454 



- 6 - 



During litigation over Lease Sale 42, Interior promised that 

 "the data collected through every phase of exploration and 

 operations on Georges Bank will provide a complete and tested 

 system for analyzing and preparing for future leasing operations 

 in virgin offshore territories." Yet Interior failed to fund 

 the Biological Task Force for two years after the sale. Only 

 when EPA ordered monitoring as a condition of NPDES permits was 

 the Monitoring Program begun. This delay lost two years of 

 important baseline data. 



Interior has since pursued its plan for a second lease sale 

 in the Georges Bank area. No attempt was made to await important 

 monitoring results from Sale 42. Perhaps conveniently, those 

 results were not available at the time of the Sale 52 decision, 

 and therefore were ignored by the Secretary. 



Attached to this testimony is a copy of the chronology 

 of Lease Sale 52, prepared in chart form by CLF staff. It 

 is clear from the chronology that every monitoring report from 

 Lease Sale 42, purportedly so important for future lease sale 

 decisions, was completed after the final EIS for Lease Sale 52. 

 No substantial monitoring data were incorporated into the lease 

 sale process. 



Interior's attitude has important and troubling implications. 

 OCS monitoring programs may h& regularly preferred as panaceas 

 for assorted environmental woes; a catch-all for all future 

 adverse impacts; or, more simply, a delay tactic. ( "Don ' t worry, 

 we'll study the problem later.") Unless checked. Interior will 

 continue to approach OCS science backwards: there is no 

 problem if there is no information. 



