452 



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estimation job incompetently or the careful balancing Congress 

 mandated is a hopeless gesture. In either event, the remedy 

 is not to lease every square foot of seabed. Instead, Congress 

 should require that resource estimates be prepared more ac- 

 curately . 



I should add at this point that the "hypothetical" nature 

 of resource estimates also calls into question Interior's 

 ability to obtain fair market value for its leases. Lacking 

 accurate estimates, how can the Secretary ever determine a 

 reasonable price for lease sales? Again, Congress's clear 

 requirements in the OCSLA would have been thwarted by Interior's 

 cavalier view of its resource estimation obligations. 



If Interior continues to pursue its new concept of in- 

 ventory leasing, CLF believes that swift, decisive Congressional 

 action will be necessary. Otherwise, every lease sale will be 

 followed by Interior's declaration that another sale is 

 necessary to more accurately determine the nature of the 

 resource. There is no logical end to the cycle, unless Congress 

 requires either: (1) a more serious Interior effort to pre- 

 pare resource estimates, or (2) separate exploration leasing, 

 so that the right to develop any resources discovered is not 

 converged along with exploration rights. In other words, if 

 we are to have "inventory" leasing. Congress should create a 

 true inventory program. Exploration rights should be all that 

 are sold until the full extent of the oil resource is known. 



