survey was conducted. survey. All parties concede the need for a Until the survey has started, irreparable harm will continue and there will be a continuing failure to begin even minimal compliance with NEPA requirements. This Court should order the several government agency Defendants to quit passing the buck and get on with the job of completing an aerial radiological survey of Bikini and such other Northern Marshall's Atolls as are necessary to draw valid conclusions as to the risks of radiation posed by the Bikini Resettlement and so that the irreparable injury to which the People of Bikini have been subjected can come to an end at the earliest possible date and so that all of the agency Defendants can come into compliance with requirements of NEPA at the earliest possible date. It is requested that this Court order the several agencies to commence actual onsite aerial radiological surveillance no later than 30 days after the date the preliminary injunction is issued and order that the aerial radiological survey be completed no later than 120 days after the date of the Court's order. VII. INDEPENDENT ANALYSIS As stated above, the People of Bikini have utterly lost faith in the conclusions which have been expressed to canem by first AEC then ERDA. virn which they, They cannot make decisions as a community, are satisfied, unless thev have coniidence in the sclentizic advice upon which those cecisions must be based. Furthermore, compliance with NEPA requires an ability for analysis of technical cata independent 9052081 tte