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argued that the estimates were reduced, and therefore so were 

 the risks. This is difficult to assess, for the actual risk 

 reduction was never discussed or quantified. 



Interior's second argument appears to have been adopted 

 only after the first began to falter. Now DOI appears to 

 maintain that the resource estimates are merely "hypothetical" , and 

 can never be confirmed or deemed reliable until there is ex- 

 tensive exploration. 



Interior thus appears to disavow its own resource estimates. 



This new tactic has alarming implications. Interior would have 



us believe that oil and gas estimates are never too low to 



ban drilling. In their view, OCS lease sales should always 



proceed, resulting in a process of "inventory" leasing. 



Clearly, this was was not the intention of Congress. The 



OCSLA never suggests or endorses inventory leasing. On the 



contrary, the Act requires that the timing and location of 



leasing shall be based, among other things, on: 



existing information concerning the geographical, 

 geological, and ecological characteristics of 

 such regions .... 



(and) a proper balance between the potential 

 for environmental damage, the potential for oil 

 and gas, and the potential for adverse impact 

 on the coastal zone. 



The Act gives the Secretary the authority to obtain proprietary 



information in order to make informed leasing decisions. If 



resource estimates are as meaningless as Interior would now 



have us believe, then either the agency is performing its 



