475 



For these reasons, the Sierra Club strongly supports the legisla- 

 tion proposed by Representative Gerry Studds and Senator Edward 

 Kennedy which would prohibit drilling in certain areas of Georges 

 Bank until either the year 1990 or the year 2000. 



In response to the question, Mr. Chairman, which you posed to 

 the last panel of what can Congress do, I think I would answer that 

 in the past we have traditionally considered it the Department of 

 the Interior's role to be a steward of our natural resources. They 

 appear to have sacrificed that role to a great extent during this ad- 

 ministration. So perhaps it is necessary at this point for Congress 

 to take action such as those actions suggested in the Studds-Kenne- 

 dy bill, in which areas of particular biological sensitivity are identi- 

 fied and then they are removed from lease sales by legislation. 



The Sierra Club believes that the creation of the Biological Task 

 Force and the development and creation of the monitoring program 

 have so far been of great value and importance. We would like to 

 know in reference to the previous comments about the Department 

 of the Interior's support for this program that it was our under- 

 standing that the program was funded only when the EPA re- 

 quired that results of the monitoring be incorporated into the 

 NPDES permits. 



We believe that the monitoring program provides a good begin- 

 ning for ongoing efforts to evaluate potential impacts to the biologi- 

 cal resources. And the monitoring studies appear to be well de- 

 signed and well executed. One of the greatest concerns of the 

 Sierra Club is the potential long-term effect of drilling discharges. 



Even the final EIS for lease sale 52 acknowledges that there are 

 serious gaps in the information we have about that problem. The 

 EIS, in fact, mentions the possibility of suspension of sediments by 

 accumulation and other possible long-term impacts. 



The BTF monitoring program has developed some excellent base- 

 line data which will enable assessment of the effects of drilling in 

 the future. But the results which are available to date are not a 

 full assessment of impacts of oil and gas drilling in themselves. 

 There has only been a small amount of drilling to date over a rela- 

 tively short period of time, so it is not surprising that there is no 

 demonstrated impact. If impacts on the fishery were noticeable al- 

 ready, then certainly future drilling activity would be very danger- 

 ous. 



We recommended that special attention be paid to the potential 

 implications of the elevated barium levels found on block 410, par- 

 ticularly if future monitoring in this area indicates a consistent 

 pattern. 



And for that reason I did have concern, as I heard earlier in this 

 hearing, there seems to be a possibility that lease sale 42 monitor- 

 ing be discontinued, because it appears then we might not know 

 how significant the findings we have already had on the elevated 

 barium levels really are. 



I did want to point out the EIS for 52 does indicate barium is a 

 metal of concern. And we would take issue with the idea expressed 

 previously that we should wait until the effects show up on the 

 Georges Bank fishery. We would say it is too late when the effects 

 have shown upon the fishery. 



