Public Display under the Marine Mammal Protection Act and the 

 Endangered Species Act." The discussion paper explained the 

 permit requirements of the Acts and the applicable implementing 

 regulations, as well as relevant policies adopted by the Service. 

 Specific chapters were included on public display permits, 

 scientific research permits, enhancement permits, and the 

 relationship between permits and the National Environmental 

 Policy Act, which presented additional information and posed 

 several questions for public comment. 



By letter of 24 August 1989, the Commission provided 

 extensive comments on the discussion paper. Among other things, 

 the Commission: recommended that the Service consider updating 

 the introductory chapters of the discussion paper to serve as a 

 resource document on the permit process; suggested a definition 

 of public display; recommended that amendments to the Animal and 

 Plant Health Inspection Service's marine mammal care and main- 

 tenance regulations be amended or augmented; provided comments on 

 the Service's interim policy on education and conservation 

 programs required of public display permit holders; supplied an 

 attachment detailing its views concerning the basic information 

 requirements for scientific research permit applications and 

 subsequent reports; proposed criteria for reviewing enhancement 

 permits; recommended that the Service review and revise its legal 

 interpretation of the status of progeny from pre-Act marine 

 mammals held in captivity; recommended that the Federal agencies 

 sharing responsibility for marine mammal management develop 

 strategies for improved communication, seek consistency in 

 developing, interpreting, and implementing regulations, and adopt 

 a more consistent approach to administration of the permit 

 process in general ; and commented that the Service should 

 consider whether capture and temporary maintenance of marine 

 mammals pending completion of a permanent facility is appropriate 

 and, if so, under what conditions. 



Beginning in October 1989, the Service convened a series of 

 working sessions on various aspects of its permit program to 

 solicit additional public comment and to foster greater discus- 

 sion of the major issues. The first session sought to define 

 public display. Subsequent workshops addressed scientific 

 research permits, care and maintenance standards for captive 

 marine mammals, and public display education and conservation 

 programs. A special presentation on the permit review and on 

 scientific permits in particular was made by the Service at the 

 Eighth Biennial Conference on the Biology of Marine Mammals, held 

 by the Society for Marine Mammalogy in December 1989. The 

 Service is planning two working sessions in January 1990 on the 

 application of the National Environmental Policy Act to the 

 permit process. 



Based upon its discussion paper, comments on the discussion 

 paper, and information generated at the working sessions, the 



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