Interior at year's end and two 

 applications that were under Commission review at year's end. 

 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 1989. The aver- 

 age time required for Commission review of these matters was 34 

 days. 



For the 22 applications processed by the Department of 

 Commerce during 1989, it took an average of 178 days (median, 159 

 days) from the date the application was received by the 

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

 cations submitted to the Department of the Interior were pro- 

 cessed in an average of 72 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 145 and 7 days, respectively, compared to 116 and 87 days, 

 respectively, in 1988. 



Permit System Review 



During the 1988 reauthorization of the Marine Mammal 

 Protection Act, considerable attention was given to revising the 

 Act's permit provisions. As noted in Chapter II of this Report, 

 the provisions were amended, including the addition of authority 

 for permits to enhance the survival and recovery of marine 

 species and stocks. 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 



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