ERDA's SUGGESTED RESPONSE AND/OR COMMENTS Paragraph Deny present existence of NEPA obligations, consistently J with the position expressed at the informal conference with the Court on November 1. ERDA defers to the Department of the Interior (DO1) with respect to obligations under the Trusteeship Agreement. ERDA denies NEPA obligations, but admits jurisdiction and venue. Deny, for lack of knowledge. 3 4, 5, 6 The complaint has no paragraphs 4, 5, and 6. P US DOE ARCH TS Ubjection should probably be made to maintenance of the suit '' are 836 U.S. ATOMIC ENERGY® @ ©]#55 action. Query whether members of the liclass RG_____COMMISSION- -—-—-+z5-humerous as to make it impractical to bring them all ‘ eJ Collection Pos|Dest Files the Court.'' Box__141326 FolderBik Tawsult| may, Our practical concern is that the in fact, run counter to the true desires of some off the Bikinians. Admit. Admit. We note, however, that there appears to be no basis for naming Stanley as a defendant. He has no responsibility for Bikini-related activities, except to provide logistic support as directed. See also our response to Interrogatory No. 1, previously furnished. ERDA defers to Department of Defense (DOD) (though we note the obvious, that Schlesinger is no longer Secretary). WW, 12, 13, 14 ERDA defers to DOI. 63 Enclosure \