481 



Sierra Club Testimony — page 4 



elusions of the BTF into its decision-making procedures. 

 We note that Interior initially scheduled Lease Sale 52 before the 

 monitoring studies for Sale k2 were published, before the Task 

 Force developed any identification of biologically sensitive areas, 

 criteria to determine impacts, or mitigating measures, and before 

 information on deepwater tracts was available. We note further that 

 the Environmental Impact Statement for Sale 52 did not consider 

 all available and relevant information, such as the information 

 contained in the University of Rhode Island CETAP studies, particularly 

 that relating to migration patterns of endangered species of whales. 

 Finally, the Final Notice of Sale for 52 included, in addition to 

 deepwater tracts, seven canyon tracts, despite repeated objections 

 expressed by environmentalists, the fishing community, and the 

 Commonwealth of Massachusetts, and despite the fact that the studies 

 completed to date on Lydonia and Oceanographer canyons indicate many 

 gaps in our understanding of transport of materials up and down * 

 canyon walls, and potential transport off the bank into the canyons. 



The Department of the Interior must revise its approach to the 

 scheduling of lease sales and the preparation of Environmental Impact 

 Statements, substituting bona fide consideration and incorporation 

 of all available scientific information into its decision-making 

 for its present policy. The sensitivity of the Georges Bank area 

 and the value of the ecosystem there dictate a policy of proceeding 

 slowly with extreme caution. With accelerated leasing and drilling 

 programs in this area, it is possible that irreparable harm could 

 already be done by the time impacts are revealed by the studies. 

 Furthermore, the huge areas which are being offered for leasing, 

 particularly as proposed in Sale 82, make sound decision-making about 



