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unsound and administratively cumbersome. It is nearly impossible for meaningful data and conclusions about environmental impact to be to be generated about a multi-million acre study area. As we stated in our comments on the five Year Plan Ers, we believe the lease sale EISs should focus on tracts where there is geologic potential, industry interest, and a minimum of environmental conflict to allow for a more effective and useful environmental impact assessment and review process. CONCLUSIONS ABOUT IMPACTS Past lease sale and five year plan EISs have all contained conclusions which essentially dismiss or minimize any environmental concerns about oil drilling in the North Atlantic. Although we believe a conclusion of minimal impact might be justified in isolated situations depending on site specific data, we do not agree that such conclusions can be drawn gonorically for all future drilling activity in the North Atlantic, as has beon done in past EISs. These past Eiss reflect a predisposition to dismiss onvironmental concerns using what we perceive to be three lines of faulty reasoning: 1) Because the areas directly exposed to drilling are expected to be small relative to the entire sale area, the impacts ar. "averaged out to be small; 2) because past drilling on Georges Bank (eight exploratory drill rigs) apparently resulted in no significant, long lasting adverse effects, it is assumed that the same will be true in the future; or 3) because :ertain impacts, such as to submarine canyons, are expected to be localized, they are as• sumed to be minor. (Please refer to the discussion about environmental consequences of North Atlantic lease sales on pages IV.8.1.-10 through IV.B.1.-32 of the Final Eis for the 1987-1992 Five Year Plan for examples of the three types of conclusions). Regarding the first type of reasoning, we believe the nature of the impact itself or value of the impacted resource is the relevant issue, not how the impact compares spatially to a multi-million acre area in the North Atlantic. The second approach draws on the extremely limited experience of only eight drili rigs and transposes that experience to the future, even though future drilling could involve activity much more extensive and in different locations in the North Atlantic than occured following Lease Sale 42. The third type of reasoning, equating "localized with

minor impacts, is on its face ill-founded. An adverse impact 'localized in a critical spawning area for a commercially important species such as scallops could be quite severe both biologically and in terms of of economic impacts. We urge MMS to avoid use of these kinds of reasoning in the lease Sale 96 EIS and subsequent decisions.

Our reason for focusing on the approaches which have been taken in past biss is not to dwell on unresolved concerns we have had. but rather to express our hope that the next EIS process be carried out in a manner more reflective of the concerns so many have voiced throughout the history of the ocs program in the North Atlantic.

We would be pleased to assist you in any way that we can during the development of the EIS. In the moant ime, feel free to call me at FTS 835-3416 (commercial 617/565-3416).

Sincerely,

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Elizabeth Higgins eongram
Assistant Director for Environmental Review

Office of Government Relations and Environmental Review

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This is la regard to the letter dated July 3, 1987, from the Assistant Director of Eavironmental Review, EPA Region 1. That letter (copy eaclosed) contained scoping comments for proposed Outer Continental shelf (OCS) Lease Sale 96, tentatively scheduled for February 1989, We were somewhat surprised and disappointed that comme ats from another Federal Ageacy vould be presented la such a way as to potentially undermine the ocs leasing program in the North Atlantic. This is particularly disturbing coas idering the fact that evidence for the recommendations is either absent or based on lacorrect lafomation. In addition, we have noticed a strong parallelism between the EPA comments aad those we have received from outside groups which have traditionally opposed our program. It was distressing to see a blanket endorsement of presently uaknown requests for further deferrals which appeared la the letter as, "aay other deletioas recommended by states." We feel that this apparent lack of objectivity and support for conflicting laterests, without documentacioa, does not eahaace the overall public perception of either of our Agencies. The Departmeat of the Interior's focused leasing policy is desigaed to balaace protection of the eavironment with the Nation's need to explore for and develop domestic energy supplies. By charter of the OCS Lands Act and a fim belief in a multiple use concept for our Nation's OCS lands, the Minerals Management Service vigorously pursues resolutioa of aay perceived or actual coaflicts associated with eavironmentally safe laveatorylag of hydrocarboa resource potential. We are perplexed at Region I's decision to resubuit comments, generally hostile to the S-Year Progra, considering that this program had been reviewed by the United States Coagrus and approved by the Secretary of the Interior. In addition, the tone and substance of the letter do little to assure us that we would in fact receive the assistance offered. This is especially troublesome la light of the ongoing effort between our Agencies to develop and implement aa MOU regarding our mutual res poasibilities for regulating activities on the ocs. Laclosed is a detalled response to many of the comments contained in the July 3 letter. We hope it will clarify aay ni sconceptions regarding the techaical aspects of our program.

We are available to discuss this matter and trust that a mutually beneficial exchaage of information will occur in the future.

Siacerely,

Bucet. Washion

Bruce G. Weetma
Regional Director

3 Laclosures

Response to July 3, 1987, letter from
the Environmental Protection Agency

Region 1

Comment:

the risks posed by oil and gas drilling are unreasonable and unnecessary in view of .. and the low level of industry interest in the area.

Response: The "risk" is actually quite low. The 5-Year Environmental Impact statement estimated mean number of spills (with two North Atlantic sales on the schedule) is 0.16 with a 15 percent chance of a spill (1,000 barrels or greater) occurring over approximately 30 years. For Sale 82, during the assumed production life of the proposed action (approximately 30 years) the oil spill Risk Analysis Model projected a nean number of 0.40 spills greater than 1,000 barrels and approxima tely 0.19 spills greater than 10,000 barrels. The probability of oil spill occurrence (if oil is present) is based on the assumption that realistic es tina tes of future spill frequencies can be based on past OCS experience. Sources of da ta include accident files, production records, Devanney and Stewart (1974, 1976), Danenberger (1976, 1980), and other published literature -the oil Spill Intelligence Report (1979 and 1980) as well as a worldwide survey of tanker accidents.

Concern about potential oil spills has spurred Federal regulatory changes and technological advances to reduce the likelihood of a spill. These changes include tighter controls over drilling mud systems, more stringent casing, cementing, testing programs, inspection and emergency testing for blowout prevention, and training of rig personnel. The success of these measures is illustrated by the fact that only about 1,600 barrels were spilled from all sources related to ocs oil and gas operations undertaken in 1985 nationwide. To put this figure in perspective, ocs oil and condensate production in 1985 was almost 400,000,000 barrels. Additionally, oil imports pose environmental problems resulting from potential oil spills from the foreign tankers that bring oil into U.S. waters. Not only are foreign tanker spill rates higher than those of U.S. tankers used to transport ocs crude oil, but petroleum imports increasingly tend to be refined products which are more toxic than crude oil.

Gas

Furthermore, the North Atlantic area is considered to be gas prone. can play a major role in replacing oil in stationary applications. Many facilities in the North Atlantic which use oil to fuel industrial and utility boilers are capable of burning natural gas as well. However, the gas must be available. While there is a "bubble' of gas, i.e., surplus deliverability, at present, the decline in drilling which is eroding the proved oil reserve base, is affecting natural gas supplies as well. Therefore, irrespective of the size of the resource base, there is no guarantee that gas will be deliverable.

2

The statement that "there is a low level of industry interest in the area" is untrue. We announced at the recent scoping meetings (that EPA attended) that we received 1,272 nominations on 1,036 blocks in response to the call and Supplemental Call for Information (November 4, 1986, and Pebruary 25, 1987, Federal Register Notices). We are, therefore, proceeding with our pre-gale process.

Comment: "... the 5-Year Program includes no deferrals of any part of the North Atlantic we request that the EIS thoroughly examine the full range of alternatives involving deletions of areas of concern ... tracts included in the Congressional nora torium .. tracts adjacent to and in submarine canyons

the Gulf of Maine ... any other deletions recommended by states . . . you should focus on tracts where there is geologic potential, indus ery interest and a minimum of environmental conflict ... Response: This Eis, like its predecessors, will be prepared in full compli ance with all statutory and regulatory requirenents and guidelines. Furthermore, it will be based on the most current, credible scientific information available. Every connent we receive will be considered. Special consideration is given to state comments as required by Section 19 of the OCS Lands Act. we are meticulously examining the full range of alternatives which will ultimately be used during the Secretarial decision process. As it has in the past, the EPA Region I will receive a copy of the Draft EIS for review and comment.

The statement, that there have been no deferrals of any part of the North Atlantic, is not correct. Rather, 89 percent of the North Atlantic Planning Area has been deferred from Sale 96. EPA's letter asks that we consider the deferral of the moratorium area. We note that blocks prohibited from leasing by the Congressional mora torium were never considered for inclusion in Sale 96.

For the record, the Leasing mora torium (generally) includes:

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As was announced at the 5-Year Program stage, in Sale 96 press announcements, and at the Sale 96 scoping meetings, two additional major North Atlantic subareas are deferred through mid-1992:

° 15 Nautical miles Offshore, or Further Offshore,

to the limit of Low Hydrocarbon Potential

• The Gulf of Maine, North of 42°30'N Latitude

84-150 0-88---17

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