action, the Commission believes that there are a number of 

 unrecognized uncertainties concerning the likelihood and 

 extent of some potential effects. For example, the DEIS 

 provides information indicating that oil spills are not 

 likely to occur and contact large numbers of either 

 endangered or non-endangered marine mammals and in some cases 

 concludes or implies that the proposed action therefore would 

 have negligible or minor impacts. It does not always recog- 

 nize that the effects of an oil spill are independent of the 

 probability that a spill will occur and that it therefore is 

 inappropriate to conclude that the effects will be negligible 

 or minor because the probability of occurrence is negligible 

 or minor. 



The Commission also believes that some potential impacts 

 are difficult or impossible to identify or assess from avail- 

 able information. Therefore, it will recommend that the 

 Service modify the draft Statement to acknowledge the uncer- 

 tainties concerning the likely effects of the proposed action 

 and that the Final Environmental Impact Statement consider: 

 (a) the possible effects of garbage disposal from platforms 

 on polar bears; (b) the possibility that oil spills, distur- 

 bances, etc., will cause walrus, polar bears, ice seals, and 

 other species to move to adjacent and already occupied areas, 

 increasing animal densities in those areas to levels that 

 will damage or deplete food supplies; and (c) the possible 

 cumulative effects of subsistence harvesting and other 

 activities, as well as oil and gas exploration and develop- 

 ment, on bowhead and beluga whales, polar bears, walrus, and 

 seals. The Commission also will recommend that the Minerals 

 Management Service consider developing and implementing 

 monitoring programs aimed at detecting possible unforeseen 

 impacts before those impacts can reach unacceptable levels. 



Canadian Oil Exploration on Georges Bank 



Early in 1986, the United States learned of Canadian 

 industry proposals to carry out exploratory drilling for oil 

 and gas on the Canadian portion of Georges Bank. Such 

 activities could affect fishery and other resources on the 

 U.S. portion of Georges Bank and the United States made 

 inquiries to determine the nature of the proposals and steps 

 that had been or would be taken to ensure that the 

 activities, if permitted, would not have significant adverse 

 environmental impacts. To help address its concerns, the 

 United States was given an Environmental Evaluation of the 

 proposed action. 



The Commission staff reviewed the Environmental Evalu- 

 ation and, by letter of 15 August, provided comments to the 

 Department of State on those parts of the evaluation relating 

 to marine mammals. In its comments, the Commission noted 

 that the environmental evaluation identified the species of 



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