453 



At that time, appropriate balancing decisions can be made 

 regarding the wisdom of proceeding with development. 



The First Circuit described Lease Sale 42 as an "uneasy 

 calculus" between oil estimates and fishery resources. 

 Today, as oil and gas potential have plummeted, the value 

 and reliability of the fishery have, if anything, grown. 

 A balance which three years ago was an "uneasy calculus" is 

 no longer even a close call. Yet Interior's dangerous con- 

 cept of inventory leasing ignores the crucial "balancing" 

 test of the OCSLA. As a result, an area which should presently 

 not be leased is once again (pending litigation) up for sale. 



II. THE BIOLOGICAL TASK FORCE (BTF) 



CLE believes there are three important issues regarding 

 the Georges Bank BTF Monitoring Program that should be 

 considered: (1) the Department of the Interior's use of the 

 Monitoring Program to date; (2) the future directions and 

 goals of the BTF; and (3) the broad implications of the Monitor- 

 ing program for the future of the Georges Bank fishery. 

 A. Interior's Use of the Monitoring Program 

 The Department of the Interior exhibits an astonishing 

 ambivalence regarding the Georges Bank monitoring program. 

 On the one hand, the monitoring program is widely touted as an 

 example of its environmental sensitivity; simultaneously. 

 Interior completely ignores the results and timetable of 

 this major scientific effort when making major policy and 

 leasing decisions. 



