Environmental Response Policy

5/23/2017: IOSC 2017 Recap #1- Time for a refresh in the pre-spill planning consultation process

Maritime Commons attended the International Oil Spill Conference in Long Beach, California, last week to cover Coast Guard presentations on response related topics. As promised, in the coming days, we’ll be posting recaps of Coast Guard presentations to keep our subscribers who were unable to attend the conference current on the latest Coast Guard policy changes, innovations, trends, and lessons learned.

 To kick off the series, first up is a presentation by Lt. Cmdr. Stacey Crecy on changes to laws and policies governing oil spill preparedness and the pre-spill planning process.

 Crecy’s presentation was part of the “Laws and Policy” session moderated by Andy Nicoll with Oil Spill Response Limited.

Time for a refresh in the pre-spill planning consultation process

Lt. Cmdr. Stacey Crecy of the Office of Marine Environmental Response had the opportunity to present during IOSC about pre-spill planning consultations as required by Section 7 of the Endangered Species Act.

Crecy focused on efforts by the National Environmental Compliance Subcommittee, formed by the National Response Team, to update a 2001 interagency memorandum of agreement guiding federal government coordination to meet environmental requirements during oil spill response and preparedness activities.

Under the ESA, pre-spill planning requires the federal government to evaluate whether response actions are likely to jeopardize the continued existence of any endangered or threatened species or destroy, adversely harm, or modify a critical habitat.

“The pre-spill consultation process is tricky enough on a regular day, but it is more difficult to do during a response and get all the information needed to make a good decision,” Crecy said.

The purpose of the 2001 MOA, which was signed by the Coast Guard, Environmental Protection Agency, Department of State, US Fish and Wildlife Service, Department of Commerce, and the National Marine Fisheries Service, was to: 1) achieve better conservation of listed endangered or threatened species and their critical habitats during implementation of oil spill response activities, and 2) improve coordination of ESA consultations before, during, and after spill response operations.

Crecy said because few forums existed to discuss environmental laws and policies, the NEC subcommittee focused on developing solutions to achieve a common understanding. One of the primary issues revealed during NEC meetings was that conservation biologists and oil spill responders were often conflicted in their interpretations of the wording in the ESA, based on their different professional perspectives.

One tool the NEC subcommittee developed to address this was the response action matrix. The matrix is designed to generate meaningful discussions between responders and biologists to identify natural resources in a particular region that may be impacted during a spill. The matrix identifies 34 spill response activities, such as booming and skimming, and evaluates them against eight specific environmental categories, such as wildlife species and marine environment.

“We found that biologists who aren’t in the field all time didn’t really understand the mechanics of oil spill response,” Crecy said. “The response action matrix helps biologists understand our response activities, which in turn helps them really understand and identify what species may be impacted.”

Crecy concluded her presentation with a brief description of a second tool the NEC subcommittee is developing: the biological evaluation template, which action agencies will use to document pre-spill planning conversations and serve as the basis for their determinations.

“Our ultimate goal is to, of course, increase preparedness and if you’re having these conversations before the emergency then you’re one step ahead,” Crecy said. “When that happens during the consultation at a regional programmatic level, it will at least result in some best management practices that may be incorporated into area contingency plans and increase overall preparedness.”

Want more information about the Coast Guard’s work on the National Environmental Compliance Subcommittee? Post questions below or email Lt. Cmdr. Crecy in the Office of Marine Environmental Response.

Want to read more from the Coast Guard at the 2017 International Oil Spill Conference? Check out our previous posts on Maritime Commons:

6/5/2017: IOSC Recap #5 – USCG Sector Delaware Bay: Response to rail incidents planning project
5/25/2017: IOSC Recap #4-Tank Barge APEX 3508: Best practices for detection and recovery of sunken oil
5/25/2017: IOSC Recap #3-Tank Barge Argo: A case study on the employment of NCP special teams

5/23/2017: IOSC 2017 Recap #2-In a hostile environment? Skills needed for success

5/23/2017: IOSC 2017 Recap #1- Time for a refresh in the pre-spill planning consultation process

5/16/17: IOSC 2017 – Opening plenary session – Prevent, Prepare, Respond & Restore


This blog is not a replacement or substitute for the formal posting of regulations and updates or existing processes for receiving formal feedback of the same. Links provided on this blog will direct the reader to official source documents, such as the Federal Register, Homeport and the Code of Federal Regulations. These documents remain the official source for regulatory information published by the Coast Guard.

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