U.S. Coast Guard Vessel Response Plans Salvage & Marine Firefighting RRT Update LT Evelynn Samms U.S. Coast Guard Headquarters Office of Vessel Activities, VRP Program 202-372-1225 1 United States Coast Guard Vessel Response Plan Program SMFF Brief SMFF/ CAPS Overview Status Report Response expectations before February 22, 2011 Response expectations after February 22, 2011 Salvage and Marine Firefighting References SMFF Enforcement Status Report United States Coast Guard Salvage and Marine Firefighting Requirement, Vessel Response Plans for Oil, Final Rule Published December 31, 2008 for February 2011 Implementation: Defines SMFF services / resources. Establishes planning timeframes for response. Provides criteria for determining resource provider adequacy. Vessel Owners / Operators must establish SMFF Contracts with Funding Agreements Overview 3 Vessel and Facility Response Plans for Oil: 2003 Removal Equipment Requirements and Alternative Technology Revisions (CAPS); Final Rule Published August 31, 2009 for February 2011 Implementation: Enhances the existing response requirements for vessels and facilities by requiring advance contracts for: Dispersants and related delivery equipment; Aerial tracking and trained observational personnel. Vessel Owners / Operators must establish CAPS Contracts with Funding Agreements Overview 4 Salvage and Marine Firefighting Requirement, Vessel Response Plans for Oil, Final Rule SALVAGE AND MARINE FIREFIGHTING SERVICES: SALVAGE: Assessment and Survey Stabilization Specialized Salvage Operations MARINE FIREFIGHTING Assessment and Planning Fire Suppression Overview 5 United States Coast Guard Salvage and Marine Firefighting Requirement, Vessel Response Plans for Oil, Final Rule Contracts & Funding Agreement Contract or other approved means must include a written funding agreement. Funding agreement ensures that responses are not delayed due to negotiations. The regulation provides a definition of a funding agreement. The Coast Guard is willing to consider the LOF in lieu of a funding agreement in meeting “contract or other approved means” with certain stipulations. Overview 6 United States Coast Guard Vessel and Facility Response Plans for Oil: 2003 Removal Equipment Requirements and Alternative Technology Revisions (CAPS); Final Rule Contracts & Funding Agreement Contract or other approved means must include a written funding agreement. Funding agreement ensures that responses are not delayed due to negotiations. The regulation provides a definition of a funding agreement. The Coast Guard is willing to consider the LOF in lieu of a funding agreement in meeting “contract or other approved means” with certain stipulations. Overview 7 United States Coast Guard SMFF Compliance Status Report Jan 2011 The new requirement affect almost 8000 vessels and over 700 Vessel Response Plans. Conditionally accepted the SMFF “Core” GSA submissions from DonJon Smit, Resolve Salvage and Fire, T&T Bisso and Marine Response Alliance (MRA). Beginning to receive VRPs with SMFF updates. Coast Guard approved Incorporation by reference Most ACPs have addressed SMFF resource updates. Status Report United States Coast Guard CAPS Compliance Status Report Jan 2011 The new requirement affect almost 8000 vessels and over 700 Vessel Response Plans. To date no OSRO has received classification from NSFCC. The “CAPS” dispersant regulation has no provision for waiver request. If vessel owner/operators can’t comply with the regulations they must request Alternate Planning Criteria IAW 33 CFR 155.1065. Status Report United States Coast Guard VRP Program References TVRP – Tank Vessel Response Plans 33 CFR 155 Subpart D, Subpart I (New) NVIC 2-10 – Industry Guidance for Implementation and Enforcement of the Salvage and Marine Firefighting Regulations for Vessel Response Plans Job Aid – Evaluation of Salvage & Marine Firefighting Services CG 543 Policy Letter (09-02) – Alternative Planning Criteria Frequently Asked Questions, http://homeport/uscg.mil/vrp 33 CFR Part 155 Vessel and Facility Response Plans for Oil: 2003 Removal Equipment Requirements and Alternative Technology Revisions; Final Rule. Federal Register 8/31/2009. 33 CFR Part 155 Salvage and Marine Firefighting Requirements; Vessel Response Plans for Oil; Final Rule. Federal Register 12/31/2008. United States Coast Guard http://homeport.uscg.mil 11 United States Coast Guard Salvage and Marine Firefighting Requirement, Vessel Response Plans for Oil, Final Rule CG-543 (Office of Vessel Activities) CAPT Eric Christensen CG-5431 (Domestic Vessels Division) CDR Lee Boone VRP Program Staff LCDR Ryan Allain LT Evelynn Samms LT Jarrod DeWitz Mr. Tim Brown Ms. Patricia Adams MST1 Dean Johnston MST2 Aaron Jessup Program Manager Asst Program Manager/Tank VRPs E-migration and NTVRP Regulatory Development SOPEPS/SMPEPS Nontank Vessel Response Plan Manager Policy Development/Industry Outreach VRP Tracking & Data Entry Oversight VRP Policy & Enforcement- Help Desk 12 United States Coast Guard Questions? 13 United States Coast Guard