Commercial Vessel Compliance

Gov’t Initiated Unannounced Exercise program requirements for FY20

The Coast Guard on Sept. 30, 2019 published the FY20 Government Initiated Unannounced Exercise (GIUE) requirements for each Captain of the Port zone, sector, and marine safety unit, in accordance with the maximum number of GIUEs permitted under regulation and the National Preparedness for Response Exercise Program Guidelines.

GIUEs are a cornerstone of the area oil spill exercise cycle and a key tool for Captains of the Port to evaluate risk and measure oil spill response preparedness. One of the key benefits of the GIUE program is the ability for COTPs to identify risks and apply a structured average most probable discharge (AMPD) exercise to analyze the plan holder’s capabilities.

Requirements for AMPD equipment are defined in 33 C.F.R. § 154.1045(c) and 33 C.F.R. § 155.1050(d). Plan holders do not meet these requirements by merely staging the equipment onsite. One of the exercises that plan holder’s receive credit for is an equipment deployment exercise. Therefore, adequate amounts of this equipment should be deployed and observed in an operational state during a GIUE. Containment boom, along with all necessary equipment for proper deployment, are to be in place within one hour and skimming devices, including temporary storage, within two hours. These requirements specify criteria to be used during the planning process and are not performance standards. As such, some time variance based on actual exercise conditions may be granted.

Coordinating GIUEs with other agencies benefits both plan holders and governing agencies alike. Joint GIUEs are a success story as they achieve the goals of testing industry, improve interagency relations and provide training opportunities, while concurrently reducing industry’s exercise burden. It is a priority for Coast Guard units to conduct joint exercises with partner federal, state, and local agencies when possible.

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.