Service will be revising its permit regulations. The Service 

 hopes to have a draft proposed rule available for interagency 

 review in March 1990. 



At the close of 1989, the Commission was drafting a letter 

 to the Service identifying other steps that should be taken to 

 streamline and improve the permit process, including those 

 changes that can be implemented without amending the regulations. 

 That letter is expected to be sent early in January 1990. 



Issues Concerning Lethal Take for Public Display 



During 1987, the Fish and Wildlife Service requested 

 Commission comments on a permit application seeking authority to 

 kill a walrus for purposes of museum display. By letter of 28 

 October 1987, the Commission advised the Service that, in its 

 view, lethal taking of marine mammals from the wild for this use 

 is not warranted if satisfactory specimens can be obtained from 

 alternative sources, such as an animal that dies in captivity, is 

 killed intentionally or unintentionally during scientific 

 research, or is taken incidental to commercial fishing. In this 

 regard, the Commission noted that, if a specimen is not 

 immediately available, one is likely to become available within a 

 reasonable time and it therefore recommended that the applicant 

 be required to explore alternative sources of animals. 



In a related letter, also sent to the Service on 28 October 

 1987, the Commission recommended that the Service prepare a 

 general policy statement concerning such requests and provide a 

 draft to the Commission and the National Marine Fisheries Service 

 for review. Specifically, the Commission suggested development 

 of a policy requiring that, whenever possible, applications 

 requesting specimens for mounted displays be met by sources that 

 do not require a direct lethal take and that permits authorizing 

 lethal takes for such purposes be issued only when specimens 

 cannot possibly be obtained from other sources. On 24 November 

 1987, the Service replied to the Commission's letter, noting that 

 it agreed that lethal take for public display is inappropriate if 

 specimens are available from other sources and that it intended 

 to adopt a formal policy on the matter. Late in 1987, the 

 Service prepared a draft policy statement and provided it to the 

 Commission and the National Marine Fisheries Service. 



In August 1988, the Commission learned that effective 

 identification of possible alternative sources of suitable 

 specimens to satisfy the request noted above was not taking 

 place, possibly because of poor communication and coordination 

 between the Service's Permit Office in Washington, D.C., and its 

 Alaska Regional Office. A formal policy statement concerning 

 such requests had not yet been adopted by the Service and, by 

 letter of 18 August 1988, the Commission recommended that the 



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