441 



first was to defuse the storm of controversy which surrounded the 

 decision in 1979 not to pursue the possibility of a Marine 

 Sanctuary on Georges Bank. 



To allay concerns that the biological implications of OCS 

 operations resulting from Sale 42 would receive insufficient 

 attention at the Department of the Interior, the Biological Task 

 Force was formally established by interagency agreement, with 

 rights of appeal spelled out should any agency be aggreived by a 

 Task Force decision. 



This formality was unique to the North Atlantic BTF. 

 Biological Task Forces had been created in other leasing regions, 

 but on an informal basis to provide a consultative mechanism for 

 the various agencies involved in overseeing oil and gas activity. 



This consultative role was the second major purpose of the 

 Task Force. The need to coordinate the activities of Interior, 

 NOAA, and EPA in OCS management decisions, particularly with 

 regard to conflicts with fisheries, has been apparent for some 

 time. The federal government is not well organized to handle 

 these conflicts, since the oil and gas responsibilities are in 

 one department, where they receive regular secretarial attention, 

 and the fisheries responsibilties are in another department, 

 where they are located in a relatively small bureau which is 

 somewhat outside the mainstream functions of the department in 

 which they are located. 



There is thus a critical need for regular contacts between 

 Interior and NMFS to deal with fish/oil conflicts. Since EPA 

 also has a role owing to its substantial permitting 

 responsibilites , the Task Force is composed of the appropriate 

 federal agencies to consider the operational aspects of oil and 

 gas regulation. 



There have been difficulties caused by these agencies' 

 occasional inability to decide between having representatives 

 from the headquarters or regional levels as their 

 representatives, but by and large the Task Force has provided a 

 good means of coordinating federal agency activity. 



This was especially apparent during the permitting process 

 for the wells drilled on Sale 42 blocks. The Monitoring Program 

 which the Task Force recommended was essential to the granting of 

 the NPDES permits by EPA, since it allowed for the granting of 

 permits conditional on further study. 



With the substantial controversy surrounding the fate and 

 effects of drill muds which was going on at the time, EPA would 

 have been hard pressed to issue an NPDES permit based on a 



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