As shown by the Verified Complaint, all of the
agency Defendants are agreed that the radiological survey
performed thus far at Bikini is inadequate to the need for
information, on the part of not only the Bikini People, but
also the Defendant agencies.

It is clear that compliance with the National
Environmental Policy Act (NEPA) can only be attained by
zirst completing a valid aerial radiological survey, then
analyzing the data from the survey as well as the data from

evaluation of persons who have been exposed to radiation on
Bikini Island.
Without completion of an aerial radiological
survey,

there cannot ever be NEPA compliance.

Furthermore,

so long as a radiological survey is not completed, the

People of Bikini are precluded from making any decisions as
to wheré they will live or what will be their future.

Irreparable injury is thus ongoing so long as the information
to be gained from a survey is unavailable.
Obviously, the survey is not going to be completed
unless it is, at some point, begun.

ERDA itself expressed a

willingness to start a radiological survey in April 1975.

Verified Complaint § 74.

Request was made that the Depart-

ment of Defense provide helicopters necessary to such a
survey.

The Department of Defense did not bother to reply

to the March 1975 request from Department of the Interior
for helicopter support until May 29, 1975, almost three
months later.

As 44 76-79 of the Verified Complaint show,

Leiters from one cabinet cfficer to another went all the way
around the sorn Zrom ERDA to Interior to Defense and back

again but no helicopters were provided and no aerial radiological

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