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
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