438 



In the absence of the kinds of studies that the task force recom- 

 mended, EPA would have been hard-pressed to make a decision 

 that would not have been challenged. But with the studies and 

 with the consultative role that the task force was able to serve, 

 EPA's permitting process went ahead with some degree of credibil- 

 ity. 



A major reason for that credibility is that the task force did its 

 work in a relatively open and forthright fashion. It conducted its 

 meetings in public; it offered opportunities for members of the 

 public and the States to comment and be involved throughout the 

 process not only in the formal task force meetings but in the devel- 

 opment of the monitoring program in the subcommittee. This role 

 of providing a public forum to discuss the issues surrounding the 

 permitting and the beginning of exploratory drilling off Georges 

 Bank was a very critical one. 



It was also important that the task force created a scientifically 

 sound monitoring program. They had the benefit of being able to 

 review and criticize a number of earlier drill mud studies and then 

 attempt to develop a study which corrected the problem with earli- 

 er studies. As a result, I think they have designed and overseen 

 perhaps the best studies to date on the fate and effects of drill 

 muds, which is certainly one of the central issues in the regulation 

 of oil and gas drilling. 



The results of that monitoring program are now beginning to 

 come in. While there is still a great deal of work to be done. But 

 the early results give cause for optimism that oil and gas oper- 

 ations on those ecosystem types on Georges Bank that were stud- 

 ied, and from the point of view of the routine discharges that were 

 examined, present relatively few conflicts. 



These successes of the task force I think are noteworthy and are 

 a cause for optimism in the future. But I don't think they can be 

 taken as evidence that oil and gas activity is now capable of pro- 

 ceeding on a full-speed-ahead basis on Georges Bank, or anywhere 

 else for that matter. There are still some major problems the task 

 force is going to have to look at. 



A first order of business is going to be to figure out what the re- 

 sults mean — when the final reports from the first-year studies 

 come in. 



The task force has a responsibility to recommend to MMS con- 

 cerning biological impacts and an implicit responsibility to assist 

 EPA in its regulatory decisions. It must begin considering relative- 

 ly soon what the results of the monitoring program mean and 

 whether, for instance, EPA's permit restrictions on drilling dis- 

 charges should be continued, modified, or eliminated. 



The task force is also going to have to begin considering the deep 

 water issues. We heard a little bit about that this morning. Clearly 

 some of the things the task force has done so far are going to have 

 to be radically altered in the deep water. Where we looked at 

 benthic impacts in the Georges Bank, we are going to have to be 

 asking questions such as: What are the impacts of drill muds fall- 

 ing through nearly a mile of water instead of 4 or 500 feet of 

 water? 



This is a whole new set of issues that will have to be addressed. 



