General authorization permit application

National Marine Fisheries Service
Marine Mammals
Marine Mammal General Authorization
OMB No. 0648-0084
Expires: MM/DD/YYYY

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NATIONAL MARINE FISHERIES SERVICE
ENDANGERED SPECIES AND MARINE MAMMALS
MARINE MAMMAL GENERAL AUTHORIZATION

TABLE OF CONTENTS
INTRODUCTION.......................................................................................................... 3 
LETTER OF INTENT.................................................................................................. 5 
PROJECT INFORMATION ....................................................................................................................... 5 
PROJECT DESCRIPTION ........................................................................................................................ 6 
PROJECT SUPPLEMENTAL INFORMATION ......................................................................................... 8 
PROJECT LOCATIONS AND TAKE INFORMATION ............................................................................. 9 
NATIONAL ENVIRONMENTAL POLICY ACT (NEPA) CONSIDERATIONS ................................... 11 
PROJECT CONTACTS ........................................................................................................................... 12 
SUBMIT APPLICATION ......................................................................................................................... 15 

ADDITIONAL INFORMATION ............................................................................. 15 
PAPERWORK REDUCTION ACT STATEMENT .................................................................................. 15 

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Introduction
What is this application for?
 This application is for submitting a Letter of Intent under the Marine Mammal
Protection Act (MMPA) General Authorization (GA) to conduct bona fide
scientific research on marine mammals for activities involving only Level B
harassment1.


Species include these under NMFS’ jurisdiction:
 cetaceans (dolphins, porpoises, and whales)
 pinnipeds (seals and sea lions).

What is this application not for?
 Research on marine mammals listed as endangered or threatened under the
Endangered Species Act (ESA). A list of marine mammals that are listed under
the ESA can be found here: http://www.nmfs.noaa.gov/pr/species/esa/listed.htm.


Research that exceeds Level B harassment. Examples include tagging, biopsy
sampling, and captures.

What types of research usually qualify as Level B harassment?
 Photo-identification/photogrammetry
 Behavioral observations
 Vessel surveys
 Aerial surveys (except over pinniped rookeries at altitudes < 1,000 feet)
 Other activities may also qualify – call us at 301-427-8401 if you have questions.
What if I want to conduct research on endangered or threatened species or
conduct research that exceeds Level B harassment?
 You should apply for a scientific research permit:
http://www.nmfs.noaa.gov/pr/permits/mmpa_permits.html#enhancement.
What is a Letter of Intent and a Letter of Confirmation?
 The GA uses different terminology than other permits. A Letter of Intent (LOI) is
the application you submit. If your activities qualify, you will receive a Letter of
Confirmation (LOC) that allows you to conduct your research.

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Harassment means any act of pursuit, torment, or annoyance which- (Level A Harassment) has the potential to injure a marine mammal or marine mammal stock in the
wild; or,
 (Level B Harassment) has the potential to disturb a marine mammal or marine mammal stock in
the wild by causing disruption of behavioral patterns, including, but not limited to, migration,
breathing, nursing, breeding, feeding, or sheltering but which does not have the potential to injure
a marine mammal or marine mammal stock in the wild.
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What are the advantages of applying under the GA?
 The GA is an expedited process. It does not require a 30-day public comment
period, unlike other permits.
When should I apply?
 At least 4 months before your project will begin, preferably 6 months.
What is the process for getting an LOC?
1. Follow these instructions and contact the Permits and Conservation Division at
301-427-8401 with any questions.
2. Submit your LOI via APPS.
a. An assigned permit analyst will review your LOI.
3. Address any questions on the LOI within 60 days or your application will be
withdrawn.
a. We will deem your LOI complete and draft the LOC and supporting
documentation. This includes the National Environmental Policy Act
analysis, which is reviewed by the appropriate office and signed by the
Office Director.
b. The Division Chief signs the LOC.
4. Keep a copy of your LOC with you during field research.
How do I use APPS?
 Refer to Chapter 2 (“How to Use the System”).


When starting from your portfolio, click on the link of your file number under the
“File Number” column to take you to the application.



Save your application every 20 minutes or you will lose information!



You do not have to complete an application in one session. Your application will
remain in draft mode until you submit.



An * means it is a required field.



If you cut and paste from Word, special characters and formatting may be lost.



Attachments cannot be larger than 10MB – contact us if you have larger files you
need to attach.

Important information
 If you do not follow these instructions, your LOI will be withdrawn and you will
be asked to resubmit a new LOI that includes the information required.


If we request additional information and do not receive it within 60 days, we may
withdraw your LOI.

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

Your LOI must be a stand-alone document and must describe all proposed
activities even when you reference published literature.



The LOI should be free of grammatical errors and readable to a lay person.



You are highly encouraged to contact us at 301-427-8401 with questions in
advance of submitting your application.

Questions?
 Contact the Permits and Conservation Division at 301-427-8401.

Letter of Intent
Project Information
File Number
 This number is automatically generated and cannot be changed. To facilitate
processing, reference this File No. in correspondence with our office.
*Project Title (up to 255 characters)
 Provide a concise title to include the activity, species (or taxa if multiple species),
location, and purpose of the study. For example:
 Boat-based photo-ID of bottlenose dolphins in the Gulf of Mexico to
characterize population structure and movement patterns.
*Project Status
 The project status (New or Renewal) is automatically selected based on your
answers in the pre-application guide (PAG). Do not change this field.
Previous Federal or State Permit #
 If applicable, enter your most recent and closely related NMFS LOC or permit
number. Otherwise leave blank. State permit numbers are not applicable.
*Permits Requested
 MMPA General Authorization will be listed based on your answers in the PAG.
If other options are listed, please call us at 301-427-8401 for assistance.
*Where Will the Activities Occur?
 One or more general locations will be listed based on your answers in the PAG.
If a location is incorrect, please call us at 301-427-8401 for assistance.
*Research Timeframe
 Enter the desired start and end dates of the entire project in the following format:
MM/DD/YYYY. The start date must not be prior to the date you submit the
application and should be at least 4 months after the date you submit. The end

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date must be within five years of the start date because LOCs are valid for a
maximum five year period.
*Sampling Season/Project Duration (up to 1,000 characters)
 Describe the annual field season(s) including the months of the year and
frequency of fieldwork (e.g., when and how many times per year/how frequently
will you conduct the research activities?).
*Abstract (up to 2,000 characters)
 Purpose of the research
 Target and non-target species (common and scientific names)
 Take activities (e.g., boat based photo-ID)
 Specific geographic locations
 Requested duration of the LOC (the maximum is five years).
Project Description
*Project Purpose: Hypothesis/Objectives and Justification (up to 64,000 characters)
 Discuss the purpose of your project including your hypotheses and/or objectives.


Briefly summarize published findings related to your objectives. If you
previously held or worked under an LOC or permit, use literature citations from
that work to show how you previously met your objectives; or, use other
published literature on the subject. Describe how this study is different from,
builds upon, or duplicates past research.



Explain how you determined your sample size. For example, did you base your
numbers on previous encounter rates or abundance estimates for your study area?
If appropriate for your study, include a power analysis or other sample size
estimation to show whether the sample size is sufficient to provide statistically
significant or otherwise robust results appropriate for your study.



The information above should support how your proposed research is bona fide,
including how the results of your research:
 are likely to be accepted for publication in a refereed scientific journal;
 are likely to contribute to the basic knowledge of the species biology or
ecology; or
 are likely to identify, evaluate, or resolve conservation problems.

*Project Description (up to 64,000 characters)
 Methods: Provide clear descriptions of all take methods/procedures for each
species, and the number of animals by age class2 and sex you expect to take by
each method/procedure annually.
2

Define how age classes (e.g., neonate, calf/pup, juvenile, subadult, adult) are distinguished, by taxa or
species.
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

If working with lactating females and dependent calves or pups, indicate their
minimum age and specific protocols for working around them, and how you will
avoid harassment that could result in calf/pup abandonment or injury.



There should be a narrative description for each take action and procedure in the
take table, and vice versa. Further, the take requests in the narrative must match
those in the take table.



Include the purpose of each take activity (i.e., how the take activities relate to
meeting your objectives).



Figures and photographs are useful to illustrate your methods. You can attach
them on the Supplemental Information page.



Cite references for the methods where applicable, but do not substitute a literature
citation in lieu of a complete description of the methods.



See table below for examples of information to include when describing your
methods.

Take action/ procedures
Manned aerial and vessel
surveys

Unmanned aircraft systems
(UAS)

Details to include in methods
-Type of survey craft and vessel
-Type of survey (e.g., line transect, photogrammetry)
-Track lines (maps may be attached separately)
-Number of surveys per year
-Altitude and air speed/distance and vessel speed
-Protocols for breaking track to ID species including minimum
and maximum approach distance and duration spent with
group or individual/day
Same general questions above for aerial surveys and also the
following:
-Type of UAS – fixed wing or vertical takeoff and landing
(VTOL)
-Payload components – what is the UAS carrying?
-Will the UAS ever be beyond the line of sight?
-Does the device have an auto-return feature should the device
fail?
-Ground control station (where is it located - on shore or on
vessel, number of stations, and how close the station will be to
animals)
-Spotter roles needed (e.g., one spotter monitoring the UAS,
another for monitoring the ground control station)
-Battery life
-Do you have the appropriate FAA permits/authorizations
(including pilot licenses)?

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Take action/ procedures
Non-intrusive sampling (e.g.,
behavioral observations via
focal follows and ground
surveys, collecting scat/spew,
photo-ID, underwater
photography, passive acoustic
monitoring photogrammetry,
remote video monitoring)

Details to include in methods
-Approach method
-Sampling method
-Minimum and maximum approach distance
-Within sight of animals or not (e.g., from a blind)?
-Frequency of observations/sampling
-Number of approaches/attempts per animal/day
-Duration of observations/sampling/day
-Data or sample collection and analysis
-If conducting underwater photography/videography, specify
the method (e.g., snorkeling, underwater pole cam, or divers
that could use typical gear or rebreathers) and number of
individuals in the water at a given time



Behavioral Responses/Mitigation: For each method, describe the anticipated
responses (severity and duration of harassment) and the mitigation measures you
use to minimize those responses. If your activities coincide with reproductive
seasons or maternal care, how will you avoid disruption of these sensitive
biological periods and ensure mother-calf/pup pairs are not disrupted? Explain
how your research will not exceed Level B harassment.



Non-target species and conspecifics: Include a list of non-target species that
may be encountered in your study area and whether they will be harassed and
what you will do to minimize harassment.
 The GA cannot authorize you to take threatened or endangered species. If
ESA-listed species occur in your study area, explain how you will avoid
them (e.g., not in area during time of study; would not approach closer
than 100 meters; would halt operations until non-target species moved out
of study area).
 If takes to non-target, non-ESA listed marine mammals may occur,
include these on separate rows in the Take Table to include incidental
harassment of non-target conspecifics or other marine mammals.



Research Coordination: Describe how you collaborate or coordinate with other
researchers in your action area, and who they are. Also, indicate if you will be
contributing to a regional photo-ID catalog.

Project Supplemental Information
Attach a Supplemental Information File
 You can attach files to provide additional information. You can attach a map on
the Location screen.
Attach a References File
 Attach a bibliography of references cited in this application

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Project Locations and Take Information


You will first describe where you plan to work. Then, for each location, you will
use the Take Table to list the species you expect to encounter and the take
procedures you will conduct.



Add New Location: provide information about one (or more) study areas
 General area (ocean basin)
 State(s), as applicable.



Enter Location Details, as applicable:
 Waterbody: enter names of rivers, estuaries, bays, etc.
 Latitude and longitude of your study area
 River miles (Begin Mile and End Mile)
 Limits of your study area (e.g., to the U.S. EEZ, to the edge of the
continental shelf, to 50m depth)
 Names of land masses where research will occur (e.g., islands, rookeries).



Attach File: Include high quality map(s) with the correct scale that clearly shows
the location of your proposed activity and any environmental aspects of interest.
If possible, include a shapefile, Google Earth kmz/kml, or ASCII text file with
lat/long data and the associated basic metadata with your electronic application
submission.

Take Table
The take table represents the estimated number of animals you may harass (take)
annually during your research.
The options that appear in the dropdown menus in the take table are based on the species
group (marine mammals) you indicated in the PAG, the location that you have selected,
and the fact that the GA can only authorize Level B harassment. If you are having
difficulties, please first check that the previous fields were entered correctly.
Columns you will fill out in the take table:
1) Select: Leave this box blank unless you need to copy, move, or delete the line
following the instructions above.
2) Species: Use the drop down list to select. Species are listed alphabetically by
common name and/or category (e.g., dolphin, bottlenose). If the species you are
looking for is not on the drop-down menu, double check your location (species
are populated based on location). If you are still having problems, contact the
Permits Division at 301-427-8401.
Note: The GA is for non-ESA listed species only. You will not have the option
to select endangered or threatened species.
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3) Listing Unit/Stock: Select the applicable stock. Choose Range-wide if, for
example, your location has multiple stocks of the same species and you cannot
distinguish between them while in the field.
4) Production/Origin: Select Wild from the drop-down list.
5) Life Stage: Select from the drop-down list. You may enter take information for
more than one life stage (e.g., adult versus juvenile) on separate rows or select a
combination of life stages for one take category.
6) Sex: Select from the drop-down list. If your activity targets only one sex,
indicate which. If it targets both and they can be targeted separately, enter
separate rows for male and female; otherwise select Male and Female.
7) Expected Take: This represents a reasonable estimate of the number of animals
you will encounter, annually. Under the GA, you will not be limited to this
number or penalized if you exceed this number.
For cetaceans, you will count every animal you approach3 within a certain
distance, regardless of whether a behavioral reaction has occurred.
 Only count 1 take per cetacean per day including all vessel approaches.
 During manned aerial surveys flown at an altitude lower than 1,000 ft,
count 1 take per cetacean observed per day, regardless of the number of
passes over the same animal.
 During Unmanned Aircraft System (UAS) surveys, count 1 take per
cetacean approached per day, regardless of the number of passes.
For pinnipeds, you will only count 1 take per pinniped per day for those that
show movement4 or flushing5 (excluding alert6) to an approach or other permitted
activity, regardless of the number of approaches and behavioral responses of the
same individual in a day. In the description of methods (above), indicate the
number of approaches per animal per procedure per day needed.

3

An "approach" is defined as a continuous sequence of maneuvers involving a vessel, including drifting,
directed toward a cetacean or group of cetaceans closer than 100 yards for baleen whales and 50 yards for
all other cetaceans.
4

Movements in response to the source of disturbance, ranging from short withdrawals at least twice the
animal’s body length to longer retreats over the beach, or if already moving a change of direction of greater
than 90 degrees.

5

All retreats (flushes) to the water.

6

Seal head orientation or brief movement in response to disturbance, which may include turning head
towards the disturbance, craning head and neck while holding the body rigid in a u-shaped position,
changing from a lying to a sitting position, or brief movement of less than twice the animal’s body length.
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8) Takes Per Animal: Estimate the number of times the same identifiable
individual will be encountered, annually, if known. If you are not certain the
same individuals will be encountered, put 1.
9) Take Action: Select Harass.
10) Observe/Collect Method: Select the method of observation (e.g., survey,
vessel). Select only one observe/collect method per row. If various methods will
be used, you must provide take information in separate rows for each observe
method.
11) Procedures: Provide specific information on the research activities that will be
conducted. A separate pop-up window will appear with a species-specific list of
activities. Hold down the Control key to select all activities to be performed
concurrently. Choose Other if your proposed activity is not listed. In the Details
box (see below), briefly describe what the Other means.
Note: The procedures list includes only activities that would qualify as Level B
harassment. For example: observations, behavioral; photo-id; and acoustics,
passive recording.
12) Begin Date: Populated with the Begin Date you entered on the Project
Information page. You may change the date to coincide with a specific project
time shorter than the overall duration of the project. You cannot enter a date that
is earlier than your original Begin Date.
13) End Date: Populated with the End Date you entered on the Project Information
page. You may change the date to coincide with a specific project time shorter
than the overall duration of the project. You cannot enter a date that is later than
the End Date you previously entered.
14) Details: Enter up to 255 characters in this text box to provide details on each take
table row.
National Environmental Policy Act (NEPA) Considerations
In addition to providing information on effects to the target and non-target species in
other sections of the application, provide information as requested below on potential
environmental effects to determine if your activity may be categorically excluded from
the requirement to prepare an environmental assessment or environmental impact
statement under NEPA. If you believe any of the criteria are “not applicable” you must
explain why.
1) If your activities will involve equipment (e.g., scientific instruments) or
techniques that are new, untested, or otherwise have unknown or uncertain
impacts on the biological or physical environment, please describe the equipment
and techniques and provide any information about the use of these in the natural

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environment. In addition, please discuss the degree to which they are likely to be
adopted by others for similar activities or applied more broadly.
2) Describe the physical characteristics of your project location, including:
a. Whether you will be working in or near unique geographic areas including but
not limited to Critical Habitat for endangered or threatened species, Essential
Fish Habitat, National Marine Sanctuaries, Marine Protected Areas, State or
National Parks, Wilderness Areas, Wildlife Refuges, Wild and Scenic Rivers,
etc.
b. Next, discuss how your activities could impact the physical environment in
those locations, such as by direct alteration of substrate during use of
anchoring vessels or buoys, erecting blinds or other structures, or ingress and
egress of researchers, and measures you will take to minimize these impacts.
3) Briefly describe important scientific, cultural, or historic resources (e.g.,
archeological resources, animals used for subsistence, sites listed in or eligible for
listing in the National Register of Historic Places) in your project area and discuss
measures you will take to ensure your work does not cause loss or destruction of
such resources. If your activity will target marine mammals in Alaska or
Washington, discuss measures you will take to ensure your project does not
adversely affect the availability (e.g., distribution, abundance) or suitability of
these animals for subsistence uses.
4) Discuss whether your project involves activities known or suspected of
introducing or spreading invasive species, intentionally or not, (e.g., discharging
ballast water, use of boats/equipment at multiple sites). Describe measures you
would take to prevent the possible introduction or spread of non-indigenous or
invasive species, including plants, animals, microbes, or other biological agents.
Project Contacts
As the person entering the application, you will automatically be assigned the following
roles: Applicant/Permit Holder, Principal Investigator, and Primary Contact. See
Chapter 2 for directions on how to change who is assigned to these roles, and this table.
Project
Contact

Must be named in
the permit
application

Able to make changes to application, Description of
request changes to the permit, and
qualifications required
submit reports; will receive automatic
emails from APPS.

Applicant/
Permit
Holder
Applicant or
Responsible
Party*
Principal
Investigator

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Project
Contact

Must be named in
the permit
application

Able to make changes to application, Description of
request changes to the permit, and
qualifications required
submit reports; will receive automatic
emails from APPS.

Primary
Contact
CoInvestigator
Research
Assistants

* The Applicant/Responsible Party may also be the PI or a CI if participating in the
research; therefore, the description of qualifications is required if they are listed as the PI
or a CI.
To prevent duplicate entries, you MUST ALWAYS search the database for the person
before entering a new contact. To facilitate the search, start with only putting the last
name in APPS search box.
A project must have a Responsible Party if the Applicant/Permit Holder is an
organization, institution, or agency. The Responsible Party or Applicant/Permit Holder is
an official who has the legal authority to bind the organization, institution, or agency and
is ultimately responsible for the activities of any individual operating under the authority
of the permit.
The Principal Investigator (PI) is the individual primarily responsible for the take and
any related activities conducted under the permit. There can only be one PI on a permit.
The PI:
 must have qualifications, knowledge and experience relevant to the activities
authorized by the LOC
 must be on site during activities conducted under the permit unless a CoInvestigator is present to act in place of the PI
 may also be the Applicant/Permit Holder and Primary Contact.
Co-investigators (CIs) are individuals who are qualified and authorized to conduct or
directly supervise activities conducted under an LOC without the on-site supervision of
the PI.
 You may add CIs to the application if the PI will not always be present during the
permitted activities.
 CIs can also be added or removed once a permit has been issued.
Include a table listing the names of the PI and CIs, and the specific procedures they will
oversee or conduct. Attach the table on the Supplemental Information page.

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Example Table Attachment: Personnel Roles
Name/Affiliation
Role
Researcher name,
PI or CI
Affiliation, City,
State
John Smith, Ph.D., Principal Investigator
University A, City,
State
Jane Doe, Ph.D.,
Co-Investigator
Institution B, City,
State

Activities
Specific activities they will
conduct under the LOC and
whether they are supervising
Supervise and perform all
activities under the LOC
Conduct and oversee close
approach and photo-ID

Qualifications and Experience
Federal Regulations require that persons authorized as the PI or CIs have qualifications
commensurate with their duties. In addition, the names of the PI and CIs are sent to the
NOAA Office of Law Enforcement to determine if any violations of the MMPA, ESA,
and other environmental laws have occurred.
The permit applicant is therefore required to submit the following information about the
qualifications and experience of the PI and all CIs to demonstrate they have qualifications
commensurate with their duties as stipulated in the Personnel Table. A CV or resume
must be up to date and contain all relevant information below. If sufficient
experience is not provided, additional information will be required and the personnel will
not be authorized to conduct the proposed activities unless sufficient experience is
demonstrated
1) Contact information - All documentation submitted will be publicly available.
DO NOT include personal information (e.g., social security number, date of birth,
nationality, or home phone/ address-unless it is also the business phone/address).
 Name (first middle last)
 Business phone, e-mail, and mailing address
2) Relevant education and training
 Degree, major, name of institution, year received
 Applicable certificates or licenses, year received
 Other relevant training or certification, year received
3) Relevant experience
 Job title, affiliation/location, and dates
 Detailed description of when and how the individual obtained experience
in the methods they will be conducting and/or supervising as outlined in
the Personnel Table. This should include objective metrics such as:
• The level of training received and who trained them
• The number of hours/months/years they have been performing the
activities and with what species

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• Whether and to what extent they have performed them without
supervision or have supervised the proposed activities
4) List of grants awarded demonstrating available resources relevant to the
proposed activities or history of securing resources for similar work
5) Annotated publication history relevant to the activities being conducted
under the permit
Submit Application
See Chapter 2 for how to submit your application and check on its status.

Additional Information
Under section 104(c)(3)(C) of the MMPA, as amended, persons may be authorized to
take marine mammals in the wild by Level B harassment, as defined in 50 CFR 216.3, for
purposes of bona fide scientific research. Interested persons are required to submit a
letter of intent in accordance with the interim final rule published on October 3, 1994 and
submit certain information outlined at 50 CFR 216.45(b) under the General Authorization
and provided in these instructions. Regulations implementing the GA may be found at 50
CFR 216.45 [59 FR 50376, Oct. 3, 1994] and are available at the following web site:
http://www.nmfs.noaa.gov/pr/laws/50cfr216.txt. MMPA section 104 is available at the
following web site: http://www.nmfs.noaa.gov/pr/pdfs/laws/mmpa104.pdf.
Paperwork Reduction Act Statement
The information requested in this application is required and is used to determine whether
the research described in the letter of intent is likely to exceed Level B harassment of a
marine mammal in the wild, whether a scientific research permit is required to conduct
all or part of the subject research, whether the research as described in the letter of intent
is bona fide, and to determine the effects of the activity on marine mammals and the
environment.
Public reporting burden for this collection of information is estimated to average 10
hours per response (i.e., the above application), including the time for reviewing
instructions, searching existing data sources, gathering and maintaining the data needed,
and completing and reviewing the collection of information. Send comments regarding
this burden estimate or any other aspect of this collection of information, including
suggestions for reducing this burden, to the Chief, Permits and Conservation Division,
Office of Protected Resources, F/PR1, NOAA/National Marine Fisheries Service, 1315
East-West Highway, Silver Spring, MD 20910.
The letter of intent and any associated documents, including any reports required under
the GA, are considered public information and as such, are subject to the Freedom of
Information Act.

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Notwithstanding any other provision of the law, no person is required to respond to, nor
shall any person be subject to a penalty for failure to comply with, a collection of
information subject to the requirements of the Paperwork Reduction Act, unless that
collection of information displays a currently valid OMB Control Number.
OMB No. 0648-0084
Expires: MM/DD/YYYY

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