The Coast Guard Cutter Hickory crew performs an annual-required deployment of the ship’s spilled oil recovery system as part of a demonstration of pollution response capabilities in Dutch Harbor, Sept. 13, 2011. (U.S. Coast Guard photo)

GAO: Improved Analysis of USCG Vessel Response Plan Use Could Help Mitigate Marine Pollution Risk

Coast Guard regulations require tankers and other large vessels to have plans for responding to incidents that caused or could cause an oil spill. Plans must identify response resources, such as the equipment needed for spill cleanup, salvage, and firefighting.

However, the Government Accountability Office found that the Coast Guard has only verified the accuracy of the salvage and firefighting information in 71 of over 3,000 of these plans.

The Coast Guard has started to collect data on whether these plans were followed in past incidents. GAO made 2 recommendations, including that the Coast Guard use incident data to improve how it reviews these plans.

The U.S. Coast Guard’s (Coast Guard) processes for reviewing and approving vessel response plans (VRPs) assess whether they comply with regulatory requirements and have contracts in place for response resource providers, such as oil spill removal, and salvage and marine firefighting services. GAO and industry stakeholders identified risks in the Coast Guard’s processes such as the

  • relatively small number (71 of more than 3,000 VRPs) of verifications conducted of salvage and marine firefighting response capabilities;
  • limited availability of reliable data on the location of oil spill and marine firefighting response capabilities; and
  • limited availability of certain resource providers to respond to an incident.

For example, industry stakeholders stated that some subcontracts with salvage and marine firefighting resources provide that the subcontracted vessels are obligated to respond “as available,” raising questions as to whether they are committed to respond to an incident. A senior Coast Guard attorney told GAO that such subcontracts are inconsistent with the VRP regulations. However, in its VRP reviews, the Coast Guard does not review subcontracts. Coast Guard officials stated that they are developing guidance for reviewing subcontracts and to clarify that equipment cannot be included on an “as available” basis. These officials also stated that they have the authority to do more to assess VRPs and in April 2018 began collecting incident data and reviewing whether VRPs were followed in each incident. However, this effort does not fully analyze these data to determine whether or how its review processes could be strengthened. By doing so, the Coast Guard could help mitigate identified risks in the processes and provide greater assurance of the efficacy of VRPs for ensuring oil spill or marine firefighting responses.

The Coast Guard’s processes for reviewing requests to use alternative planning criteria (APC) is based on federal regulations and national guidelines, and also largely relies on the professional judgment of field personnel and local guidance and tools to determine whether requests meet regulatory requirements. However, Coast Guard and maritime industry officials cited several challenges, including a lack of clarity about how proposed APC measures designed to prevent incidents are to be evaluated, as well as the impact of its military personnel rotations on the consistency of APC reviews. Under Coast Guard policy, military personnel rotate in and out of locations on a regular basis, and 12 of the 18 non-Coast Guard stakeholders GAO spoke with cited personnel rotation as a key concern given the associated loss of experience and local expertise. In October 2019, the Coast Guard created an advisory group to identify solutions to challenges faced by the VRP Program, including those for APC. However, the Coast Guard did not initiate the advisory group using key program management practices, such as establishing milestones, roles and responsibilities, and the methods for how the group is to carry out its work. By adopting such program management practices, the Coast Guard’s advisory group would be better positioned to successfully address challenges identified in the VRP review and approval process.

GAO recommends that the Coast Guard (1) analyze incident data involving VRPs to identify potential improvements to its VRP review processes, and (2) adopt key program management practices in carrying out its VRP advisory group efforts. The Coast Guard concurred with both recommendations.

Read the GAO report

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The Government Technology & Services Coalition's Homeland Security Today (HSToday) is the premier news and information resource for the homeland security community, dedicated to elevating the discussions and insights that can support a safe and secure nation. A non-profit magazine and media platform, HSToday provides readers with the whole story, placing facts and comments in context to inform debate and drive realistic solutions to some of the nation’s most vexing security challenges.

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