446 



happen to be high, are touted as quite promising, reason to pro- 

 ceed, reliable, whatever. 



It seems to me that we are facing a situation where the Depart- 

 ment has converted what Congress intended to be a very careful 

 balancing of resource potential versus environmental risk into an 

 inventory process — let's go out and lease as much area as possible, 

 let's discover whatever oil is out there, and then we will proceed 

 with production. 



Let me get to the question of production that was raised by the 

 chairman earlier. There is no separation at the moment between 

 exploration and development on Georges Bank or in any other 

 area. There is an environmental impact statement required at the 

 production phase. But what you need to remember is that the abili- 

 ty to terminate oil activity is very limited under the Outer Conti- 

 nental Shelf Lands Act. It is quite obvious once the areas are 

 leased that we will have production. 



There is another aspect to the environmental impact statement 

 at the production phase that makes it somewhat questionable as to 

 whether it is very useful. The Department needs only prepare one 

 EIS in production, and the timing of that production EIS is not 

 specified in the legislation. So you could have one exploratory well 

 come in and, before any further exploration information is availa- 

 ble, you could have an EIS prepared on the production phase. It 

 would say, yes, let's be forward. And that would be the end of it. 

 There would be no further environmental analysis required. 



I would go back to a suggestion that the chairman made earlier 

 and that I made in my written testimony. There should be a seri- 

 ous effort to separate exploration from development — whether that 

 means separate leasing, whether it even means you have to pay 

 the oil industry to do the exploration in a particularly vulnerable 

 area like Georges Bank, or whether it simply means that the deci- 

 sion point for production is a much more substantial decision than 

 it now is. I don't know the answer. But one of those alternatives 

 has to be selected. Otherwise, as the situation now stands, once the 

 areas are leased you will see us proceed right through production. 

 We are leasing them apparently based on what Interior now claims 

 is hypothetical resource information. 



I would also ask why is the resource information so bad. We have 

 an entire agency full of geologists that are supposed to be telling us 

 what is out there. We spend a good deal of money on geological re- 

 search. I question whether these resource estimates are as bad as 

 the Department would now have us believe. And it seems to me 

 that there is either a question of incompetency in the agency's own 

 ability to estimate, or a lack of will to do the job well, or in fact we 

 are facing a serious impossibility of estimating at all, in which case 

 the entire balancing process is worthless. 



Let me turn briefly to the biological task force and some of the 

 questions regarding its authority. 



It seems to me the task force has done a pretty good job develop- 

 ing a monitoring program for Georges Bank. One point about the 

 monitoring program that is important to keep in mind is that it 

 was not funded by the Department of Interior for at least 2 years 

 after the biological task force proposed it. And that delay resulted 

 in significant loss of available information. What happened before 



