488 



its frantic course to develop all OCS resources. This is unwise, unjustifiable, 

 and a gross breech of the public trust. 



Secondly, the studies conducted under the Monitoring Program have taken 

 a fragmented approach to a oonplex ecosystem. The conponents of the ecosys- 

 tem include {though not limited to) the benthic conminity, the planktonic 

 camunity, fish and cetaceans, all living in an amazingly dynamic marine 

 environment. But the studies focus on individual aspects of that ecosystan, 

 and even in this fragmented framework, not all aspects of the ecosystem have 

 been studied. For exanple, while the benthic oonmunity is being studied, the 

 planktonic community is not. Moreover, the results of these individual 

 studies have not been assembled and synthesized in a way that might give 

 some preliminary indications as to how the various factors interrelate. This 

 piecemeal approach can not begin to give a true picture of the exchange 

 mechanisms between the various levels within the ecosystem, because in reality 

 there are no truly distinct "levels" within an ecosystem. There is a whole, and 

 unless the whole can be grasped, understanding isolated parts does little to 

 enhance our knowledge. 



Thirdly, while the program was designed to monitor the long term cumu- 

 lative effects of offshore drilling, by studying the effects of exploratory 

 drilling, it addresses only the inpacts of exploratory drilling, and only 

 in the present. The cumulative inpacts from an accelerated development of 

 Georges Bank, combined with the stress inflicted by oil-laden forrtation 

 waters discharged during the development and production phase Vvon't be 

 estimated by the present studies. These studies will only show what is 

 happening as a result of activities that have already occurred — of what 

 real value is a studies program that is designed specifically to tell us 

 the nature of the environmental destruction we have just comnitted? 



Even the information we do have has limitations which preclude its 

 use in drawing final conclusions, especially in light of the fact that the 

 results now available cover only the impacts of the first year of drilling, 

 when only a few dry holes had been drilled. This can't possibly demonstrate 

 long term cumulative inpacts. 



The studies conducted as part of the Georges Bank Monitoring Program, 

 as well as studies of Georges Bank conducted under the Bureau of Land Manage- 

 ment's Eiivironmental Studies Program acknowledge same of their own limitations. 

 The following quotes fran reports indicate the acknowledged limitations: 



1. "Assessing the Inpact of Oil Spills on a Ccjnmercial Fishery," University 

 of Rhode Island and Applied Science Associates, Inc. 



On page 38 and 39, the authors have listed factors 

 not addressed in the study: 



"1. Effects of oil spills on the food chain 



2. Tainting of fish stocks through ingestion, absorption 

 or bioaccumulation of hydrocarbons. 



3. Contamination of sediments in spawning areas by acute 

 or chronic hydrocarbon pollution, or drilling muds 



4. Effects on adults, including lethal toxicity, and 

 sublethal physiological changes affecting reproductive 

 behavior cr the viability of reproductive products." 



Each of these four factors would be likely to dramatically affect the 

 size of the fisheries stock, or the comnercial value of the remaining 

 stock. As such, this study should not be used as conclusive evidence 

 that the Georges Bank fishery will not be severely impacted by OCS devel- 

 opment. 



