- 28 - Paragraph ERDA's SUGGESTED RESPONSE AND/OR COMMENTS (Continued) 103 Deny. 104 Deny. Need for study already denied. ERDA could do it objectively. if it were needed, Plaintiffs’ refusal or Inability to concede that objectivity cannot justify retention of "independent" study group. 105 Conclusion of law which requires no answer. 106 Conclusion of law which requires no answer. 107 Conclusion of law which requires no answer. 108 Conclusion of law which requires no answer. 109 Conclusion of law which requires no answer. In view of the foregoing responses to the numbered allegations of the complaint, ERDA denies each claim alleged in paragraphs 111 through 115, and opposes the grant of any relief sought in the prayer for relief. We do, of course, stick by the agreements voluntarily made in discussions in Honolulu on November 1, 1975, and will work with DO! on resolving the question of funding the aerial survey. DOE ARCHIVES Enclosure 1 GO