special biological significance, and stipulation 2 (the biological 

 stipulation) would be invoked. There would likely follow debate on whether 

 drilling should be allowed. If drilling were allowed, discharges might be 

 prohibited. If not prohibited, it is likely that discharge restrictions would 

 be required, as well as monitoring. The MMS has traditionally taken the 

 position of conditioning activity, and placing restrictions on drilling 

 activity in order to avoid deferring areas from leasing. 



The MMS has taken this approach in some controversial areas, and in many 

 areas it has been a sensible method. But, in the North Atlantic, the 

 information argues for no drilling in submarine canyons, and further argues 

 whether, in fact, the 200-m exclusionary zone is sufficient. 



I will close by noting that, although the present focus is exploratory 

 drilling, the potential impacts of development and production are what most 

 people are concerned about. The reasons include: 



■ transport of materials 



■ pollutants attached to fine-grained sediments 



■ question of the fate of fine-grained materials in the canyons 



■ recognition of the unique canyon habitat 



All four argue for preventing these areas from being leased in the first 

 place. 



- 74 



