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Res. 418, which I hope we can get passed here in the House and in

the Senate.

Thank you for the inspiration.

We look forward to your early

and safe return, and probably Bruce Vento can arrange a committee hearing to have you tell the Congress and the country about your exploits, and I know you'll have a lot of support in that regard.

To all of you on the expedition, comrades all, crusaders for the environment, from us here in Washington and in the Congress, good luck! Thanks for your message.

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IMPLEMENTATION OF THE NATIONAL SCIENCE FOONDATION'S STRATEGY FOR COSPLTANCE WITH EWRONMENTAL LAW IN AXTARQUICA

Division of Polar Programs
Office of the General counsel
National Science Foundation

Washington, DC

November 16, 1989

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In ruime 1989, the Director of the Division of Polar Programs (DPP) established a Task Force to align actions stated in oppis Agenda with actions recommended in the National Science Foundation's (NSF) Office of the General counsel's (OGC) review of environmental law and policy in Antarttica; and, to lay at a detailed plan of action and milestones (POASIM) to accomplish the actions. In preparing this document, the Task Force considered DPP's Pnvironmental Protection Agenda action items and OCC's recommendations as required under takings for the U.S. Antarctic Program (USAP). As presented in the occ analysis (see Attachment I to this document), recommended actions were described by reference to types of pollution control. In ander to implement these recanmendations, they were categorized in a matrix by the Task Force as either Management Astions (requiring policy formulation or decisiomaking) or operational Actions (requiring a more direct, hands-on strategy). within each category the recommended actions were then assigned a level of priority based upon accomplishment of subsequent actions (Attachment I). Each recomended action was reviewed to disclose its relevant policy fondations; appropri-ate courses of performance were identified; and finally, estimated levels of effort and funding required to accomplish the action were agreed upon, where possible. The availability of human (internal and external to DPP) and financial resources to accomplish the recommended actions will, of course, be dependant upon existing resources and pending appropriation requests. Estimated costs earmarked for the actions in this report would derive from the NSF's major, multi-year Safety, Environment, and Health Initiative. The Congress has sent a bill to the President to launch this effort. In Fiscal Year (FY) 1990, this Initiative earmarks $10 million to start the undertaking. Cver half of this initial increment is for environmental activities, with the balance earmarked for safety and health-related improvements. The total package is expected to approach $200 million over five years, exclu sive of aircraft acquisition of this amount, over $30 million is reserved for improvement of environmental protection and management. The activities detailed in this document, and their attendant resource requirements, are summarized in its Attachments.

FIDINGS

I. MANAGEMENT ATIONS

Promulgate Environmental Impact Assessment Regulations Me)

Two broad policy mandates, Executive Order 12014, of January 4, 1979, and Antarctic Treaty Consultative Recommendation XIV-2, underlie this require ment. The NSF, as stated in DPP's Agenda, recognizes the requirement to promulgate procedures for environmental impact assessment, and to conduct such assessments of specified actions undertaken in the support of sponsored research activities in Antarctica. This recommended action heads the list of management actions as its completion will help DPP to undertake and complete other environmental protection and management actions, and errvirormental measurements.

DPP has prepared draft procedures for the conduct of such assessments. These procedures are now being reviewed by the OGC. Proposed regulations will be published in the Federal Register for public comment by the end of calendar year 1989, and final regulations are scheduled to be completed during Fiscal Year (FY) 1990. In the interim period, the DPP will continue to conduct, or require the conduct of, appropriate environmental assessments of major Federal antarctic actions. The Task Force estimates that caupletion of this action will require 0.5 tull time equivalent personel (FTE) from DPP with 0.5 FTE support from OGC, and that no studies or additional funding will be necessary to promulgate the procedures.

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Erective Order 12114 and Antarctic Treaty Consultative Reccomendation XIV-2 require environmental impact assessments (TAS), and subsequently, preparation of environmental impact statements (ERISS) for Federal actions found to

have significant impacts in the Antarctic. Escecutive Order 1204 allows agencies to establish categorical exclusions similar to the National Enviromental Policy Act (NEPA).

Environmental Impact Assessment M2A) and M2B). While the occ analysis has concluded that NEPA is not applicable to USAP's antarctic activities, DPP nonetheless recognizes that NEPA provides an appropriate model for assuring the quality of QISAP environmental assessments. Recommendation XIV-2 is consistent with U.S. law and USAP policy, and encarrages Treaty parties to exchange the results of any ETAs and any ESS. DPP will include the findings of its EIAS and EISS in the usual exchange of documents among parties to the Antarctic Treaty. The impact assessment focus of this action will be arrgoing and under the initiation and guidance of DPP. Arrently, such impact assessments are done by DPP staff (appradmately 0.25 FIE). When additional support becomes available, conduct of this work will be assigned to an external support contractor. The cost estimate for this action is $250K over a five year period.

MESTONES

CONDUCT NECESSARY ENVIROMENTAL IMPACT ASSESSMENTS AND STATEMENTS (M2)

(MA) Environmental Impact Assessments

Ongoing

conduct Impact Assessments (In House, Pre-M) Conduct Impact Assessments (Contractor, Post-ta)

Ongoing

(M2B) conduct Other Needed Environmental Impact statements

-Identify Subject Actions

angoing

conduct EISS

As Needed

Update USAP Programmatic Environmental Impact statement mac). In 1988, DPP began the ETS "sooping" process by soliciting comments and whether and how its 1980 programmatic BTS should be revised. During 1989, DPP established an Interagency Agreement between NSF and the Department of Energy's Oak Ridge National Laboratory (ORNL) to update this programmatic EIS. Collection, analysis, and interpretation of information to be used by DPP in the preparation of the ETS is underway by the Integrated Analysis and Assessment section of CRL

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