December 26, 1988

Dr. Fred Piltz, Chief

Environmental Studies Section

Minerals Management Service

Pacific OCS Region

1340 West Sixth Street

Los Angeles, California 90017

Re: Pacific OCS Region Draft Environmental Studies Plan, Fiscal Year 1990, September, 1988

Dear Sir:

I would like to offer the following comments on the DESP. I would like to start with an analogy. If you take a sharp axe into the woods, you can chop down a tree in a few minutes. It is extremely unlikely that there will be anyone or anything there to stop you. I say this to make two points: the environment is very sensitive; and it has almost no protection. There are no policemen standing by to protect nature. She is totally vulnerable.

Another analogy. If it were proposed that every child in the U.S. were to be taken from its mother at birth and raised by the State, we would not be funding scientific studies on the effects of this, studies on ways of mitigating the negative effects, or "baseline" studies so we could determine whether it would have any negative effects. Whoever proposed this nutty idea would have to prove its value. The burden of proof would not be on the public.

It is time that we apply the same reasoning to projects that are just as nutty, and that obviously threaten enormous environmental damage: the burden of proof, and the cost of the justifying studies, must be shifted to the project proponents, to prove that the environment will not be seriously damaged. The number and magnitude of environmental threats are so great that they simply cannot be handled by a system that requires the public

to prove the harmfulness of each and every such project. The deck is stacked heavily toward the exploiters. The fox is guarding the chickens.

In your case, all studies must be done hurriedly, yet scientifically (these qualities are mutually exclusive). None of these studies will ever discover such long-term effects as cancer or genetic damage, because you don't allow them the necessary time. Since you control the funding of research, it is unlikely that a study attempting to show why the drilling should not be done would get funded. The only studies you fund seem to assume that the drilling will be done, and aim to find out how to mitigate the negative effects (as though such things can be mitigated; how would you mitigate living in an oil spill? Would buying everyone rubber boots make it okay?). On the other hand, the oil drilling proponents aren't required to hurriedly (or in any other way) provide scientific proof that the drilling is a good thing. (By the way, scientists are people who are paid in order to give them the freedom to do unbiased research. "Industry scientists" (p.6) is an oxymoron. You cannot get honest research from people who have a monetary stake in the outcome.)

Your air quality strategy is an example of the dice being loaded. Dispersion characteristics are irrelevant. If damaging pollution is being released, who cares whether it goes toward San Francisco, Japan, or the upper atmosphere? That is too unpredictable. But what is predictable, is that it will be damaging. If we spare California, but pollute someone else, we can be sure that the same will be done to us. The world is too small nowadays for this type of irresponsible thinking. What is important is the worldwide pollution inventory. The world is essentially a single air basin. If we were to apply the Golden Rule, then polluters would be required to breath their own poisons, and there would be no pollution problem.

On p. 31 you mention "the review, summarization and synthesis of existing ... literature". Depending on who does this, it could produce helpful clarification, or propaganda. You should stick to publishing, and leave the editing to the (true) scientists.

On p. 35 you state: "The primary objective of the endangered species studies funded by the Pacific OCS Region is to determine and minimize significant risks to the marine mammmal and seabird populations from potential impacts of OCS oil and gas development." You beg the question of whether the drilling should go on at all. You also assume that "minimized" risks will be acceptable. You also ignore the thousands of species (e.g. microorganisms) that may be endangered but aren't on any official list of Endangered Species. This passage illustrates all of my points: nature cannot protect herself; putting the burden of proof on the public will simply ensure that the environment will continue to lose most battles; you apparently intend to proceed with the drilling, regardless of the research (since it is surely obvious what the research will show: the drilling will be very harmful to the environment); the dice are loaded to come up "drill"; and there really is no way to "mitigate" such damage.

My recommendation is that you demand that the beneficiaries of these projects show how they will ameliorate, rather than aggravate, air pollution, the greenhouse effect, the ozone depletion, the devastation and extinction of species, and the ocean environment. If and when they can satisfy all of their opponents, then approve the projects. (If, for some reason, you can't do that,

then make sure that studies by groups and individuals opposing the drilling get funding preference, since the deck is already heavily stacked in favor of the drillers.)

The Indians had the right idea: nature doesn't belong to us; we are only, at best, caretakers. You should change your name again. Department of Offshore Drilling would be more accurate. The minerals don't need to be managed. They are doing just fine where they are, thank you. And so are we.

Respectfully yours,

Michael J. Vandeman, Ph.D.