Instructions for a Marine Mammal General Authorization Letter of Intent

OMB No. 0648-0084; Expires xx/xx/xxxx

National Marine Fisheries Service

Instructions for a Marine Mammal General
Authorization Letter of Intent
TABLE OF CONTENTS

INTRODUCTION .................................................................................................. 2
NEW TO THE GA? HAVE QUESTIONS? ........................................................................................................................... 2
WHEN FILLING OUT YOUR LOI: ....................................................................................................................................... 2
NEED HELP?........................................................................................................................................................................ 3

LETTER OF INTENT ........................................................................................... 3

PROJECT INFORMATION.................................................................................................................................................... 3
*PROJECT PURPOSE: HYPOTHESIS/OBJECTIVES AND JUSTIFICATION ..................................................................... 4
*PROJECT DESCRIPTION ................................................................................................................................................... 5
PROJECT SUPPLEMENTAL INFORMATION ...................................................................................................................... 9
*PROJECT LOCATIONS AND TAKE INFORMATION ........................................................................................................ 9
*TAKE TABLE ...................................................................................................................................................................10
*ANTICIPATED EFFECTS ON THE ENVIRONMENT ......................................................................................................12
*PROJECT CONTACTS ......................................................................................................................................................14
SUBMIT APPLICATION .....................................................................................................................................................16

FREQUENTLY ASKED QUESTIONS ............................................................. 16

WHAT TYPES OF RESEARCH USUALLY QUALIFY AS LEVEL B HARASSMENT? .........................................................16
WHAT ARE A LETTER OF INTENT AND A LETTER OF CONFIRMATION?..................................................................17
WHAT ARE THE ADVANTAGES OF APPLYING UNDER THE GA?.................................................................................17
WHEN SHOULD I APPLY? ................................................................................................................................................17
WHAT IS THE PROCESS FOR GETTING AN LOC? .........................................................................................................17
WHAT IS THE PROCESS FOR REQUESTING AN AMENDMENT TO AN LOC? ..............................................................17
WHAT IF I WANT TO CONDUCT RESEARCH ON ENDANGERED OR THREATENED SPECIES OR CONDUCT
RESEARCH THAT EXCEEDS LEVEL B HARASSMENT? ..................................................................................................18

ADDITIONAL INFORMATION....................................................................... 18
PAPERWORK REDUCTION ACT STATEMENT ........................................ 18

1

Questions or Problems? Contact the NMFS Permits and Conservation Division:
301-427-8401

OMB No. 0648-0084; Expires xx/xx/xxxx

Introduction

These instructions are for submitting a Letter of Intent (LOI) under the Marine
Mammal Protection Act (MMPA) General Authorization (GA) for bona fide scientific
research 1 on non-listed marine mammals for activities involving only Level B
harassment 2.

These instructions are not for research on marine mammals listed as endangered or
threatened under the Endangered Species Act (ESA). See a list of ESA species under
NMFS’ jurisdiction. They are also not for research that exceeds Level B harassment
(e.g., captures, biopsy sampling, or tagging).

New to the GA? Have questions?

We recommend you visit our General Authorization web page or see the FAQ on
page 16.

When filling out your LOI:
•
•
•

•

Refer to Chapter 2 for guidance on how to use APPS.

Save your application every 20 minutes or you will lose information!
You do not have to complete your LOI in one session. Your application will
remain in draft mode until you submit.
An * means it is a required field.

1 Bona

fide scientific research means scientific research on marine mammals conducted by qualified
personnel, the results of which: (i) Likely would be accepted for publication in a refereed scientific
journal; (ii) Are likely to contribute to the basic knowledge of marine mammal biology or ecology.
(Note: This includes, for example, marine mammal parts in a properly curated, professionally
accredited scientific collection); or (iii) Are likely to identify, evaluate, or resolve conservation
problems.

2 Level

B harassment means any act of pursuit, torment, or annoyance which 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.
2

Questions or Problems? Contact the NMFS Permits and Conservation Division:
301-427-8401

OMB No. 0648-0084; Expires xx/xx/xxxx
•

•
•

•

•

•
•

You may want to use these instructions as a template to draft your LOI in a
Word doc and then cut and paste into APPS. However, note that certain
formatting and special characters may be either lost or migrated incorrectly.
Attachments cannot be larger than 20MB – contact us if you have larger files
you need to attach.

Your LOI must be a stand-alone document that describes all proposed
activities and is readable to a layperson.

If you do not follow these instructions, your LOI will be returned and you will
be asked to resubmit a new LOI that includes the information required.
We can only consider those activities that you describe in your LOI.

We will not consider your LOI if you have overdue reports for your most
recent permit or Letter of Confirmation (LOC).

Need help?

We encourage you to contact us with questions before submitting your application.
You can reach us at the phone number on the bottom of this page.

Letter of Intent
Project Information

File Number: This number is generated by APPS 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 that includes
activities, 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 APPS 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.
3

Questions or Problems? Contact the NMFS Permits and Conservation Division:
301-427-8401

OMB No. 0648-0084; Expires xx/xx/xxxx

*Permits Requested: MMPA General Authorization should be listed based on your
answers in the APPS pre-application guide.

*Where Will the Activities Occur? One or more general locations will be listed
based on your answers in the APPS pre-application guide.

*Research Timeframe: Enter the desired start and end dates of the entire project
in the following format: MM/DD/YYYY. The start date cannot be before the date
you submit the application and should be at least 4-6 months after the date you
submit. The end date must be within 5 years of the start date because LOCs are
valid for a maximum of 5 years.
*Sampling Season/Project Duration (up to 1,000 characters)
•
•

Describe your annual field season(s) including
the months of the year.
Include the frequency of fieldwork (e.g., when
and how many times per year will you conduct
the research activities?).

*Abstract (up to 2,000 characters): a short summary
that must include:
•
•

•
•
•

Purpose of the research.
Species that may be harassed (common names).
For research on multiple species, you can
summarize instead of listing every one. For
example: 6 species of cetaceans and 2 species of
pinnipeds.
Take activities (e.g., boat based photo-ID).
Specific geographic locations.
Requested duration of the LOC (the maximum is
5 years).

*Project Purpose: Hypothesis/Objectives and
Justification (up to 64,000 characters)

1. Identify and discuss the research question(s) or
purpose of your project.

Bona Fide Research
The information in your
application should demonstrate
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

4

Questions or Problems? Contact the NMFS Permits and Conservation Division:
301-427-8401

OMB No. 0648-0084; Expires xx/xx/xxxx

2. Briefly summarize published findings related to your research.
• If you previously held or worked under an LOC or research permit,
use literature citations from that work to show how you previously
met your objectives; and/or
•

Use other published literature on the subject.

3. Describe how this study is different from, builds upon, and/or duplicates past
research.
4. Explain how you estimated your take numbers (see guidance on pages 10-11
for how to count take).
• For example, did you base them on previous encounter rates or
abundance estimates for your study area and the number of surveys
to be conducted?
•

•

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.

Indicate the number of times known individuals will be intentionally
harassed in a year. Explain why these takes are needed to meet your
objectives.

*Project Description (up to 64,000 characters)

Methods
Describe your methodologies. Your narrative description must match your APPS
take table (see Take Table section below). Every procedure listed in the take table
must be described here. It is helpful to reference take table lines in the narrative
that correspond to the take actions and procedures. Be sure to provide:
•

•
•

Clear descriptions of all methods (i.e., procedures) for each species. See
Additional Guidance section below.
A brief statement of each method’s purpose (i.e., how the activity relates to
meeting your objectives).
Define how you differentiate age classes (e.g., neonate, calf/pup, juvenile,
subadult, adult). If applicable, distinguish by taxa or species.
5

Questions or Problems? Contact the NMFS Permits and Conservation Division:
301-427-8401

OMB No. 0648-0084; Expires xx/xx/xxxx

•

•
•
•

•

If working with dependent calves/pups, their moms, or known pregnant
females, give specific protocols for working around them, including how you
will avoid separating mothers from calves/pups.
Mitigation measures that are inherent to your methods may be included in
this section or in the Effects and Mitigation section below.
Figures and photographs that illustrate your methods. You can attach them
on the Project Supplemental Information page.
Citations for the methods where applicable, but do not substitute a literature
citation in lieu of a complete description of the methods. You can attach a
Literature Cited on the Project Supplemental Information page. References
must be made available upon request.
See Additional Guidance section below.

Additional Guidance for Commonly Used Methods:
Aerial, ground, and vessel surveys

Type of aircraft and vessel
Type of survey (e.g., line transect, photogrammetry)
Track lines (maps may be attached separately)
Number of surveys per year
Air speed
Vessel speed
Minimum altitude or approach distance to animals
Protocols for breaking track to ID species
Protocols for approaching on land, whether a blind or cover will be used
Number of platforms (aircraft and vessel) to be operated at the same time
Duration spent with group or individual/day
Unmanned aircraft systems (UAS)
Provide the general aerial survey information above and the following:

Type of UAS – fixed wing or vertical takeoff and landing (VTOL)
Payload components – what is the UAS carrying and for what purpose (e.g., camera,
sensor)?
Ground control station (what it is, where is it located - on shore or on vessel,
number of stations, and how close the station will be to animals)
Encounter duration – maximum amount of time over same animals
6

Questions or Problems? Contact the NMFS Permits and Conservation Division:
301-427-8401

OMB No. 0648-0084; Expires xx/xx/xxxx

Number of platforms (UAS) to be operated at the same time
Do you have the appropriate FAA permits/authorizations (including pilot licenses)?
Remotely operated vehicle (ROV), vessel or amphibious
For underwater and amphibious ROVs, same details as for vessel surveys and also:
Description and size of ROV
Whether it is tethered or wireless, tether material and length
Describe any light sources
Whether there will be a live video feed monitored
Encounter duration

Data collection
Examples include behavioral observations via focal follows and ground surveys,
collecting scat/spew, photo-ID, passive acoustic monitoring, photogrammetry, and
remote video monitoring.
Be sure to discuss the following, as applicable:

Approach method (e.g., by foot, vessel or aircraft)
Filming/photography equipment and methods
Minimum approach distances
Within sight of animals or not (e.g., from a blind)?
Number of observations/sampling per year
Frequency of observations/sampling per year (e.g., monthly)
Samples to be collected and method (e.g., scat by hand)
Number of attempts per animal/day for biological sampling
Duration of observations/sampling/day
Data analysis
Underwater photography/videography

Method (e.g., snorkeling, underwater pole cam, conventional scuba gear, or rebreathers)
Maximum number of individuals in the water at a given time and their roles
(including safety divers)
Minimum approach distance to animals
Maximum amount of time spent with same animals/day
7

Questions or Problems? Contact the NMFS Permits and Conservation Division:
301-427-8401

OMB No. 0648-0084; Expires xx/xx/xxxx

Effects and Mitigation:
You may include mitigation and monitoring protocols here, or above in your
methods. Do not restate them here if they are included above; simply reference the
section where the following information is found.
•

•

•

For each method (procedure), describe the anticipated responses of the
animals (type, severity, and duration of harassment).
Describe what you will do to minimize those responses, including:
o If your activities coincide with reproductive seasons or maternal care,
how will you avoid disrupting these sensitive periods and ensure mothercalf/pup pairs are not separated?
o Explain how your research will not result in injury or mortality.
o Describe if you will employ mitigation measures when you observe
unintended adverse reactions. If you would use the same measures for
a suite of activities, you may provide one discussion for that suite of
activities.
o If applicable, you can cite an ethogram to illustrate potential responses.
Please describe any mitigation you will take to avoid or minimize impacts to
non-target protected taxa (e.g., sea turtles, corals, USFWS species). Discuss
whether and how they may be incidentally harassed or otherwise affected.

Non-target Marine Mammals:
Discuss whether and how non-target marine mammals may be encountered in your
study area. These are species that co-occur with your target species and that could
be harassed or taken during your research.
•

•

The GA cannot authorize you to take threatened or endangered species. If
ESA-listed species occur in your study area, explain how you will identify and
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 as separate rows in your Take Table with incidental harassment in the
8

Questions or Problems? Contact the NMFS Permits and Conservation Division:
301-427-8401

OMB No. 0648-0084; Expires xx/xx/xxxx

procedure column. These could be non-target conspecifics or other species
of marine mammals.

Research Coordination
• Include the names and affiliations of other researchers you will coordinate
with and specifically how this will occur to minimize repeated disturbance to
marine mammals.
• Indicate how you will collaborate with other researchers, including if you
will be contributing to a regional photo-ID catalog or otherwise sharing data.

Project Supplemental Information

Attach a Supplemental Information File
You can attach up to 10 files to provide additional information.
• Preferred file formats: Word, Excel, PDF, or text.
• The maximum file size allowed is 20 MB.
• Audio and video files (such as mp3, m4b, wav) cannot be uploaded. Contact
us if you need assistance.
• On the Location screen you will be asked to attach a map.

Attach a References File
Attach a bibliography of references cited in your LOI. Referenced materials must be
made available upon request, as needed for evaluation of the LOI or preparation of
any necessary NEPA analyses. If a link to your referenced material is available, add
the link to your References File.

*Project Locations and Take Information

First, you will 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.
1. Add New Location: provide information about one or more study areas
• General area (ocean basin)
• State(s), as applicable.
2. Enter Location Details, as applicable:
• Waterbody: enter names of rivers, estuaries, bays, etc.
9

Questions or Problems? Contact the NMFS Permits and Conservation Division:
301-427-8401

OMB No. 0648-0084; Expires xx/xx/xxxx
•
•

•

Latitude and longitude of your
study area
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).

3. Attach File: Include high quality map(s)
to scale that clearly shows the location of
your proposed activity and any
environmental aspects of interest.
Include a shapefile, Google Earth
kmz/kml, or ASCII text file of the project’s
location and the footprint of the affected
area with lat/long data and the associated
basic metadata.

*Take Table

The take table summarizes the estimated
number of animals you expect to encounter
annually during research. See the sidebars on
the following pages for guidance on how to count
animals.
Columns you will fill out in the take table:
1. Select: Leave this box blank unless you
need to copy, move, or delete the row.

2. Species: Use the drop down list. The GA
is for non-ESA listed species only. You
cannot select endangered or threatened
species.

3. Listing Unit/Stock: Select the applicable
stock. Choose Range-wide if your location
has multiple stocks of the same species
and you cannot distinguish them while in
the field.
10

How to count takes
of pinnipeds

Count 1 take per animal per day
for those hauled-out animals
that react to the research,
regardless of the number of
responses, including:
•
•
•

movements of twice the
animal’s body length or
more,
changes of direction greater
than 90 degrees, or
retreats (flushes) to the
water.

Count 1 take per animal per day
for those animals in water that
exhibit a noticeable adverse
behavioral response from your
activities
Do not count alert behaviors
such as:
•
•
•
•

turning head towards the
disturbance,
craning head and neck while
holding the body rigid in a ushaped position,
changing from a lying to a
sitting position, or
brief movements of less than
twice the animal’s body
length.

Questions or Problems? Contact the NMFS Permits and Conservation Division:
301-427-8401

OMB No. 0648-0084; Expires xx/xx/xxxx

4. Production/Origin: Select Wild.

5. Life Stage: Select from the drop-down list. You
may enter take information for more than one life
stage (e.g., adult and 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 and pinnipeds: in the Project
Description, you must indicate how many times
per day you would approach the same animal or
group of animals as well as how many times per
year you will target the same group of animals.

8. Take Action: Select Harass.

9. Observe/Collect Method: Select the method of
observation (e.g., survey, vessel). If various
methods will be used, you must provide take
information in separate rows. If you will be
approaching animals from a boat to fly UAS
surveys, select “survey, aerial/vessel.”

How to count
takes of
cetaceans

Count every animal
approached regardless of
whether a behavioral
reaction has occurred.

During vessel surveys, only
count 1 take per animal per
day including all
approaches. An “approach”
is defined as a continuous
sequence of maneuvers
involving a vessel,
equipment, or researcher’s
body, including drifting,
directed toward a cetacean
or group of cetaceans closer
than 100 yards for baleen
and sperm whales and 50
yards for all other cetaceans.

During aerial surveys
(manned or UAS) flown at an
altitude lower than 1,000
feet, count 1 take per animal
observed per day, regardless
of the number of passes over
the same animal.

10. Procedures: Provide specific information on the
research activities that may cause Level B
harassment. 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.
11

Questions or Problems? Contact the NMFS Permits and Conservation Division:
301-427-8401

OMB No. 0648-0084; Expires xx/xx/xxxx

a. Choose Other if your proposed activity is not listed. In the Details box
(see below), briefly describe what the Other means.

11. 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 that is shorter than the overall duration of the project.

12. End Date: Populated with the End Date 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.
13. Details: You may enter up to 255 characters in this text box to provide
details on each take table line. This is especially useful for clarifying age
class, takes, intentional repeated takes, specific activities, or projects.

*Anticipated Effects on the Environment

1. Will you be working in or near areas with unique environmental
characteristics or important scientific, cultural or historical resources?
Examples include:
•
•
•
•
•
•
•
•
•
•
•
•
•
•

Animals used for subsistence
Archaeological resources
Critical Habitat of ESA-listed species
Essential Fish Habitat including wetlands, coral reefs, sea grasses, and
rivers
Federally recognized Tribal and Native Alaskan lands, cultural or natural
resources, or religious or cultural sites
Marine Protected Areas
Minority or low-income communities
National or State Parks
National Marine Sanctuaries and National Monuments
National Historic Landmarks
Sites listed in or eligible for listing in the National Register of Historic
Places
Wild and Scenic Rivers
Wilderness Areas
Wildlife Refuges
12

Questions or Problems? Contact the NMFS Permits and Conservation Division:
301-427-8401

OMB No. 0648-0084; Expires xx/xx/xxxx

a. If yes, please list those areas. As applicable, mention if you will need to or
have already obtained permission (licenses, permits, authorizations) to
work in these areas.
b. How would your activities affect such resources? What measures will
you take to ensure your work does not cause loss or destruction of such
resources?
c. For marine mammal activities in Alaska or Washington, how will you
ensure your project does not adversely affect the availability (e.g.,
distribution, abundance) or suitability (e.g., food safety) of marine
mammals for subsistence uses?

2. Discuss if your activities have the potential to impact the physical or
biological environment, in particular coastal and marine environments.
Impacts can be positive or negative. Examples of potential impacts include:
•
•
•
•
•
•
•

Altering substrate while anchoring vessels and buoys.
Using bottom trawls or other types of nets.
Erecting blinds or other structures.
Ingress and egress of researchers.
Injuring or killing benthic organisms (e.g., sea grass, corals).
Altering the physical or chemical characteristics of water (e.g., oil
spills)
Affecting a species’ abundance or distribution.

3. Does your project involve activities known or suspected of introducing or
spreading invasive species, intentionally or not? Examples include
transporting animals or other biological specimens, discharging ballast
water, and using 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.

4. Will your activities involve collecting, handling, or transporting potentially
infectious agents or pathogens, such as biological specimens (animals, blood,
tissues)?
13

Questions or Problems? Contact the NMFS Permits and Conservation Division:
301-427-8401

OMB No. 0648-0084; Expires xx/xx/xxxx

Will your activities involve using or transporting hazardous substances, such
as toxic chemicals?
If yes to either question, describe the protocols you will use to ensure that
public health and human safety are not adversely affected, such as by spread
of zoonotic diseases, chemical injuries, or contamination of food or water
supplies.

5. Do your activities involve equipment (e.g., scientific instruments) or
techniques that are new, untested, or have unknown or uncertain impacts on
the biological or physical environment?
If yes:

a. Briefly describe the equipment or techniques and provide any
information about the use of these in your study area, other areas,
and/or with other taxa.

b. Discuss the degree to which they are likely to be adopted by others for
similar activities or applied more broadly.

*Project Contacts

As the person entering the application, you will automatically be assigned the
following roles: Applicant/Permit Holder, Principal Investigator, and Primary
Contact.

1. You may need to change or add personnel. See Chapter 2 for directions on
how to change who is assigned to these roles.
2. Use the guidance below to help you decide who should have what role.
3. To prevent duplicate entries, ALWAYS search APPS for the person before
entering a new contact. Start with only putting the last name in APPS
search box.
4. Include a table (see example Table 2) 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.
5. As you add personnel, check whether each person already has a
Qualifications Form (QF) in APPS. It will appear next to their name once
you add them to your Contacts page. If there is not a QF in APPS, then attach
one for the PI and each CI. See Qualifications and Experience below.
14

Questions or Problems? Contact the NMFS Permits and Conservation Division:
301-427-8401

OMB No. 0648-0084; Expires xx/xx/xxxx

Descriptions of Personnel Roles
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 LOC. There can only be one PI on an
LOC. The PI:

Must have qualifications, knowledge, and experience relevant to the activities
authorized by the permit
● 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.
●

The Primary Contact is the person primarily responsible for correspondence
during the application review process and after a permit is issued. Typically this
person administers the LOC, requests amendments/modifications (e.g., personnel
changes, filming requests), and submits reports. The Primary Contact may also
serve other roles on the permit (e.g., Applicant/Permit Holder, PI, CI).

The Applicant/Permit Holder or Responsible Party, PI, and Primary Contact
will have access to APPS to enter and edit the application, submit reports and
modification requests, and will receive automatic emails from APPS.
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 an LOC has been issued.
●

15

Questions or Problems? Contact the NMFS Permits and Conservation Division:
301-427-8401

OMB No. 0648-0084; Expires xx/xx/xxxx

Research Assistants (RAs) are individuals who work under the direct and on-site
supervision of the PI or a CI. RAs cannot conduct permitted activities in the absence
of the PI or a CI. RAs do not need to be named in the application or permit.
Qualifications and Experience

The PI and each CI must have a Qualifications Form (QF). Previously we accepted
CVs, resumes, and biosketches, but often these did not include sufficient information
about the person’s field experience. The QF is designed to give us the information
we need. Once you fill out a QF and attach it to your profile in APPS you won’t have
to do it again, unless your skills or experience change. Each contact should only
have 1 QF file in their profile; they may replace the existing file with an updated
version as they gain new experience.
Persons authorized as the PI or CIs must have qualifications corresponding to their
duties. If you do not provide sufficient information, we will not authorize the
person(s) to conduct the research or enhancement activities.

In addition, you must submit a table (see Table 1) defining the roles and activities to
be performed for the PI and each CI listed in the LOI.
Table 1. Example Personnel Roles
Name/Affiliation

Role

John Smith, Ph.D.,
University, City, State

Principal
Investigator

Jane Doe, Ph.D.,
Institution, City, State

Co-Investigator

Activities
Supervise and perform all
activities under the LOC

Conduct and oversee close
approach and photo-ID

Submit Application

See Chapter 2 for how to submit your application and check on its status.

Frequently Asked Questions

What types of research usually qualify as Level B harassment?
•

Photo-identification/photogrammetry
16

Questions or Problems? Contact the NMFS Permits and Conservation Division:
301-427-8401

OMB No. 0648-0084; Expires xx/xx/xxxx
•
•
•
•

Behavioral observations
Vessel surveys
Aerial surveys, manned or unmanned (except those over pinniped rookeries
at altitudes < 1,000 feet)
Other activities may also qualify – call us at the number on the bottom of the
page if you have questions.

What are a Letter of Intent and a Letter of Confirmation?

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.

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 prior.

What is the process for getting an LOC?

1. Follow these instructions and contact the NMFS Permits and Conservation
Division with any questions.
2. Submit your LOI via APPS.
a. A permit analyst will review your LOI and contact you if additional
information is needed.
3. Address any questions within 60 days or your LOI will be withdrawn.
a. Once we consider your LOI complete, we will draft the LOC and
supporting documentation, including the National Environmental
Policy Act analysis and other information.
b. The Division Chief will sign the LOC if your proposed activities are for
bona fide research and Level B harassment only.
4. Keep a copy of your LOC with you during field research.

What is the process for requesting an amendment to an LOC?

Use APPS to request an amendment to your LOC. You’ll need to provide a
description of your proposed changes and include all the necessary details for those
changes, as applicable. Use these application instructions as a guide. For example,
changes to your objectives will require that you discuss all the points in the Project
Purpose section. Additions to personnel require Qualifications Forms and
descriptions of their roles.
17

Questions or Problems? Contact the NMFS Permits and Conservation Division:
301-427-8401

OMB No. 0648-0084; Expires xx/xx/xxxx

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. Visit our scientific research
permit web page or use the APPS Pre-Application Guide to start an application.

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:
https://www.gpo.gov/fdsys/granule/CFR-2009-title50-vol7/CFR-2009-title50vol7-sec216-45. MMPA section 104 is available at the following web site:
https://www.fisheries.noaa.gov/marine-mammal-protection-act.

Paperwork Reduction Act Statement

The information requested in this application is required. It will be used to
determine:
•
•
•
•

whether the research described in the LOI 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 LOI is bona fide, and
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
18

Questions or Problems? Contact the NMFS Permits and Conservation Division:
301-427-8401

OMB No. 0648-0084; Expires xx/xx/xxxx

and Conservation Division, Office of Protected Resources, F/PR1, NOAA/National
Marine Fisheries Service, 1315 East-West Highway, Silver Spring, MD 20910.

The LOI 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.

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.

19

Questions or Problems? Contact the NMFS Permits and Conservation Division:
301-427-8401