469 



question of substantial risk is another one. You apply the adjective 

 "substantial" to the term "risk," and you get a question of how 

 much is too much. 



Mr. D' Amours. We all understand that point. But the question is 

 given, as Ms. Hughes just said, that the only basis upon which you 

 can make a judgment as to relative risk, substantive relative risk, 

 granted, is the resource estimate that you are given. 



Now, do you share DOI's view that they are not really worth a 

 whole lot, and you cannot tell until you drill an3rway, so go ahead 

 and drill in any case, and the risk in terms of exploratory drilling 

 is not really substantial anyway. 



Do you share that view, or would you take issue with it? 



Mr. CoLGAN. I would take issue with that view to the extent that 

 one could conclude from the resource estimates that one should 

 drill in every instance. 



I think the evidence is clear that one should not drill in every 

 instance. We have actively opposed leasing in certain areas, such 

 as the canyons. And I would take issue with that statement to the 

 extent that one concludes from that that the resource estimates are 

 irrelevant, or that the process of making a decision about a particu- 

 lar lease sale can take place in the absence of any definite determi- 

 nations about where particular environmental risks are. I think 

 you cannot conclude that leasing is safe in all areas, and that it 

 should proceed therefore. 



Mr. D' Amours. What standard would you use to determine 

 whether leasing should go forward in sales 52, 84, and 96 in 

 Georges Bank, if you cannot rely upon the USGS resource esti- 

 mates? 



Mr. CoLGAN. My own standard in making that decision — and we 

 in the States do have to make that decision is the presence of re- 

 sources which are demonstrably at risk from known drilling haz- 

 ards. And that includes particularly drilling mud discharges as a 

 routine matter. 



By way of illustration, the lobsters and scallops, are the clearest 

 example of a high value fishery which can be located right under a 

 rig. If you dump substantial quantities of drill muds on them, there 

 is evidence in the scientific literature which indicates that both 

 lobsters and scallops are detrimentally affected by drill muds. 



On that basis, I have no problem recommending that those areas 

 be taken out of lease sales. 



I also have a problem with this notion of inventory. Doug talked 

 about that a little bit. 



My reading of the OCS Lands Act amendments and the original 

 OCS Lands Act is that we are selling these leases for the produc- 

 tion of oil and gas, subject to environmental constraints. Interpret 

 "inventorying," to mean "let's find out what is there and then we 

 will know what to do with it." I think this is a mistaken reading of 

 that act. 



We didn't pass the OCS Lands Act amendments to just go out 

 and find out what is there. We passed it to go out and produce that 

 oil and gas which is environmentally sound to produce because, as 

 a nation, we have need of the energy. 



So I have a great deal of trouble with the "inventorying" notion 

 which the Department of the Interior interprets to mean that they 



