510 



2. At a meeting in May, I understood that there were severe 

 budgetary constraints in the DOI environmental studies program, and 

 that an effect of Secretary Watt's accelerated leasing program was 

 a reduced studies program. In my view, this seems contradictory 

 and is contrary to reasonable and careful progress. The environ- 

 mental studies should go hand-in-hand with the associated leasing 

 activities. 



3. I have the impression that the DOI is de-emphasizing pre-lease 

 studies and instead beginning to focus on post-lease studies. The 

 studies preceding leasing activities in an an area are important to 

 assessing environmental impacts and preparing the EIS. Particular- 

 ly in upcoming lease areas where required or suggested studies have 

 not taken place, it is my view that, as a general policy, leasing 

 should not occur in the absence of such studies. Where approp- 

 riate, pre-lease environmental studies should definitely be 

 continued. 



4. At present (and perhaps in the near future) , we in the 

 northeast are experiencing a lull or decrease in leasing activi- 

 ties. This is due in part to various court and legislative 

 actions. My concern is that DOI will interpret this as a signal to 

 correspondingly decrease the level of environmental studies — 

 reasoning perhaps that since there is no leasing activity, there is 

 no need for environmental studies. Assuming that there will be 

 additional leasing activities in the future (an assumption I think 

 most will recognize as probable) , it is my view that this lull 

 should be used to advantage. Needed studies should be initiated 

 and/or carried forward, as appropriate. This is particularly true 

 since very often studies require three or four years to produce 

 useful results. Waiting until leasing activity again resumes and 

 then calling for the required studies will not allow sufficient 

 time for data collection. This may result in further delays or 

 perhaps leasing activities proceeding in the absence of appropriate 



