444 



In addition the questions we musk ask are likely to be much 



different in deep water. Where we concentrated on benthic 

 impacts on the Continental Shelf, we must now ask: will there be 

 any benthic impacts after drill muds have fallen through a mile 

 or more of water?. Clearly we face entirely different kinds of 

 issues in the deepwater, issues whose shape we can still only 

 dimply perceive. 



The deepwater is only one area where we are proceeding into 

 new territory. The Department of the Interior is considering 

 offering tracts along the northern edge of Georges Bank in the 

 proposed February, 1984 Lease Offering. The wisdom of offering 

 leases in this area I will leave to other discussions, but it is 

 clear that new problems will have to be faced by the Task Force 

 if leases are sold in this region. 



Finally, the EPA is actively considering moving to a 



general NPDES permitting system for Georges Bank oil and gas 



drilling. The Task Force must give careful consideration to the 



implications of general permits for any future monitoring 

 programs . 



The Department of the Interior has already extended the 

 jurisdiction of the Task Force to cover the entire North 

 Atlantic, and continues to give high priority to the monitoring 

 program funding in its Environmental Studies Program. I think 

 the Department recognizes the importance of the Task Force and is 

 committed to using it in future management decisions, and I would 

 like to express my appreciation for that committment. 



As we move into the next phase of the Task Force's job, I am 

 quite optimistic that the overall record of success of the Task 

 Force will be built upon. I have only two major negative 

 observations from the experience to date, one of which I have 

 already mentioned and that is the occasional confusion among the 

 federal agencies about what level of representation is 

 appropriate. Though I am loathe to interfere with federal agency 

 decision making, I do think that the closer to the actual 

 management decisions a person is, the better he will serve both 

 his agency and the Task Force. 



The other negative observation concerns state participation 

 on the Task Force. States were made non-voting members of the 

 Task Force primarily to avoid bringing the Task Force under the 

 restrictions of the Federal Advisory Committees Act. 



Though there is some merit in keeping the Task Force as a 

 relatively informal group without the additional bureaucratic 

 strictures of Federal Register notices etc., it should be 

 remembered that the states are major decision makers in the DCS 



