‘Survey was conducted.
survey.

All parties concede the need for a

Until the survey has started, irreparable harm will

continue and there will be a continuing failure to begin
even minizal compliance with NEPA requirements.
This Cours should order the several government
agency Defendants to quit passing the buck and get on with
the job oz completing an aerial radiological survey of

Bikini and such other Northern Marshall's atolls as are
necessary to draw valid conclusions as to the risks of
radiation posed by the Bikini Resettlement and so that the
irreparasle injury to which the People of Bikini have been
subjectec can come to an end at the earliest possible date
and so that all of the agency Defendents can come into
compliance with requirements of NEPA at the earliest possible
date.
It is requested that this Court order the several
agencies 2o commence actuél onsite aerial radiological
surveillence no later then 30 days after the date the preliminary injunction is issued and order thac the aerial
radiological survey be completed no later than 120 days
after the date of the Court's order.

VII. INDEPENDENT ANALYSIS QEgT AVAILABLE cOPY
as stated above, the People of Bikini have utterly
lost faith in the conclusions which have been expressed to

then dv first AEC then ERDA.

They cannot rnake decisions

with which they, as a community, are satisfied, unless they
have coniicgence in the scientific advice upon which those
decisions aust be based.

Furthermore, compliance «;ith NEPA

requires an ability for analysis of technical data independent

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