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to all research activities conducted in the wild, including those 

 involving non-intrusive close approach, has proven inefficient 

 and inflexible. Clearly, the permit requirements of the MMPA are 

 too burdensome and too lengthy when the research involves only 

 the non- intrusive close approach of marine mammals in the wild. 



Much of the scientific research on wild marine mammals involves 

 only non- intrusive close approach without significant contact or 

 restraint. We believe that the MMPA should be amended to shorten 

 and simplify the permit process for scientific research involving 

 these low- impact types of harassment. 



In addition, there are other activities that have proven 

 important in increasing the public's understanding and 

 appreciation of marine mammals. These include both activities 

 that allow the public to observe these magnificent animals in the 

 wild and efforts to bring documentary films and photographs of 

 wild marine mammals to the large segment of the public that will 

 never be able to observe them in their natural habitat. The law, 

 as presently written, does not provide an exception to the 

 general moratorium on the taking of marine mammals for purposes 

 of public observation or wildlife photography, resulting in a 

 virtual prohibition on the non- intrusive close approach of wild 

 marine mammals for such educational purposes. Such non-intrusive 

 close approach of wild marine mammals should be authorized under 

 the law and monitored appropriately by NMFS . However, it is 



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