485 



While the work already undertaken has added to our knowledge, 

 it should be viewed as a minimal effort. In light of the problems 

 with the current studies program, Greenpeace strongly makes the 

 following recommendations: 



There should be no new leasing of OCS tracts, or drilling of lease sale 42 tracts 

 until: 



All toxic chemicals can be traced completely through the ecosystem; a document 

 is prepared which syntheses all of the work done on Georges Bank to date; and a 

 holistic model is developed which provides a framework for further studies that en- 

 compass the entire ecosystem. 



The most important point to remember about the studies done to 

 date is this: They represent the immense burden of proof incum- 

 bent upon the Federal Government to show that drilling will not 

 interfere with the delicate ecosystem of Georges Bank. 

 With respect to fluctuating resource potential estimates: 

 Section 18 of the Outer Continental Shelf Lands Act (OCSLA) re- 

 quiries that the Secretary manage an oil and gas leasing program 

 consistent with certain principles. The law states that: 



Management of the Outer Continental Shelf shall be conducted in a manner 

 which considers economic, social, and environmental values of the renewable and 

 nonrenewable resources contained in the Outer Continental Shelf, and the potential 

 impact of oil and gas exploration on other resource values of the Outer Continental 

 Shelf and the marine, coastal, and human environments. 



In the balancing equation, estimates of resource potential must 

 be compared against the potential for adverse impact to various re- 

 sources such as fisheries, endangered marine mammals, and recre- 

 ational areas. 



It is clear from Judge Mazzone's decision on lease sale 52 that 

 the Department of the Interior failed to do an adequate analysis 

 based on its own limited interpretation of the law. 



Regardless of the error made by Interior in this particular case, 

 section 18 should be interpreted in a broader sense. In particular, 

 the one factor that has never been included in the balancing equa- 

 tion is the value of "the renewable and nonrenewable resource con- 

 tained in the Outer Continental Shelf as required by section 18. If 

 we are to fulfill our roles as trustees of the Earth for future gen- 

 erations, we have to begin to weigh our priorities differently when 

 we make balances such as that required by OCSLA. 



The Department of the Interior, as managers of lands valued by 

 competing interests, must be required to protect those resources 

 over the long term. For this reason, as part of the balancing, a dif- 

 ferent kind of assessment should be included as a priority. 



The life of the oilfield, as explained in the impact statement for 

 least sale 52, is estimated to be approximately 30 years. The life of 

 the Georges Bank fishery, if protected, will remain as it is now, as 

 far into the future as we can see. This should be part of the bal- 

 ance. 



Moreover, the development of renewable alternative energy 

 sources, which once developed also have an indefinite lifespan, is 

 not considered in the EIS as a possible substitute for offshore oil 

 and gas development. This, too, should be part of the balance. 



Similarly, the environmental hazards should be compared be- 

 tween the various sources of energy alternatives, and should enter 

 into the balance. I have oftentimes heard Mr. Watt claim that off- 



