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encourage the National Marine Fisheries Service and the Fish and 

 Wildlife Service to develop clear, concise instructions for preparing 

 permit applications; direct the Services to advise applicants within 

 30 days of receiving an application if it is complete or not, and fin- 

 ish reviews within 60 days of an application's being judged com- 

 plete; authorize the Services to exempt certain categories of re- 

 search from the notice and comment requirement and perhaps 

 other requirements related to permit review; streamline procedures 

 for authorizing the importation of specimens for scientific purposes; 

 clarify in report language that the term bona fide refers to an ap- 

 plication made in good faith without fraud or deceit, an application 

 made with earnest intent, and one for which the scientific purpose 

 is neither specious nor counterfeit; amend the Act to enable the 

 Secretaries to authorize the taking of marine mammals including 

 depleted species, incidental to filming for either educational or com- 

 mercial purposes under certain conditions when harassment might 

 occur; and authorize the Secretaries to waive the 30-day public no- 

 tice and comment period when delaying research could result in 

 harm to a species, population, or individual marine mammal, or re- 

 sult in loss of unique, unforeseen research opportunities. 



Other problems with the scientific research program identified by 

 the participants can be addressed administratively, we think. 



The Commission is opposed to the needless use of invasive and 

 lethal research techniques, but believes that there are instances 

 when lethal or invasive research is necessary and appropriate to 

 further basic knowledge. 



We also note that existing statutory provisions ensure that such 

 techniques will not be used when nonlethal or less invasive meth- 

 ods are practicable. 



In my written statement, I address at length the question of 

 which agency or agencies should be given jurisdiction over captive 

 marine mammals. The Commission believes that split jurisdiction 

 works. While the Animal and Plant Health Inspection Service has 

 experience with captive animals under the Animal Welfare Act, 

 and can inspect facilities, it does not have the expertise with re- 

 spect to marine mammal biology, physiology, behavior, and specific 

 marine mammal needs that the National Marine Fisheries Service 

 and the Fish and Wildlife Service have. 



The responsibilities of the three agencies are largely complemen- 

 tary. Since the Interagency Agreement in place since 1979 works 

 and there is little duplication of effort under the Animal Welfare 

 Act and the Marine Mammal Protection Act, we recommend that 

 Congress clarify that the jurisdiction over captive marine mammals 

 is intended to be provided under both Acts. 



My written statement also provides comments on other permit- 

 related amendments proposed for consideration during reauthoriza- 

 tion. These include the use of marine mammals in interactive dis- 

 plays, the importation of depleted marine mammals for public dis- 

 play, the applicability of the National Environmental Policy Act to 

 the capture of wild marine mammals for the purpose of public dis- 

 play, and the prohibition against feeding wild marine mammals. 



My written statement also discusses issues of interest to Alaskan 

 native groups who seek to ensure 1) that the current exemption al- 

 lowing the taking of marine mammals for subsistence and handi- 



