Civil Division Deputy Assistant Attorney General Washington, D.C. 20530 December 17, Ms. Ruth VanCleve Deputy Assistant Secretary, Office of Territorial and International Affairs 1980 Policy Decartment of the Interior 18th and C Streets, Washington, D. C. Dear Ms. N. W. 20240 VanCleve: The Department of Justice was invited to submit its comments on reports submitted by the Department of Energy and a Department of Interior contractor concerning implementation of Public Law 96-205. As we have previously stated, at the heart of implementation of Public Law 96-205 is a fundamental decision on the scope of its coverage. As you note in your August 8, 1980, discussion paper, the most reasonable interpretation is that the statute contemplates coverage of more than the people of the four named atolls but something less than all of the people of the Marshall Islands. The standard by which additional atolls are covered involves determinations of complex issues which to date the Department of Interior has not attempted to resolve. In the absence of Congressional clarification or agreement by concerned agencies on the standard by which people of additional atolls should be covered, we believe that the implementation of Public Law 96-205 appropriately should be limited to the peoples of the four named atolls. However, we believe significant efforts should be made to resolve the standard issue as expediously as possible in order to determine the scope of Public Law 96-205. Further, in our view, considerations of program efficiency, cost effectiveness and generalized equity do not, standing alone, constitute sufficient grounds by which the coverage of Public Law 96-205 could be extended to all inhabitants of the Marshall Islands. Because the statute obviously does not contemplate coverage of all persons who might have been exposed