GA-LOI-Application

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 OR NEED HELP?.......................................................................... 2
WHEN FILLING OUT YOUR LETTER OF INTENT ...................................................................................... 2

LETTER OF INTENT ........................................................................................... 3
PROJECT INFORMATION ............................................................................................................................ 3

*PROJECT PURPOSE: HYPOTHESIS/OBJECTIVES AND JUSTIFICATION ............................................... 4
*PROJECT DESCRIPTION ............................................................................................................................ 6

PROJECT SUPPLEMENTAL INFORMATION ............................................................................................. 11

*PROJECT LOCATION ............................................................................................................................... 11
*TAKE TABLE ........................................................................................................................................... 12
*ANTICIPATED EFFECTS ON THE ENVIRONMENT ................................................................................ 14
*PROJECT CONTACTS ............................................................................................................................... 16

SUBMIT APPLICATION ............................................................................................................................. 19

ADDITIONAL INFORMATION ....................................................................... 19

WHAT TYPES OF RESEARCH USUALLY QUALIFY AS LEVEL B HARASSMENT? ................................... 19
WHAT ARE A LETTER OF INTENT AND A LETTER OF CONFIRMATION? ............................................ 19
WHAT ARE THE ADVANTAGES OF APPLYING UNDER THE GA? .......................................................... 20
WHEN SHOULD I APPLY? ......................................................................................................................... 20

WHAT IS THE PROCESS FOR GETTING AN LOC? ................................................................................... 20
WHAT IS THE PROCESS FOR REQUESTING AN AMENDMENT TO AN LOC? ........................................ 20

WHAT IF I WANT TO CONDUCT RESEARCH ON ENDANGERED OR THREATENED SPECIES OR CONDUCT
RESEARCH THAT EXCEEDS LEVEL B HARASSMENT? ............................................................................ 20

APPLICABLE LAWS AND REGULATIONS .................................................. 20
PAPERWORK REDUCTION ACT STATEMENT ......................................... 21
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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 on
non-listed marine mammals for activities involving only Level B harassment.
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.

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 or need help?

We recommend you visit our General Authorization web page, see the Additional
Information on page 20, or contact us at nmfs.pr1.apps@noaa.gov.

When filling out your Letter of Intent
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Your LOI must be a stand-alone document, readable to a layperson.
If you do not follow these instructions, your LOI will be returned.
We will not consider your LOI if you have overdue reports.

You will need to enter this information in our online permit system, APPS
https://apps.nmfs.noaa.gov/.

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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:
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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.
Previous Federal or State Permit #: If applicable,
enter your most recent and closely related NMFS LOC
or permit number. Otherwise, leave blank.
*Permits Requested: MMPA General Authorization
should be listed based on your answers in the APPS
PAG.

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

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

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An * indicates a required field.

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Consider using these
instructions as a template to
draft your LOI in Word. Then
cut and paste into APPS.

Special characters may be lost
or migrated incorrectly.
Refer to Chapter 2 for how to
navigate APPS.
Your LOI will remain in draft
mode until you submit.

Attachments cannot be larger
than 20MB – contact us if you
need to attach larger files.

*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 LOC is 5
years. See Additional Information on page 20 for details on when to apply.

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*Sampling Season/Project Duration (up to 1,000 characters)
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Describe your annual field season(s) including the months of the year and
frequency of fieldwork (e.g., when and how many times per year will you
conduct the research activities?).

If you conduct research year-round, indicate when activities are most likely to
occur and how frequently.

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

We recommend you provide the information in this order:
1. Discuss the need for the research and the
research questions you want to answer.

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:
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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.
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If you previously held or worked under an LOC or research permit, use
literature citations from that work to discuss how you previously met
your objectives; and
Use other published literature on the subject.
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3. Describe how this study is different from, builds upon, and/or duplicates past
research.
4. Identify your objectives or hypotheses based on the above information.

5. Take Number Rationale: Explain how you estimated your annual take
numbers (see guidance on pages 10-11 for how to count take). Under the GA,
you will not be limited to this number or penalized if you exceed it.
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For example, did you base take 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.
Discuss whether the same individual animals may be taken more than
once a year.
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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).

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.

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*Project Description (up to 64,000 characters)

Overview
Provide a brief overview of a typical day in the field and the suite of activities you
intend to perform during a marine mammal encounter. 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 (i.e., procedures; see Table 1 below).
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Your narrative description must match your APPS take table (see Take Table
section below). It is helpful to reference take table lines in the narrative that
correspond to the take actions and procedures.

Table 1. APPS Take Table Method/Procedure options for an LOC. Options vary
depending on if you are studying pinnipeds or cetaceans.
Acoustic, passive recording Observation, monitoring
Remote vehicle, vessel
Collect, molt
Observations, behavioral Remote video monitoring
Collect, scat
Other
Sample, exhaled air
Collect, sloughed skin
Photo-id
Sample, fecal
Collect, spew
Photogrammetry
Underwater photo/
videography
Collect, urine
Photograph/video
Unintentional harassment
Count/survey
Remote vehicle, aerial
(fixed wing)
Imaging, thermal
Remote vehicle, aerial
(VTOL)
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Be sure to provide clear descriptions of all methods (i.e., each procedure in
your APPS take table). See guidance below for what details to include.
A brief statement of each method/procedure’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.
For each method, state if you will target:
o Calves/pups (specify age/dependency);
o Females accompanying calves/pups (specify age);
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Pregnant females, and if so, include estimated trimester; and/or
Compromised animals.

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.

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.

Guidance on Describing Commonly Used Methods
Aerial, ground, and vessel surveys
• Number of surveys per year
• Type of aircraft and vessel
• Number of platforms (aircraft and vessel) to be operated at the same time
• Type of survey (e.g., line transect, photogrammetry)
• Minimum altitude or approach distance to animals
• Air speed
• Vessel speed
• Protocols for breaking track to ID species
• Protocols for approaching on land, whether a blind or cover will be used
• Duration spent with group or individual per 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)
• Number of platforms (UAS) to be operated at the same time
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Payload components – what is the UAS carrying and for what purpose (e.g.,
camera, sensor)?
Ground control station (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)
Encounter duration – maximum amount of time over same animals
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
• Deployment method
• Describe any light sources
• Whether there will be a live video feed monitored
• Encounter duration

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 per day
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)
• Sampling method
• Minimum approach distances
• Filming/photography equipment and methods
• For pinnipeds: Within sight of animals or not (e.g., from a blind)?
• Number of observations/sampling events per year
• Frequency of observations/sampling events per year (e.g., monthly)
• Samples to be collected and method (e.g., scat by hand)
• Number of approaches per animal per day for biological sampling
• Duration of observations/sampling per day
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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.
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Discuss how take table actions (Observe/Collect Methods and Procedures) will
affect target and non-target animals.

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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:
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Typical behavioral responses
Worst-case responses
% of animals that typically exhibit each response type
Condition of animals on resight
Time it takes to resume normal behavior after disturbance
Time it takes to repopulate rookeries/haul outs after flushing
Effects on lactating females and their dependent young or other sensitive life
stages

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Explain how your research will not result in injury, mortality, or
reproductive effects.

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Describe what mitigation measures you will employ to minimize adverse
reactions. If you will use the same mitigation measures for a suite of activities,
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).

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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 monitoring protocols after your activities.
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Explain if and why monitoring or mitigation is not feasible for specific
species, situations, etc.

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 unintentionally harassed or otherwise affected.

Non-target Marine Mammals

Discuss whether and how non-target marine mammals may be unintentionally
harassed in your study area. 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.
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The GA cannot authorize you to take threatened or endangered species. If ESAlisted 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 unintentional harassment in the
procedure column.

Other non-target taxa (e.g., sea turtles, corals, Johnson’s sea grass) should be addressed
in the Effects and Mitigation section)
Research Coordination
• Describe how you will coordinate with other LOC/Permit Holders in your study
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?
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Will you collaborate with other permitted researchers to share data, for
example, by contributing to a regional photo-ID catalog? If so, explain your
collaboration plans and list names and affiliations.
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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.
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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 and preparation of MMPA or NEPA
analyses. If a link to your referenced material is
available, add the link to your References File.

*Project Location

First, describe where you plan to work. Then,
for each location, 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.

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 responses, including:
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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:
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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.

2. Enter Location Details, as applicable:
• Waterbody: enter names of rivers, estuaries, bays, etc.
• Latitude and longitude of your study area
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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 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.

*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 in APPS:
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 nonESA listed species only. You cannot select endangered
or threatened species.

3. Listing Unit/Stock: Select the applicable stock. Only
choose Range-wide if your location has multiple stocks
of the same species and you cannot distinguish them
while in the field.
4. Production/Origin: Select “Wild.”

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 within 100 yards
for non-ESA-listed baleen
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.

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.
6. Sex: Select from the drop-down list. If your activity targets only one sex,
indicate which. Otherwise select Male and Female.
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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.
8. Take Action: Select Harass.

9. Observe/Collect Method: Select the method of observation (e.g., “survey,
vessel”). Select only one observe/collect method per row. If you will be
approaching animals from a boat to fly UAS surveys, select “survey,
aerial/vessel.”

10. Procedures: 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 on the same animals.
a. Choose “Other” if your proposed activity is not listed. In the Details box
(see below), briefly describe what the Other means.
b. Use “Unintentional Harassment” if you may unintentionally harass nontarget, non-ESA listed marine mammals during your research.

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: Enter up to 255 characters to provide details on each take table line.
This is especially useful to clarify age class, takes, specific activities, or projects.

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*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? Yes or no.

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

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)

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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. a. 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. 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. 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.
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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.
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You may need to change or add personnel. See Chapter 2 for directions on how
to change who is assigned to these roles.
Use the guidance below to help you decide who should have what role.

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.

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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 2). Attach
the table on the Supplemental Information page.

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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.
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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:
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Must have qualifications, knowledge, and experience relevant to the activities
authorized by the LOC.
Must be on site during activities conducted under the LOC 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 an LOC is issued. Typically this person
administers the LOC, 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.
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 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 an LOC 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 LOC.

Unmanned Aircraft Systems (UAS) Pilots are persons who have their FAAcertification to fly UAS 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.
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Personnel for 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 in Table
2 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:
Experience working with the subject
species/taxa in the wild and UAS
experience with an FAA UAS certification

PI or CI to supervise and operate UAS.
No separate UAS Pilot required to be named
in the LOI.

If the person has:

They may be named as:

Scenario 2: Species expert (PI or CI) accompanied by an FAA-certified UAS pilot

PI or CI to supervise UAS. A separate UAS
Pilot must be named for the UAS operation.

Experience working with the subject
species/taxa in the wild, but no UAS
experience

UAS pilot to operate the UAS or directly
oversee operation as the remote pilot in
UAS experience and FAA UAS certification
command. The UAS pilot must be
but no marine mammal experience
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 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 to demonstrate they were qualified in the proposed
take activities.
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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 one QF file in
their profile; it will apply to all LOCs or permits they are affiliated with. They may
replace the QF with an updated version when 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).

In addition, you must submit a table (see Table 3) defining the PI and CI roles and
activities to be performed.
Table 3. Example Personnel Roles
Name/Affiliation
Role

Activities

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

Principal
Investigator

Supervise and perform all activities
under the LOC, except UAS pilot

Bob Smith, City, State

UAS pilot

UAS pilot accompanied by the PI or a CI

Jane Doe, Institution,
City, State

CoInvestigator

Conduct photo-ID and behavioral
observations

Submit Application

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

Additional Information

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

Behavioral observations
Photo-identification/photogrammetry
Aerial surveys, manned or unmanned (except those over pinniped rookeries at
altitudes < 1,000 feet)
Vessel surveys
Other activities may also qualify – contact us 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.
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What are the advantages of applying under the GA?

The GA is an expedited process. It does not require a 30-day public comment period,
unlike other permits.

When should I apply?

At least 4 months before your project will begin, preferably 6 months 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 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. ‘
4. Once we consider your LOI complete, we will draft the LOC and supporting
documentation, including the National Environmental Policy Act analysis and
other information.
5. The Division Chief will sign the LOC if your proposed activities are for bona fide
research and Level B harassment only.
6. 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. Use
these application instructions as a guide. For example, changes to your objectives will
require you discuss all the points in the Project Purpose section. Additions to personnel
require Qualifications Forms and descriptions of their roles.

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.

Applicable Laws and Regulations

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,
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1994, and submit certain information outlined at 50 CFR 216.45(b) under the General
Authorization and provided in these instructions. Under NEPA, Federal agencies must
assess the effects of federal actions on the environment.
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.

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 10 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 an LOC
under the GA pursuant to the MMPA, 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
nmfs.pr1.apps@noaa.gov.

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