MMPA-ESA-Research-Enhance-Application

Basic Requirements for Special Exemption Permits and Authorizations to Take, Import, and Export Marine Mammals, Threatened and Endangered Species, and for Maintaining a Captive

MMPA-ESA-Research-Enhance-Application

OMB: 0648-0084

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

National Marine Fisheries Service

Marine Mammal Scientific Research and
Enhancement Permit Application

TABLE OF CONTENTS
INTRODUCTION.................................................................................................. 2
NEED HELP OR HAVE QUESTIONS? ........................................................................................................... 2
WHEN FILLING OUT YOUR APPLICATION: ................................................................................................ 2

APPLICATION INSTRUCTIONS ....................................................................... 3

PROJECT INFORMATION............................................................................................................................. 3
PROJECT DESCRIPTION PAGE ................................................................................................................... 4

PROJECT SUPPLEMENTAL INFORMATION ............................................................................................. 15
CAPTIVE INFORMATION........................................................................................................................... 20
PROJECT LOCATIONS................................................................................................................................ 24

TAKE TABLE.............................................................................................................................................. 24
ANTICIPATED EFFECTS ON THE ENVIRONMENT .................................................................................. 27
PROJECT CONTACTS ................................................................................................................................. 29
SUBMIT APPLICATION.............................................................................................................................. 33

ADDITIONAL INFORMATION ....................................................................... 33

WHEN SHOULD I APPLY? ......................................................................................................................... 33
WHAT IS THE PROCESS FOR GETTING A PERMIT?................................................................................. 33
WHAT IS THE PROCESS FOR REQUESTING AN AMENDMENT TO A PERMIT? ...................................... 34

APPLICABLE LAWS AND REGULATIONS .................................................. 34
PAPERWORK REDUCTION ACT STATEMENT ......................................... 35

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Introduction

This application is for requesting a Marine Mammal
Protection Act (MMPA) and Endangered Species
Act (ESA) scientific research or enhancement
permit to take, 1 import, or export National Marine
Fisheries Service (NMFS) marine mammals:
•
•

Cetaceans (dolphins, porpoises, and whales)
Pinnipeds (seals and sea lions)

•

For work with endangered species, please see our
webpage on programmatic permitting to determine if
your methods qualify and when to submit your
application on the appropriate cycle.

•

Visit our MMPA scientific research and enhancement
permit web page, see Additional Information on p. 33,
or contact us at [email protected].

•

Need help or have questions?

When filling out your application:
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•

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Your application must be a stand-alone
document, readable to a layperson.

If you do not follow these instructions, your
application will be returned.

We will not consider your application if you
have overdue reports.

•

•
•
•

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

An * indicates a required field.

Consider using these
instructions as a template to
draft your application in Word.
Then cut and paste into APPS.
Special characters may be
either lost or migrated
incorrectly.

Refer to Chapter 2 for how to
navigate APPS.

Your application will remain in
draft mode until you submit.
Attachments cannot be larger
than 20MB – contact us if you
need to attach larger files.

1A take under the MMPA means to harass, hunt, capture, collect, or kill, or attempt to harass, hunt, capture,

collect, or kill any marine mammal. This includes, without limitation, any of the following: the collection of
dead animals, or parts thereof; the restraint or detention of a marine mammal, no matter how temporary;
tagging a marine mammal; the negligent or intentional operation of an aircraft or vessel, or the doing of any
other negligent or intentional act which results in disturbing or molesting a marine mammal; and feeding or
attempting to feed a marine mammal in the wild. Under the ESA, a take means to harass, harm, pursue, hunt,
shoot, wound, kill, trap, capture, or collect, or attempt to do any of the preceding.
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You will need to enter this information in our online permit system, APPS
https://apps.nmfs.noaa.gov/.

Application Instructions
Project Information

File Number: This number is generated by APPS and cannot be changed. To facilitate
processing, reference this File Number 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. For example:
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Vessel surveys, sampling, and tagging cetaceans in the Gulf of Mexico to characterize
population structure, foraging ecology, 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.

Previous Federal or State Permit #: If applicable, enter your most recent and closely
related NMFS permit number. Otherwise leave blank.

*Permits Requested: One or more permits will be listed based on your answers in the
APPS PAG. If the options are incorrect, please contact us at [email protected].

*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. Currently, the maximum duration for an MMPA permit is
5 years. See Additional Information on p. 33 for details about when to apply. Consult our
programmatic permitting web page if studying threatened and endangered species.
*Sampling Season/Project Duration (up to 1,000 characters): Describe the annual
season(s) of work including the months and frequency (i.e., when and how many times per
year/how frequently will you conduct your activities?). If year-round, indicate when
activities are most likely to occur and how frequently.
*Abstract (up to 2,000 characters): provide a short summary that must include:
•

Purpose of the research or enhancement.
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Species that may be taken, imported, or exported
(common names). If you are requesting takes of a
large number of species, you may list taxa instead of
all species. For example: 20 species of cetaceans and
10 species of pinnipeds.
Take activities (e.g., vessel based surveys, remote
biopsy sampling, tagging), import, or export.

Where your activities will occur and where animals
or samples will be imported or to where they will be
exported.
Requested duration of the permit.

Project Description Page

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

We recommend you provide the information in this order:

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:
•

•

•

1. Discuss the need for the research and the research
questions you want to answer.

Be accepted for publication
in a refereed scientific
journal;
Contribute to the basic
knowledge of the species
biology or ecology; or

Identify, evaluate, or resolve
conservation problems.

2. Briefly summarize published findings related to your research.
•

•

If you previously held or worked under a permit, use literature citations from
that work to discuss how you previously met your objectives; and
Use other published literature on the subject.

3. Describe how this study is different from, builds upon, or duplicates past research.

4. If proposing novel procedures, include a discussion on results from pilot studies or
studies on other species, if available.
5. For research on ESA-listed and MMPA-depleted species:
•

Discuss why your project must involve ESA-listed or MMPA-depleted species
(e.g., explain why similar results could not be obtained by using a surrogate or
captive species).
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Discuss how your project will, as applicable:

o Contribute to the objectives identified in the species’ recovery or
conservation plan or otherwise respond to recommendations of a scientific
body charged with management of the species;

o Contribute significantly to understanding the basic biology or ecology of the
species; and/or
o Contribute significantly to identifying, evaluating, or resolving conservation
problems.

6. If your goals are to directly enhance the survival or propagation of an ESA-listed
or MMPA-depleted species, you must:
•

Explain how your project will:

o Contribute to maintaining or increasing distribution or abundance,
o Enhance the health or welfare of the species,
o Enhance or benefit the wild population, or

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o Ensure the recovery of the species in the wild.

For captive maintenance for enhancement, explain how you will:
o Maintain a viable gene pool,
o Increase productivity,

o Provide necessary biological information, or
•

o Establish animal reserves.

How does the benefit of removing animals from the wild into captivity outweigh
alternatives that do not require removal from the wild? What plans are in place
for returning animals and any offspring to the wild? Justify maintaining animals
in permanent captivity.

7. Identify your objectives or hypotheses based on the above information.

8. Take Number Rationale: Explain how you determined your sample size or take
numbers and why they are needed to meet the objectives (see guidance on pages
24-26 for how to count take).
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For example, did you base your numbers on previously reported 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.

Your take numbers should be realistic based on your future research plans as
well as your previous experience. We will examine reported take numbers from
your annual reports and compare those to the take numbers you are requesting
in your new application.

For activities such as remote biopsy sampling and tagging of cetaceans, please
discuss your expected hit vs. miss rate and how you incorporated that factor into
your proposed take numbers. For example, if your goal is to obtain 30 samples,
but you’re requesting 40 takes, explain that the additional 10 takes are to allow
for some shots that contact the animal but do not take a sufficient sample. 2

Discuss whether the same individual animals may be taken more than once
a year.

o If individual animals cannot be identified in real time, estimate how many
animals may be taken repeatedly, maximum number of times an animal may
be taken annually, and under what circumstances (e.g., multiple surveys in
the same location).
o If individual animals can be identified in real time, indicate the number of
times known individuals may be intentionally taken in a year (e.g., repeat
surveys in the same area for identifiable individuals). Explain why multiple
takes of the same individual are needed to meet your objectives

*Project Description (up to 64,000 characters)

For work with endangered species, please see our webpage on programmatic permitting
to determine if your methods fall under a programmatic ESA Section 7 biological opinion
with expedited processing. If you wish to have your work covered by a programmatic
If all tagging or biopsy attempts are unsuccessful on a single day and you do NOT make contact with the
animal, you will count that take on your Level B harassment take row. If any attempts make contact with the
animal, even if unsuccessful, you will count the take against your sampling or tagging row. Report one take
per animal per day regardless of the number of attempts or approaches.

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opinion, please ensure that your described methods fit within its scope. Please contact us if
you have questions.

Overview
Provide a brief overview of a typical day in the field or facility and the suite of activities
you intend to perform on each animal during an encounter or capture event. Discuss the
order in which you’ll perform the different methods. Include where your work will happen,
especially if different projects occur in different locations.
Methods
Describe your methods. Your narrative description must match your APPS take table (see
Take Table section below).
You must provide:
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Clear descriptions of all methods (i.e., each take action and procedure in your
APPS take table). See Table 1 below for guidance on what details to include.
A brief statement of each method’s or suite of methods’ purpose (i.e., how the
activities relate 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
For each method/procedure, state if you will target:
o Calves/pups (specify age/dependency);

o Females accompanying calves/pups (specify age/if lactating);

o Pregnant females, and if so, include estimated trimester; and/or

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o Compromised animals.

List out the suite of procedures that will be performed on only a subset of animals
and explain how you will decide which animals will receive which procedures. Is
this based on sex, life stage, body size, body condition, health or appearance, needed
sample size, etc.?
If you have multiple projects, it is helpful to name them by project number or title
and include project names in the Details column of the Take Table.
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It is also helpful to reference take table lines in the narrative that correspond to the
take actions and procedures.

For intrusive 3 procedures, sensitive life stages (e.g., obviously pregnant females,
calves/pups) should be on separate rows in the take table if they will be sampled or
handled differently to other life stages.
If your work will occur concurrently with other legal takes of marine mammals
(e.g., tagging an animal following its exposure to an acoustic trial under another
authority), clarify which activities you are requesting and how they will occur in
relation to the other legal action. Specify how the associated activities are legally
covered under the MMPA and/or ESA.
Discuss whether animals of the same species (i.e., conspecifics) may be taken (e.g.,
harassed, captured) during your work.
Data analysis: Provide a brief description of how data and/or samples will be
analyzed.

Opportunistic research: If there are species that are not your main research focus,
but that you would approach and study if opportunistically encountered, include a
discussion of them in this section. Describe how the research would fit within your
objectives and which methods you would use to study these species. Include rows
for these species in your take table.
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.

Intrusive research means a procedure conducted for bona fide scientific research involving: A break in or
cutting of the skin or equivalent, insertion of an instrument or material into an orifice, introduction of a
substance or object into the animal's immediate environment that is likely either to be ingested or to contact
and directly affect animal tissues (i.e., chemical substances), or a stimulus directed at animals that may
involve a risk to health or welfare or that may have an impact on normal function or behavior (i.e., audio
broadcasts directed at animals that may affect behavior).

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For captive animals held for public display , this definition does not include: (1) A procedure conducted by the
professional staff of the holding facility or an attending veterinarian for purposes of animal husbandry, care,
maintenance, or treatment, or a routine medical procedure that, in the reasonable judgment of the attending
veterinarian, would not constitute a risk to the health or welfare of the captive animal; or (2) A procedure
involving either the introduction of a substance or object (i.e., as described in this definition) or a stimulus
directed at animals that, in the reasonable judgment of the attending veterinarian, would not involve a risk to
the health or welfare of the captive animal.
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Cite references for the methods where applicable, but do not substitute a literature
citation for 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.

Table 1. Guidance on Describing Commonly Used Methods
When describing your methods, include the following information, as applicable:
Take action/
procedures
Active acoustics
(all)

Active acoustics
(for behavioral
response studies)

Method Description Guidance

Sound source (e.g., echosounder, underwater speaker, acoustic deterrent
device)
Beam width
Water depth or depth range if applicable
Frequency (bandwidth)
Maximum source level (specify metric SELcum or SPL RMS)
Maximum received level
Distance of source to target and non-target animals
Signal duration and duty cycle
Number of exposures/trials in a day and whether you will target the same
animal(s) more than once
Duration of each sound exposure and maximum total duration of sound
emission per 24-hr period
How many sound source types might be used within a 24-hr period
Ambient sound level, when known
Distance to the relevant 120 dB/ 160 dB re 1µPa Level B Harassment
thresholds and permanent threshold shift (Level A harassment threshold)
Post playback monitoring (monitoring distance and duration)
Please include all of the details above in the Active Acoustics section. If
working with a variety of sound sources, be sure to include these details for
a “typical” playback scenario as well as a worst-case scenario (e.g. source
level, received level, duty cycle, frequency, maximum exposure duration,
etc.). Make sure to consider all functional hearing groups, including target
and non-target exposures.
We strongly recommend consulting the NMFS 2018 User Spreadsheet and
accompanying instructions. Be sure to specify if your source is impulsive
(direct from source) or non-impulsive (playback via speaker).

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Take action/
procedures
Active acoustics
(for playbacks of
natural sounds/
vocalizations)

Administer
drugs or other
substances (e.g.,
stable isotopes)

Aerial and
vessel surveys
(manned)

Aerial surveys
using
unmanned
aircraft systems
(UAS)

Method Description Guidance
Species of vocalization
Source level of the call playback
Estimated source level of the call in nature and any supporting evidence
Duration of the vocalization
Frequency of the vocalization (if a range, include highest and lowest
frequencies)
If the vocalizations do not exceed the expected source level, frequencies, or
duration of natural calls in the wild, no further detail is required.
If the vocalizations are being manipulated, please include the details
described in the “Active Acoustics (all)” section above.
Name of each drug/chemical and its purpose, including for
reversal/recovery
Emergency response and euthanasia drugs and protocols
Dosage of each drug/chemical
Delivery method and route (e.g., dart gun, inhalation, intramuscular,
intravenous, subcutaneous, topical); if dart gun: distance of pinniped to
water
Location of administration on body
Duration of anesthesia or sedatives
Post drug administration monitoring
Optional: you may include a drug table with the information requested
above
Number of surveys per year
Type and size of survey aircraft or vessel
Number of aircrafts and/or vessels to be operated at the same time
Type of survey (e.g., line transect, photogrammetry)
Minimum altitude/approach distance
Air/vessel speed
Protocols for breaking track to ID species
Duration spent with group or individual per day
Number of surveys per year
Type of and size of UAS and/or vessel
Number of aircrafts and/or vessels to be operated at the same time during
an encounter
Type of survey (e.g., line transect, photogrammetry)
Minimum altitude
Air speed
Protocols for breaking track to ID species
Duration spent with group or individual per day
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 description (what it is, where it will be located-on
shore or on vessel, number of stations, and how close the station will be to
animals)
Do you have the appropriate FAA permits/authorizations (including pilot
licenses)?
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Take action/
procedures
Auditory
brainstem
response or
evoked
potential

Capture and
restraint

Method Description Guidance
Type of sounds emitted (e.g., pips, clicks, tones)
Maximum source level
Whether animal will be transported to a facility (complete the Transport
Section in Take Table)
Distance and position from speaker relative to target animal
Signal duration, duty cycle, and frequency of sound emitted
Total duration of sound emission (including total exposure duration within a
24-h period)
Handling/restraint methods (including anesthesia/sedation, see above)
Type of measurement equipment (suction cup or needle electrodes) and
location on animal?
Handling duration
Type of capture (e.g., hand, hoop net, trap) and gear description (e.g., net
dimensions and mesh size)
Deployment methods (e.g., on foot or boat approach, number of boats, net
deployment, soak times)
Configuration, duration, and monitoring of net sets (how often net set is
checked)
Additional equipment or personnel necessary for capturing and handling
excess numbers
Number of animals captured at a time
Number of animals processed at a time
Dimensions and type of holding container/manner of restraint
Anesthesia/sedation (see Administer Drugs above)
If capturing females with calves/pups, describe how calves/pups would be
held, what procedures would be conducted on the moms and the
calves/pups, duration separated, and how they would be reunited
Manner of release
Duration of restraint/holding from capture to release
If recapturing animals, indicate under what circumstances they will be
immediately released without processing or fully or partially processed
(i.e., what will be done to them on recapture).

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Take action/
procedures
Export/ import/
receive samples

Method Description Guidance
Type of activities:
● Export samples collected under the requested permit or received from
other legal sources
● Re-import exported samples
● Import samples from foreign countries
● Receive samples from other U.S. legal sources
Sample type (e.g., skin/blubber, blood, muscle, DNA)
U.S. or foreign sources of samples:
● Authorized persons or collections, including your own research;
● Animals in captivity (samples from routine husbandry procedures or
under separate authorization);
● Animals in foreign countries stranded alive or dead or that died during
rehabilitation;
● Animals killed during legal subsistence harvests; or
● Animals killed incidental to legal commercial fishing operations
How the sample or animal was originally taken
The legal authority for the original take for imported/received samples
Sample preservation, storage/shipping/analysis
What country are samples being exported to?
Where are samples being imported or received from: high seas, name and
affiliation, or country
Designated port of entry/import or export
See also Disposition of Tissue Samples below

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Take action/
procedures
External
instruments
(e.g., external
instruments
attached with
epoxy, suctioncup, dart, or
deep-implants; a
table is helpful
for multiple tag
types)

Internal
instruments
(e.g., stomach
temperature pills,
life history tags,
internal deepimplant tags)

Method Description Guidance
Type of instrument
Type of data collection (e.g., archival requiring retrieval)
Dimensions of instrument and attachment
Mass in air or water
Percentage of body mass for all tags combined
Maximum footprint/maximum number of tags per animal
Criteria for determining tag types and number of tags on an animal (e.g.,
body condition, life stage)
Whether tags will be coated with antifouling paint
Attachment method (e.g., remote deployment of suction cup or dart barb
fired from crossbow; restraint and epoxy or harness)
For remote deployment:
● minimum approach distance and angle
● number of attempts per animal per day (i.e., success rate)
● include total number of attempts needed for all work if requesting
multiple procedures (e.g., tag and biopsy) on same animal during same
day
Location on body
For cetacean deep-implant tags with external instrumentation, please
include the tag penetration depth and describe if the tag is intended to
penetrate the blubber/muscle interface
Duration of procedure
Duration of instrument retention
Release mechanism or recapture to remove
Post-tag monitoring
Type of instrument
Instrument dimensions
Mass in air
Percentage of body mass for all tags combined
Criteria for determining tag types and number of tags on an animal (e.g.,
body condition, life stage)
Use of local anesthetic or anesthesia/sedation (see Administer drugs)
Insertion method (describe e.g., surgical implant, injection, stomach tube,
remote deployment)
Location within body
For cetacean deep-implant tags include the tag penetration depth and
describe if the tag is intended to penetrate the blubber/muscle interface
For remote deployment: minimum approach distance and angle
Duration of procedure
Duration of instrument retention
How instruments are voided
Type of data collection (e.g., archival requiring retrieval)
Post-tag monitoring

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Take action/
procedures
Invasive
sampling (e.g.,
blood, blubber,
muscle, skin);
remote or under
restraint

Marking (e.g.,
bleach, flipper
tag, freeze brand,
hot brand, paint,
PIT tag)
Non-invasive
sampling (e.g.,
breath sampling,
collecting
sloughed tissue,
focal follows,
passive acoustics,
photographic
methods)
Remotely
operated
vehicle (ROV),
(vessel or
amphibious)

Method Description Guidance
Type of tissues
Equipment (e.g., dart and stopper depth, needle, punch, scalpel)
Size or volume of sample (diameter and depth or total volume)
Equipment sterilization or disinfection
Location on body
If restrained: cleansing site; left open or wound closure
If remote:
● collection method (e.g., dart fired from rifle)
● minimum approach distance
● number of attempts per animal per day (i.e., success rate)
Number of samples per animal per capture event and per year
Sampling intervals (e.g., for serial blood or biopsy samples)
Sample preservation and storage
Type of mark
Dimensions of tag or mark
Total number of tags, marks, or brands per animal
Location on body
Method of application
Disinfection procedures
Duration of mark (e.g., until molt)
Whether marks would be reapplied, if lost
Approach method
Sampling method
Minimum approach distance
For pinnipeds: within sight of animals or not (e.g., from a blind)?
For 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,
including safety divers
Frequency of observations/sampling per day
Number of approaches per animal per day for biological sampling
Duration of observations/sampling per day
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
Deployment method, in relation to capture and release of animal, if
applicable
Describe any light sources
Whether there will be a live video feed monitored
Encounter duration

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Non-target Marine Mammals
Discuss whether and how non-target marine mammals may be unintentionally harassed,
captured, or otherwise affected. These are species that co-occur with your target species
and that could be harassed or taken during your research but that you will not
opportunistically incorporate into your study.

Include these non-target marine mammals on separate rows in the Take Table if you expect
take (e.g., unintentional harassment or capture). For ESA species designated by DPS,
specify the DPSs.
Other non-target taxa (e.g., sea turtles, seabirds, corals,) should be addressed in the Effects
and Mitigation section below.

Project Supplemental Information

Attach a Supplemental Information File
You can attach up to 10 files to provide additional information.
● Preferred file formats: Microsoft Word, Excel, or PDF.
● 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.

Status of the Affected Species (up to 2,000 characters)
If choosing “range-wide” in the Stock/Listing Unit column in your take table, indicate the
specific stocks or DPSs you are targeting, their status under the MMPA and/or ESA, and
location. Otherwise, put N/A and choose the specific stock or DPS in the take table.

*Mortalities (up to 5,000 characters)
If authorization for serious injury 4 or mortality 5 (euthanasia/intentional 6 or
accidental/unintentional) is proposed:
4 A serious injury is an injury that will more likely than not result in mortality.

5 Caused by the presence or actions of researchers including but not limited to deaths or serious injuries

sustained during capture and handling, while attempting to avoid researchers or escape capture, or resulting
from infections related to intrusive procedures such as sampling or tagging. This does not include a fetus if a
pregnant female dies.
6 This includes euthanasia for humane reasons (e.g., due to serious injury during research).
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What activities could result in serious injury or mortality and how?

What is the maximum number of animals of each species/DPS that could be
seriously injured, unintentionally die, or be euthanized annually and over the life of
the permit? For example, two serious injury/mortalities per year, not to exceed four
over the life of the permit.
Justify the number of mortalities requested.

Briefly summarize serious injuries/mortalities that have occurred during the
previous five years of your permitted activities using the same or similar
techniques; include circumstances and cause of death, and how a similar outcome
can be prevented.
Explain why it’s not feasible to use other methods that won’t result in serious
injury or mortality.

If authorization for serious injuries or mortalities of ESA-listed or MMPA-depleted
species is proposed, explain how the project will directly benefit the species or
stock or fulfill a critically important research need.
Under what circumstances is euthanasia conducted? How is it decided, conducted
(including use of drugs or firearms), and who conducts it?
What are the protocols for necropsy and carcass disposal? If necropsy cannot
occur, explain why.

What are the protocols for disposition of dependent pups or calves if lactating
females may die as a result of your actions?

*Effects and Mitigation (up to 64,000 characters)

Discuss how Take Table actions (Take Actions, Observe/Collect Methods, and
Procedures) will affect target and non-target animals. You should discuss serious injury
and mortality in the Mortalities section above.

Cite the best available science (i.e., peer-reviewed literature or other published data
sources) and your experience (e.g., personal communication, annual permit reports).
References must be made available upon request.
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Group together take actions with similar responses and describe, as applicable:
●
●
●
●
●
●
●
●
●
●
●
●
●

●

Typical behavioral and physiological responses
Worst-case responses

% of animals that typically exhibit each response type
Average/estimated recovery time

Wound healing time (e.g., from invasive sampling or tagging)
Condition of animals on recapture/resight
Recovery from sedation and/or handling

Post-release behavior (immediate and long-term)

Time it takes to resume normal behavior after harassment

Time it takes to repopulate rookeries/haul outs after flushing
Tag retention and tag breakage

Effects on lactating females and their dependent young or other sensitive life stages

For novel procedures, discuss the most likely anticipated responses based on
literature from studies on other species, if available, and any results from testing, if
applicable.
Discuss the anticipated effects on the species or stock, especially if mortalities or
reproductive effects are possible. On what is your determination based?

You may include mitigation and monitoring protocols here or in the Methods section
above. Do not restate them here if they are included above; simply reference the section
where the following information appears.
●

For intrusive procedures, including biological sampling and instrumentation, describe
your steps to prevent infection. For example, describe if and how you will:
o Prepare the sampling site by cleaning and disinfecting the fur or skin (for
captured animals).

o Use single-use, sterile instruments (e.g., needles).

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o Sterilize 7 other devices prior to use and in the field if contaminated including but
not limited to use of cold sterilization.
o Use prophylactic antibiotics to coat instruments.

•

•

●
●

●

●

o Administer prophylactic antibiotics to animals (include the drug, dosage, and
route of administration).

Describe what mitigation measures you will employ to minimize adverse
reactions. If you will use the same mitigation measures for a suite of activities, such
as those resulting in Level B harassment, you may provide one discussion for each
suite of activities (e.g., close approach by vessel for photo-identification, acoustic
recordings, collection of voided feces, and behavioral observations).
If working with dependent calves/pups, their moms, or known pregnant females,
give specific protocols for working around them. For example, how will you avoid
separating mothers from calves/pups?

Describe your short- and long-term post-procedure monitoring protocols.

Explain if and why monitoring or mitigation is not feasible for specific procedures,
species, situations, etc.

Humane 8 determination: Explain how you determined your methods involve the
least possible degree of pain and suffering possible and why there are no feasible
alternative methods.
When an IACUC (Institutional Animal Care and Use Committee) review is
required for your research facility 9, to support a humane determination under the
MMPA and compliance with the Animal Welfare Act, attach:
o

The IACUC protocols submitted

Sterilization destroys or eliminates all forms of microbial life and is carried out by physical or chemical
methods (CDC 2008). Disinfection eliminates many or all pathogenic microorganisms, except bacterial
spores, on inanimate objects usually by liquid chemicals (CDC 2008).
7

8

Humane means using the method that involves the least possible degree of pain and suffering possible.

9

Research facility is defined as an organization that uses live animals in research and receives Federal funding. Any
marine mammal research facility that uses invasive procedures which can harm or materially alter the behavior of
the animals under study requires an IACUC review and approval. If an applicant does not have an IACUC,
an alternate IACUC (e.g., of a Co-Investigator or a local university/research institution) may be used.
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o
o

•

Any IACUC comments or recommendations

The signed IACUC approval (or status of your application)

Describe any mitigation you will take to avoid or minimize impacts to non-target
protected species (e.g., sea turtles, corals, U.S. Fish and Wildlife Service species).
Discuss whether and how they may be unintentionally harassed, captured, or
otherwise affected. For ESA species designated by DPS, specify the DPSs. Identify if
you require takes of these species.

Research Coordination
● Describe how you will coordinate with other permit holders in your action area.
o List their names and affiliations.

●

o Explain how you will work together. For example, will you share vessels or
coordinate the timing of surveys to avoid repeated takes of the same
animals? ? If you will be collaborating with another researcher and using
two aircraft, vessels, or different platforms at the same time, be sure to
describe that in your methods.

Will you collaborate with other permitted researchers to share data? If so, list their
names and affiliations and explain your collaboration plans.

Attach a References File
Attach a bibliography of references cited in this application. Referenced materials must be
made available upon request, as needed for evaluation of the application and preparation
of MMPA, ESA, or NEPA analyses. If a link to your referenced material is available, add the
link to your References File.
*Resources Needed to Accomplish Objectives (up to 4,000 characters and attach files if
necessary)
●

Explain how your expertise, facilities, and resources 10 are adequate to accomplish
your proposed objectives and activities.

Expertise includes a summary of the cumulative experience of you and your personnel. Facilities include
such things as your existing infrastructure or laboratories. Resources include financial (e.g., current funding
and/or history of securing funding); material (e.g., sampling equipment, UAS, boats); and other resources
(e.g., collaborative partnerships that can be drawn on to support your work).

10

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●

●

List relevant proposals, contracts, grant awards, or letters of agreement that would
demonstrate your resources. If funding is not yet secured, provide a history of
funding over the past 5 years. Copies must be made available upon request.
Indicate the status of other international, federal, state, or local authorizations and
permits you have applied for, secured, or will apply for.

*Disposition of Tissue Samples (up to 4,000 characters)

Outline what will be done with the biological samples during your research or
enhancement and after your project is complete, as follows:

1. If you are performing your analyses in-house, state whether the samples will be
consumed, destroyed, or curated.
2. If you are sending samples to another entity:
●

●

List the name, affiliation, and location of any person or institution that will
receive, analyze, or curate samples. 11

Include the sample type and purpose of transfer (type of analysis and/or
curation). State whether samples will be consumed in analysis, destroyed,
curated, or returned.

3. If samples will remain after the completion of your research, indicate if you will
retain legal custody of the curated samples or if you will permanently transfer
custody of the samples.

*Public Availability of Product/Publications (up to 800 characters)
Describe the end products of your proposed project and how they will be made available to
the public.

Captive Information

If you will be working with animals in captivity (permanent or temporary), including
removing animals from the wild into captivity and research or enhancement on captive or
rehabilitating animals, address the following (explain if not applicable):

Persons or institutions authorized to receive samples for analysis or curation related to the objectives of
your permit are known as Authorized Recipients.

11

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1. If removing animals from the wild, explain why removal is necessary and why you
cannot obtain suitable animals from captive or rehabilitated stock.

2. If the animals are beached/stranded marine mammals undergoing rehabilitation,
indicate the name and location of the rehabilitation facility, whether the animals will
be transferred to your facility for research, and plans for release after research.

3. If the animals are already in captivity (other than animals in rehabilitation) indicate
the name and location of the facility, age and sex of the animals, and identifiers of
the specific animals (by NOAA ID number if applicable).
4. Attach a copy of any license or registration issued by the Animal and Plant Health
Inspection Service (APHIS) of the U.S. Department of Agriculture, any outstanding
variances granted, and the most recent APHIS inspection report.

5. Attach the protocol forms submitted to the appropriate Institutional Animal Care
and Use Committee (IACUC) established under the Animal Welfare Act (AWA), any
IACUC comments and recommendations, and the signed IACUC approval (or status
of your application).
6. Attach a written statement from the responsible veterinarian or expert certifying
that the facilities, methods of care and maintenance, and methods of transport will
be adequate to ensure the well-being of the animals and will comply with all care
and transport standards established under the AWA.

7. Describe the care and maintenance of the animals, including a complete description
of the facilities where they will be maintained. This includes:
● Dimensions of the pools or other holding facilities
● Water supply, amount, and quality
● Sanitation practices
● Number, sex, and age of animals by species to be held in each
● Quarantine procedures
● Acclimation plan for introducing new and currently held animals and
contingency plans if adverse responses are observed
● Diet, amount and type.
8. Will a captive breeding program be established? This includes allowing animals to
naturally breed, without assisted reproduction or other manipulation.
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If you do not intend to breed, describe how you will effectively prevent breeding
(e.g., by physical separation or other means).

If you do intend to breed, describe the objectives and purpose of breeding in the
Project Purpose section. For MMPA-depleted and/or ESA-listed species, include
justification in accordance with goals or objectives as identified in the species
status review, final rule, conservation plan, and/or recovery plan, as applicable. In
the Project Description section (Methods), describe how breeding will be managed
and monitored. In the Effects and Mitigation section, describe what mitigation will
be in place to ensure animals will not be harmed during mating, etc. What special
care will be provided for females during pregnancy and parturition? How will
neonates be cared for? Include any contingency plans.

9. Indicate the disposition of captive animals at the end of your research or
enhancement activities.

10. If you’re proposing to release of captive animals into the wild, state how long the
animals will be held, no matter how temporary. Describe the protocols for the
release, which must address:
●
●
●
●
●

Post-release monitoring protocols
Disease transmission between released animals and the wild population
Potential genetic exchanges between introduced and endemic stocks
Ability of the released animals to forage and protect themselves from predators
Elimination of behavioral patterns acquired during captivity that could prove
detrimental to the released animals or the social structure of local populations.

Importing Marine Mammals into the United States (If Applicable)
For importing marine mammals into the United States, include the following
information:
1. Identify the animal(s) to be imported including:
• Animal identification
• Estimated or known age
• Size (length and/or weight)
• Sex
• Reproductive condition (pregnant or lactating)

2. Locations:
• Country of origin

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•
•
•
•

Exporting facility
Ports of entry (https://www.fws.gov/le/designated-ports.html)
Whether you will be requesting a port of entry exemption
Final destination/facility.

3. The animal’s previous transport history (e.g., attach a NOAA Marine Mammal Data
Sheet, Species 360 specimen report, or statement from the shipping facility)
including dates.

4. For wild-caught animals:
• Describe how the animal was captured and maintained in the country of
origin, including how the captures and captive holding were conducted in a
humane manner.
• Indicate the wild stock and the geographic location the animal was collected
from. Include latitude/longitude coordinates and/or waterbody location.
• Provide documentation that the take was legal in accordance with the
capture country’s laws.
5. For captive-born animals:
• Provide documentation of the animal’s birth.
• Identify the parents of the animal and, to the extent practicable, provide
documentation of their origin (e.g., lineage), including the wild stock and
geographic location the animals were collected from.
• Use NOAA ID numbers, if applicable.

6. Attach a statement from the exporting facility and, to the extent practicable,
documentation concerning whether the marine mammal to be imported is presently
being held in compliance with the laws of the country of exportation.

7. Attach a statement from the exporting facility explaining if the requested import will
likely result in the taking of marine mammals beyond those proposed.
•
•
•

Will marine mammals be acquired to replace the marine mammals to be
imported?
Will the proposed import result in an increased demand for marine
mammals?
Provide justification for these statements.
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8. If the import is necessary for the protection or welfare of the marine mammals,
discuss the circumstances involved and any alternatives considered.

*Project Locations

First, follow the guidance below to describe where you
plan to work. Then, for each location, use the Take Table
to list the species you expect to encounter and the
procedures you will conduct in each location.
1.

2.

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 a high quality map(s) to scale that
clearly shows the location of your proposed activity and
any environmental areas 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 application.

*Take Table

The take table represents the estimated number of
animals you proposed to take, import, or export
annually during your research.

Columns you will fill out in the take table in APPS:

How to count takes
of pinnipeds

Count 1 take per pinniped per
day for those hauled-out
animals that react to the
research, regardless of the
number of approaches or
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 pinnipeds 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.

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1. Select: Leave this box blank unless you need to copy, move, or delete the row.
2. Species: Use the drop down list.

3. Listing Unit/Stock: Select the applicable MMPA
stock or ESA listing unit. Only choose Range-wide if
your location has multiple populations of the same
species and you cannot distinguish between them
while in the field.

4. Production/Origin: Select from the drop-down list.
Categories include Wild, Captive, Rehabilitation
Facility, or All.

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 on the same row.
6. Sex: Select from the drop-down list. If your suite of
activities targets only one sex, indicate which.
Otherwise, select Male and Female.

7. Expected Take: This represents a reasonable
estimate of the maximum number of individuals you
will take, import, or export, annually.

8. Take Action: The “take action” is a generalized
overview of how animals will be taken by your
activities over the course of the year (e.g.,
harass/sample). If more than one action is proposed
for your project, you must enter the takes on separate
rows.
9. Observe/Collect Method: Select the method of
observation (e.g., survey, vessel) or
collection/capture. Select only one observe/collect
method per row.

How to count
takes of
cetaceans

Count every cetacean
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
cetacean observed per day,
regardless of the number of
passes over the same
animal.

10. Procedures: You will open a separate pop-up
window with a species-specific list of activities. Check the boxes to select all activities
to be performed concurrently on the same animals.
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a. Choose “Other” if your proposed activity is not listed. In the Details box (see
below), briefly describe what the “Other” means. For example, Other = pole cam.
b. If some animals will only get a subset of procedures, list this subset on a
separate row.
c.

Use “unintentional harassment” for species
or animals that could be harassed or taken
during your research but that you will not
opportunistically incorporate into your study.

11. Transport: If you chose Transport as a Procedure,
enter information about the transport when
prompted.
a. Mode(s) of transportation: Describe the
vehicle or other platform used to transport
animals.

b. The name of the transportation company,
if applicable, and the qualifications of the
common carrier to transport live animals:
If a contractor or other entity will do the
transportation, enter information in the box.
Otherwise, click on N/A.
c. Maximum length of time from capture to
arrival at destination: How long will the
animals be in transport?
d. Description of the container (e.g., cage,
tank) used to hold the animal during
transit: Include the material and design of
the container and its dimensions.

e. Any special care procedures (e.g.,
moisture, medicines) to be administered
during transport: How will the animals be
cared for during transport?

Acoustic Playbacks
For acoustic playback trials in
the wild, estimate take for each
target and non-target species
based on the isopleth distances
that result from the following
thresholds:
•

•

Level B harassment
behavioral threshold of a
received level of 120db re
1µPa (continuous sounds)
and 160 dB re 1µPa
(intermittent sounds), and

Level A harassment
threshold for permanent
threshold shift (injury).
This varies by functional
hearing group. Refer to our
acoustic guidance at:
https://www.fisheries.noaa.
gov/national/marinemammalprotection/marinemammal-acoustic-technicalguidance

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f. A statement as to whether the animals will be accompanied by a
veterinarian or some similarly qualified person: If so, give the name,
affiliation, contact information for each person.

g. Destination: Use the drop down list to select the destination. If your
destination is not on the list, click on the “New Facility” button to add it. If the
animals will be taken to a laboratory or aquarium, provide details of the location.
If the animals will be released in another waterbody, provide details of the
location.
h. How will the animals be contained at the destination facility? Discuss the
quarantine procedures. Describe the quarantine and permanent holding spaces,
including effluent treatment.

i.

The final disposition of the animals: Describe, for example, whether the
animal will be released or retained in permanent captivity.

12. Begin Date: Auto-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: Auto-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 (Optional): Enter up to 255 characters to provide details on each take table
line. This is especially useful to clarify age class, takes (e.g., how many samples or
successful tags you hope to get), intentional repeated takes (e.g., recapture for
instrument removal), endangered DPSs where mixing occurs, 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
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•
•
•
•
•
•
•
•
•
•

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

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. (up to 1,200 characters)

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? (up to
1,200 characters)

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? (up to 800 characters)

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. (up to 2,000 characters)
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. Invasive Species
a. Does your project involve activities known or suspected of introducing or
spreading invasive species, intentionally or not? Examples include
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transporting animals or other biological specimens, discharging ballast water,
and using boats/equipment at multiple sites. Yes or no.

b. 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. (up to 1,200 characters)

4. Biological Specimens
a. Will your activities involve collecting, handling, or transporting potentially
infectious agents or pathogens, such as biological specimens (animals,
blood, tissues)? Yes or no.

b. Will your activities involve using or transporting hazardous substances, such
as toxic chemicals? Yes or no.

c. 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.
(up to 1,200 characters)

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? Yes or no.
If yes:

a. Briefly describe the equipment or techniques and provide any information about
the use of these in your study area and/or with other taxa and what is known
about their impacts. (up to 1,200 characters)
b. Discuss the degree to which they are likely to be adopted by others for similar
activities or applied more broadly. (up to 800 characters)

Project Contacts

The person entering the application in APPS will automatically be assigned the following
roles: Applicant/Permit Holder, Principal Investigator (PI), 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.
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3. To prevent duplicate entries, ALWAYS search APPS for the person before
entering a new contact. Start with the last name in the APPS search box.

4. Include a table with the names of the PI and Co-Investigators (CIs), and the specific
procedures they will oversee or conduct (see example Table 3). 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.

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,
import, export, 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 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 permit, requests amendments/modifications (e.g., personnel changes), 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.

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Co-Investigators (CIs) are individuals who are qualified and authorized to conduct or
directly supervise activities conducted under a permit without the on-site supervision of
the PI.
●

●

You must 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.

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.

Unmanned Aircraft Systems (UAS) Pilots are persons who have their FAA-certification to
fly unmanned aircraft systems and experience piloting UAS. A CI or the PI with marine
mammal experience may be qualified to serve in this role. In other cases, you may
designate someone as a UAS Pilot who is tasked with only that role and does not have
marine mammal experience.
Personnel for Unmanned Aircraft Systems (UAS)

To fly UAS, you must have: 1) someone with experience working with the target species in
the wild, and 2) someone who is FAA-certified to conduct or oversee UAS flights with
approximately 5 hours of flight experience. These may be satisfied by one or more persons,
depending on the qualifications of your team. The following scenarios describe the
personnel roles for UAS that you may request based on their qualifications.
Table 2. UAS Personnel
Scenario 1: Species expert who is also an FAA-certified UAS pilot
If the person has:
They may be named as:
PI or CI to supervise and operate UAS.
Experience working with the subject
No separate UAS Pilot required to be named
species/taxa in the wild and UAS
experience with an FAA UAS certification on the application.
Scenario 2: Species expert (PI or CI) accompanied by an FAA-certified UAS pilot
If the person has:
They may be named as:
Experience working with the subject
PI or CI to supervise UAS. A separate UAS
species/taxa in the wild, but no UAS
Pilot must be named for the UAS operation.
experience
UAS pilot to operate the UAS or directly
UAS experience and FAA UAS certification
oversee operation as the remote pilot in
but no marine mammal experience
command. The UAS pilot must be
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supervised by the PI or a CI with marine
mammal experience.

Note: Other personnel who are not FAA-certified may manually operate the UAS (e.g., for
training purposes) provided the FAA certified pilot designated on the permit directly oversees
the UAS operation.

Qualifications and Experience
The PI and each CI must complete 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 to demonstrate they were qualified in the proposed take
activities. You can download a blank QF from the Contacts page in APPS or from any of our
permitting web pages.
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; it will apply to all permits they are affiliated with. They may replace the QF with
an updated version as they gain new experience.

Persons authorized as the PI or CIs must have qualifications corresponding to their
duties. Note, if the PI or a CI will be supervising but not performing specific procedures,
they must demonstrate sufficient cumulative experience to oversee the project, personnel
(e.g., other CIs, research assistants, veterinarians), and procedures.
If you do not provide sufficient information, we will not authorize the person(s).

In addition, you must submit a table (see Table 3) defining the PI and CI roles and
activities (i.e., supervising or conducting specific procedures). Attach this table as
Supplemental Information.
Table 3. Example Personnel Roles
Name/Affiliation
Role
John Smith, Ph.D.,
Principal Investigator
University A, City,
State
Jane Smith,
Co-Investigator
Institution B, City,
State
Mary Smith,
Co-Investigator and
D.V.M., Institution Attending Veterinarian
B, City, State

Activities
Supervise all activities under the
permit; conduct all activities
except anesthesia
Conduct all activities excluding
UAS and anesthesia
Oversee and conduct anesthesia
and all biological sampling
during capture activities

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Name/Affiliation
Jane Doe, Ph.D.,
Institution C, City,
State
John Doe, Ph.D.,
University D, City,
State
Bob Smith, City,
State

Role
Co-Investigator

Activities
Conduct photo-ID and supervise
UAS pilot

CI

Collect remote skin/blubber
biopsy samples and create cell
lines
UAS pilot supervised by the PI
or a CI

UAS pilot

Submit Application

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

Additional Information
When should I apply?

MMPA permits (no ESA-listed species): at least 6 months before your project will
begin.
● ESA-MMPA permits: it depends on the species and activities
● ESA-listed Pinnipeds – at least 1 year before your project will begin.
● ESA-listed Cetaceans – your project may fall under our programmatic
consultation, which means you should submit your application 6 months
prior to starting work, following our application cycle. If your proposed
research is not covered under a programmatic, then you need to apply at
least 1 year before your project will begin.
● Note: If you are requesting deep-implant tags for ESA-listed cetacean species, you
must apply on the cycle indicated on our programmatic permitting webpage if you
wish to be covered by the programmatic consultation.
●

What is the process for getting a permit?

1. Follow these instructions and contact the Permits and Conservation Division at
[email protected] or 301-427-8401 with any questions.
2. Submit your application via APPS.
a. A permit analyst will review your application and contact you if additional
information is needed.
3. Address any questions within 60 days or your application will be withdrawn.
a. Once we consider your application complete, we will publish a notice in the
Federal Register, which starts a mandatory 30-day public comment period.
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b. Concurrently, we will send your application to the Marine Mammal Commission
and other subject matter experts in partner institutions and federal and state
agencies for review.
c. We will determine whether or not your proposed research requires an ESA
Section 7 consultation. Your research may fall under a programmatic
consultation. If it does not follow under the programmatic, we will need to
request consultation to assess impacts to ESA-listed species. The ESA
consultation can take up to 6 months.
4. Address any questions received during the comment period.
a. We will draft the permit and supporting documentation (including National
Environmental Policy Act analyses, responses to public comments, and
documentation of MMPA and ESA issuance criteria).
b. The documents will be reviewed by various NMFS offices including a legal
review.
c. For individual consultations, a Biological Opinion will be issued if ESA-listed
species may be taken and adversely affected to determine if the activity will
jeopardize the species or adversely modify critical habitat.
d. The Office Director will decide whether to issue or deny your permit.

What is the process for requesting an amendment to a permit?

Use APPS to request an amendment to your permit. 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.

Applicable Laws and Regulations

Under Section 104(c) of the MMPA and Section 10(a)(1)(A) of the ESA, persons may be
authorized to take marine mammals and threatened and endangered species, respectively,
for purposes of scientific research or enhancing the survival of the species. Interested
persons are required to submit an application in accordance with the Acts and the
implementing regulations at 50 CFR Part 216, subpart D, and 50 CFR Part 222. These
instructions for applying for a research or enhancement permit are drawn from, but do not
substitute for ESA regulations and MMPA regulations. Read the full text of the MMPA,
including Section 104. Read the full text of the ESA, including Section 10(a)(1)(A). Under
NEPA, Federal agencies must assess the effects of federal actions on the environment.
Under Section 7 of the ESA, Federal agencies must ensure that the permitted activities will
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not jeopardize the continued existence of the species or result in adverse modification of
critical habitat.

The permit application and any associated documents, including any reports required, are
considered public information and as such, are subject to the Freedom of Information Act.

Paperwork Reduction Act Statement

A Federal agency may not conduct or sponsor, and a person is not required to respond to,
nor shall a person be subject to a penalty for failure to comply with an information
collection subject to the requirements of the Paperwork Reduction Act of 1995 unless the
information collection has a currently valid OMB Control Number. The approved OMB
Control Number for this information collection is 0648-0084. Without this approval, we
could not conduct this information collection. Public reporting for this information
collection is estimated to be approximately 50 hours per response, including the time for
reviewing instructions, searching existing data sources, gathering and maintaining the data
needed, and completing and reviewing the information collection. All responses to this
information collection are required to obtain a permit pursuant to the ESA, NEPA, and their
implementing regulations. Send comments regarding this burden estimate or any other
aspect of this information collection, 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; email [email protected].

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