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Testimony of MAS on BTF 

 Page Three 



Another mandated responsibility the BTF must assume is developing criteria 

 for evaluating adverse biological effects on the ecosystem. Violating 

 standards developed by the BTF can terminate or modify OCS activities. These 

 criteria should be developed at the earliest possible date since they will 

 be an important safeguard to protect the Georges Bank fishery. 



The BTF must also begin to evaluate all ongoing. North Atlantic studies. 

 With this overall perspective, they could identify gaps in scientific research. 

 The task force should also i;ranslate the results of the studies into a form 

 or summary that would facilitate their use in the decision making process. 

 The greatest impact to the marine environment will result from chronic 

 and accidental discharges during the production phase; the BTF should 

 look ahead and determine what baseline studies will be needed in order to 

 enter the production phase. 



But the most critical question about the environmental studies in the 

 North Atlantic is how they are being used in the decision making process. 

 Tbat the environmental studies and lease sale decisions have not been coordi- 

 nated is a major weakness in the OCS leasing process as it has been conducted 

 in the North Atlantic and other areas. The Department of Interior has main- 

 tained a rigid leasing schedule that has not been sensitive to environmental 

 concerns. 



Rather than designate Georges Bank a marine sanctuary, the DOI instead 

 compromised and created the BTF. Once created, the DOI chose not to fund 

 it. It was not until the EPA required funding for the BTF as a condition 

 for Issuing the NPDES permits for Lease Sale 42 that DOI came through with 

 funding. 



The BTF began the monitoring program and other studies but DOI maintained 

 its schedule without regard to the completion of these studies. The USGS 

 began a study of sediment transport and water movement in the canyon area 

 in 1981 but when DOI proposed Lease Sale 52, the canyon areas were included 

 in the sale — even though results from the canyon studies were not yet available. 

 The USGS is just now preparing the report on the first year data. If the 

 court had not Issued a preliminary injunction on the sale, canyon tracts would 

 have been leased before the results of the scientific study could be used 

 in making decisions. This is one example of how the leasing process is not 



