450 



56 million barrels of oil — a 97% reduction. Gas estimates 

 have been comparably reduced. As the First Circuit Court 

 of Appeals noted in oral argument on June 6 of this year: 

 Interior once thought Georges Bank was Saudi Arabia; now it 

 thinks it may be Post Office Square. 



The law requires that Interior now reconsider the 

 wisdom of opening Georges Bank to oil and gas activity. 

 The Federal District Court has held that the Environmental 

 Impact Statement (EIS) for Lease Sale 52 must study anew 

 the benefits of a 56 million barrel oil project versus the 

 environmental costs to the Georges Bank fishery. And similarly, 

 under the Outer Continental Shelf Lands Act (OCSLA), the 

 Secretary of the Interior must re-balance the new potential 

 for oil and gas against the potential for environmental damage. 



The Secretary has fulfilled none of these mandates. The 



EIS is an outdated document, with only a one-page addendum on 



the drastically reduced oil resource figures. The District 



Court, in issuing its recent injunction against Lease Sale 



52, noted: 



the final EIS describes the facts and circumstances 

 of a lease sale that has become a fiction . . . 

 the 'broad, informal cost benefit analysis' re- 

 quired ... no longer has particular relevance 

 to Lease Sale 52. 



CLF V. Watt , Preliminary Injunction Hearing Transcript (Mazzone) 



March 28, 1983, pp. 17-18. 



Interior has two arguments in defense of holding Lease 



Sale 52 given the new resource estimates. Initially, it 



