476 



We have some recommendations for future activities of the BTF. 

 Most of them have been mentioned before. I am simply going to 

 refer to them and not go into a great deal of detail. 



There was discussion before that studies should be designed spe- 

 cifically for lease sale 52, with particular emphasis on the deepwa- 

 ter tracts. We would certainly concur with that. The Department of 

 the Interior apparently intended that leasing would go forward in 

 these areas, although the current body of information about 

 benthic populations, currents, and transport patterns is scanty at 

 this time. 



In reference to Mr. Danenberger's statement that Interior as- 

 sumes there is no greater risk in the deepwater areas than in the 

 areas in which drilling is taking place now, I would like to point 

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

 different organisms in lease sale 52 areas, and different current 

 speeds. So we find that statement to be without basis. 



We really need to know a lot more about lease sale areas. Previ- 

 ous witnesses have recommended integration of studies and infor- 

 mation on Georges Bank and interpretation of these by BTF. We 

 would certainly endorse that idea. I would simply like to add that 

 that BTF should also determine whether there are information 

 gaps in the research and if there are, make recommendations for 

 other studies which should be funded. 



There has also been previous reference to other BTF responsibil- 

 ities which have been identified in the charter of the BTF. To date 

 the group has concentrated on design of the monitoring program, 

 although it was given other responsibilities. We would particularly 

 like to see BTF use the information gleaned from the monitoring 

 program and other studies to identify and develop recommenda- 

 tions for areas of special biological significance in the Georges 

 Bank area, to develop criteria to determine significant impacts and 

 appropriate measures. Possible recommendations could include 

 some of the things referred to before, such as barging of drilling 

 fluids off the bank, building of pipelines, and other measures. 



But above all, the Sierra Club believes no further lease sales 

 should be scheduled on Georges Bank until the biological task force 

 has accomplished these recommended activities. It is important to 

 keep in mind once oil companies own a lease, they have an eco- 

 nomic stake to continue to the production phase if resources are 

 found. We think it is very doubtful that the production stage would 

 be stopped for environmental reasons. 



Equally important as the question of what the BTF has done and 

 should do in the future is the question of whether and how the De- 

 partment of the Interior incorporates the results of the studies and 

 conclusions of the BTF into its decisionmaking procedures. 



We note that Interior initially scheduled lease sale 52 before the 

 monitoring studies for sale 42 were published, before the task force 

 developed any identification of biologically sensitive areas, criteria 

 to determine impacts or mitigating measures, and before informa- 

 tion to deepwater tracts was available. 



We note further that the EIS for 52 did not consider all available 

 and relevant information such as the informtion contained in the 

 CETAP studies that relate to migration patterns of endangered 

 species of whales. 



