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clear that the such authorization and monitoring should be simple 

 and straightforward, and that such activities should not be 

 subject to the same review as more intrusive procedures. 



We propose that the MMPA be amended to provide for the permitting 

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

 purposes of public observation and wildlife photography. We also 

 propose that the law be amended to allow the Secretary to waive 

 the 30-day public comment period for both scientific research 

 permits and the new permits for public observation and 

 photography, where such permits involve only the non- intrusive 

 close approach of marine mammals. We would be pleased to discuss 

 other amendments that would achieve these same objectives. 



There are a few other issues that cannot be addressed solely 

 through the regulatory process or improved administration of the 

 permit program. These issues, if they are to be addressed, 

 require amendments to the MMPA. These include: 



1) The exchange of native art between U.S. and foreign museums 

 or other institutions open to the public, where such native art, 

 in whole or part, includes marine mammal parts subject to MMPA 

 prohibitions. The MMPA does not include a specific provision for 

 exempting art works and handicrafts containing marine mammal 

 parts from the prohibition on importing such parts. If such 

 native art is not purchased or sold, NMFS believes that the MMPA 



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