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 Environnental Policy Act (NEPA) can only be attained by first 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. peggy AVAILABLE COPY Without completion of an aerial radiological survey, there cannot ever be NEPA compliance. Furthermore, 50 long as a radiological survey is not completed, the People of Bikini are precluded from making any decisions as to where 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 4 74. Request was made that the Depart- ment of Defense provide helicopters necessary to such a survey. The Department or Defense did not bother to reply to the Marcn 1975 request from Department of the Interior for helicopter support until May 29, 1975, almost three ‘wonths later. As %% 76-79 of the Verified Complaint show, letters from one cabinet officer to another went all the way ARCHIVE around the horn from ERDA to Interior to Defense and back DOF again but no helicopters were provided and no aerial radiolosical - 10 - ZO i)