i^b 



the cxjncentration may decrease, their toxicity and their presence does 

 not disappear. The lack of knowledge surrounding the dispersion rate 

 and process will not help mitigate future effects of cijmulative and 

 chronic discharges in an increased development scenario. For example, 

 if there is an increase in the quantity of drilling muds discharged 

 in future development, we might see a threshold effect, i.e. in small 

 quantities we see no effect, until at sane critical level, we are 

 suddenly faced with a contamination problem. 



4. "Cetacean and Turtle Assessment Program (CeTAP)", University of Rhode Island 



Page 5 - The CeTAP study area did not extend beyonS the 1830 

 meter isobath. 



Lease sales 52 and 82 both offer tracts which seem to have drawn high 

 oil industry interest well beyond the 2000 meter isobath. 



All of the above mentioned studies recamnend fiirther study of the Georges 

 Bank region. This is the greatest indication that the researchers themselves 

 realize that studies performed to date do not provide a cortplete picture of 

 the dynamics of Georges Bank. 



While the WDrk 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 corpletely through the ecosystem 

 -A document is prepared which synthesizes all of the work done on 



Georges Bank to date 

 -A holistic model is developed v^ch provides a framewDrk for further 

 studies that enconpass the entire ecosystem. 

 The most important point to remember about the studies done to date is 

 this - they represent the immense burden of proof incumbent i^Jon the federal 

 government to show that drilling will not interfere with the delicate ecosystem 

 of Georges Bank. If studies vere to shew an irrpact, this irrpact wDuld be a 

 significant find, as we have been looking at a limited portion of the eco- 

 system. However, if no irrpacts can be found, the burden of proof ranains 

 great to claim that none exist. 



REDUCTION IN RESOURCE ESTIMATES 



Section 18 of the Outer Continental Shelf Lands Act (OCSIA) requires 

 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 vrtiich considers econcmic, social, and 

 environmental values of the renewable and nonrenewable resources contained 

 in the outer Continental Shelf, and the potential iirpact of oil and gas ex- 

 ploration on other resource values of the outer Continental Shelf 

 and the marine , coastal , and hurran environments . " 



In the balancing equation, estimates of resource potential must be can- 

 pared against the potential for adverse impact to various resources such as 

 fisheries, endangered marine manrtBls, and recreational areas. 



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

 Department of Interior failed to do an adequate analysis based on its own 

 limited interpretation of the law. Just prior to the publication of the 

 final environmental irrpact statement, resource estimates decreased by 97%, 



4 



