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investigation is being completed together with a list

of those items that require new or improved development.

We have informed industry that in those cases where

they do not respond to R&D needs, the Government will

undertake the work. But even so, public funds will need
to be provided.

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Concerning findings of other parts of the study the publication of a list of "Inadequate Components," called for in the recommendation under "Specific Technologies," will be a natural result of our aforementioned failure reporting and corrective action system. Further, these results will provide information to an established research committee to identify items for research and development. The lists of components to be developed, improved, and deployed will be passed on to the R&D committee and to a Standards Committee which is currently very active. The latter committee, by the way, has already drafted detailed standards for improved downhole safety devices which are currently being reviewed. Sand probe development and standards are high on the list of priorities.

Finally, I shall comment on the "General Policy and Management" part of the report. While we agree that promotion and regulation functions should remain divided between the Bureau of Land Management (BLM) and USGS to provide a continuous checking mechanism, we do not agree that the Survey should take the lead in preparing programmatic environmental impact state

ments.

Programmatic concerns should remain the responsibility of BLM or the Council on Environmental Quality, as is the case in the environmental assessment of the Atlantic and Gulf of Alaska OCS. We, as well as National

Oceanic and Atmospheric Administration and many others, provide the geologic, geophysical, seismic, and other environmental data and analyses that are necessary for a full environmental impact assessment. I believe this procedure complies better with the intent, if not the organizational structure, of the study recommendations. The question of sufficiency of data is, of

course, a budget problem.

Concerning the matter of concentration in the USGS of all management responsibilities on the OCS, we are currently working with the Office of Pipeline Safety to specify our respective roles. We have had meetings with the Occupational Safety and Health Administration along the same lines; we are developing understandings with the Environmental Protection Agency, and we do support the Federal Power Commission in providing estimates of recoverable gas reserves.

Lastly, by a recent policy decision, we are now publishing all new and revised OCS Orders in the Federal Register for public comment.

There have been numerous studies, reports, meetings, symposia, and legal actions concerning the development of the OCS. Several are in progress and many more will come. And this is as it should be--on the one side we have a need for the vast mineral resources that lie beneath the ocean floor, and on the other side there is a grave concern over the effects that the exploitation of these resources will have on the environment and hence our future well-being. The significance of the offshore to our national well-being, especially in these times of critical energy shortages, is clear when one realizes that over 11% of the total U.S. oil production and 13% of the gas production came from the OCS in the past year;

that this production is confined to a very small portion of those OCS

areas which have petroleum potential; and that discovery and development will hopefully be accelerated as a result of tripling the offerings to three one-million acre lease sales per year.

The Oklahoma report has gone a long way in identifying means of

improving development in this important area, and we commend both NSF-RANN and the University of Oklahoma on the study.

APPENDIX IV-3

Supplement No. 2

to

REPORT OF THE WORK GROUP ON OCS SAFETY AND POLLUTION CONTROL, MAY 1973

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