MARINE MAMMAL COMMISSION — Annual Report for 1992 
Applicant 
Application 
Department of 
Commerce 
Complete Application 
Department of 
the Interior 
Final Departmental Action 
Department of 
the Interior 
Department of 
Commerce 
Commission Recommendation 
Marine Mammal Commission 
Committee of Scientific 
Advisors on Marine Mammals 
Figure 2. Process by which requests for permits to take marine mammals are reviewed. 
processing times for the Departments of Commerce 
and the Interior were 125 and 151 days respectively, 
compared to 118 and 88 days in 1991. 
Review 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 1988 amendments, the National Marine Fisheries 
Service undertook a comprehensive review of its 
permit program. 
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 
184 
Research and Public 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, scien- 
tific research, and enhancement permits, and the 
relationship between permits and the National Envi- 
ronmental Policy Act. 
As noted in its annual report for 1989, by letter of 
24 August 1989 the Commission provided extensive 
comments on the discussion paper. Among other 
things, the Commission provided a possible definition 
of public display; recommended that the Department 
of Agriculture’s Animal and Plant Health Inspection 
Service’s marine mammal care and maintenance 
regulations be reviewed and as necessary revised; 
provided comments on the Service’s interim policy on 
education and conservation programs required of 
public display permit holders; suggested basic infor- 
