Pretty much what Jeff said. DX is easier for wide angle and macro - and it is hard to make the case for FX when all the camera's now have more than enough image quality for almost every occasion.
Don't get me wrong, FX works underwater. There is just less room for cutting corners and require considerable discipline from the photographer to realise their full potential. The main advantages of FX are high ISO performance and resolution. And you have to put gear lust to one side and ask how much do you really need those two in your photography (two such uses would be someone who does a lot of deep or dark water photography or someone who shoots in an underwater studio). Or if the camera is to only occasionally be used underwater - I prefer FX on land.
The Canon users have already been through this as they have had affordable FX cameras for longer. And during the last generation many of them swapped in their 5D2s or 1DS when the 7D came out for underwater use. Less Nikon users have been exposed to this, although two of the guys I know who shoot the D3X in Seacam housings (you will have seen their photos), use the Nikon 10.5mm for wide angle (shooting in 10MP DX mode) because they are unhappy with what they can get in FX mode. Always seemed an expensive way to shoot 10MP to me - but they are top shooters so I respect their decision.
To get back on topic, when the D7000 came out in 2010, I started using it and it made me realise what my macro had been missing. I had been getting good shots with the D700, so I hadn't realised what I was missing. High magnification shots were 1.5x easier and depth of field would always seem on my side, rather than against me for any fleeting opportunity. My macro took a big jump forward with that camera (despite the fact it had inferior AF to my D700).
Which is why I would like a D300 replacement, 16-18MP and ISO performance to match the D3, and AF from the D4 or D800 - for macro and mini-dome shots. High frame rate/buffer has limited use underwater, but is valuable on land and a high quality DX camera will be excellent for land wildlife.
In 2-3 months time I am sure that the forums will be full of people frustrated that they can't get what they want from the D800. People who come to the D800 from D700 and D3 will be used to many of these issues, but not all. But those coming from D200, D300 and D7000 will have to adapt. How much the changes will be I don't know.
I am fascinated to review the D800 (although Adam will do the main Wetpixel review) because there are several big unknowns about how it will perform underwater. The D800 is revolutionary compared to its predecessors, the other new cameras (D4 and 5D3) are upgrades, evolutionary, and I fully expect them to work like the cameras they replace, only better. It is also likely to be by far the most popular of the three for underwater use.
Alex