Marshall Islands consists of field trip ships operated by the
Division of Transportation of the Trust Territory Government

or privately operated ships, subject to the regulatory
authority of the Trust Territory Government.

During the

past several years approximately 75 people, most of them
members of the Bikini community, have taken up permanent
residence in some of the 40 concrete houses constructed on
Bikini Island, Bikini Atoll.

The field trip ships and other

ships subject to Trust Territory Government regulations
‘continue to provide a means of access to Bikini Atoll.
Statements of representatives of the United States
Atomic Energy Cormission (AEC) and United States Energy
Research and Development Administration

CERDA)

have given

the People of Bikini a basis to believe returm to Bikini
Atoll is a safe thing for them to do.

In other words,

’ Defendants have collectively acted to create a presently
existing situation in which some members of the Bikini
People may go to Bikini for the purpose of permanent residence

there.

BEST AVAILABLE COPY.
Completion of a valid radiological survey of

Bikini Atoll may show that permanent residence in the Atoll
is not acceptable on any practical basis, or completion of
such a survey may show that residence on Bikini Atoll must
‘be made subject to conditions not presently kmown.

Thus,

any person who now goes to Bikini may face a need for further

relocation upon completion of a radiological survey.
Irreparable injury may ensue from either the need for further

relocation or from radiation exposure incurred while at

Bikini Island, or both.

DOE ARCHIVES

To prevent such irreparable injury, this Court

Select target paragraph3