The natural outgrowth of the Contingency Planning process is the strategic implementation of those plans into a logical, universally known and accepted response organizational structure. Cleanup management, under the FOSC direction, is done through the use of a unified command structure which includes the FOSC, the State (or States) OSC and the cleanup manager for the spiller, or responsible party. This triad will determine the strategy for the response. In the unlikely event that agreement is not reached, however, the FOSC has the legal mandate to resolve the issue in contention with his determination as to the best resolution of the probelm.
This Incident Command System (ICS), under the triad described, is further broken down into 4 main sections. These are Planning, Logistics, Operations and Finance. Staffing of these are jointly shared and pre-determed in the response planning process. All potential response management areas of concern are coordinated through this system. Often neglected areas in previous planning methodologies are now covered (I.E. Volunteer coordination and training, dignitary visits, protocol, media relations, etc.). It is extremely flexible internally, it can grow or shrink to meet the specific demands and size requirement of an incident. We intend to implement it soon for use in our responses to what we currently refer to as incidents of national significance. This will expand the concept beyond our traditional utilization in oil pollution response to other areas of incident response.
Concurrent with the aforementioned planning, preparedness and exercising process the FOSC is supported by all of the other government agencies. This is a requirement of the NCP and it allows the FOSC to enlist the aid and special capabilities of these agencies in battling a spill. Included among these agencies is the Department of Defense which opens up a vast array of manpower and logistics support for a FOSC.
The National Response Team (NRT) and the more geographically oriented Regional Response Teams (RRT) are comprised of day members of each these federal agencies and include state representatives at the RRT level. These individuals are at the ready to assist the FOSC in expediting the resoltion of what might ordinarily be bureaucratic nightmares. These teams also are instrumental in working towards the resolution of final pre-approval agreements for different response methodologies like dispersant application and in-situ burn.
OPA 90 has required the potential spillers to be responsible and prepared to mount their own response to a pollution incident. Should the spill source be a tank ship or tank barge, the operator must have pre-existing contract with a designated oil spill removal organization (OSRO) to cleanup a "worst case discharge". Simply put, this would be a loss of the entire cargo under adverse weather conditions. Each of these vessels is now required to demonstrate financial responsibility to respond to a pollution incident. They must have approved vessel response plans which are, in effect, a vessel specific contingency plan for pollution response. The planning, coordination and conduct of the many and varied exercises required by OPA 90 have produced a response environment which is prepared for all contingencies. The combination of a joint public and private response effort, under the direction of a single federal official, the Federal On Scene Coordinator, in accordance with an agreed upon contingency plan are the pillars of our extremely successful U.S. model.
In addition to the advances made in planning, preparedness and spill management techniques we remain actively engaged in considering, evaluating and adding alternate spill response technology to our cleanup capabilities. While we insist on a privately funded and staffed response, it behooves us to remain current in our capability to provide the best response and, if necessary, best first response capability we can if private resources are either time or resource constrained in the early hours of a response.
With the exceptional professional development and increased response capabilities of our OSROS We find a diminishing need for traditional response capabilities (I.E. boom and skimmers) in the Coast Guard ready response arsenal. We are expanding our horizons to address the areas of dispersant application and in-situ burn methodologies as areas of expertise and response that are rapidly developing but are not yet universally available.
The mid 1990s have seen a tremendous increase in the number of memorandums of understanding for the pre-approval of dispersant application. Had agreements such as these been in place during previous major responses it would have eliminated significant contentious discussions and allowed for expeditious implementation of this time critical mitigation tool. We have worked aggressively with our Regional Response Teams and Area to obtain these pre-approvals and in the majority of cases we have successfully obtained either pre-approval or accelerated approval procedures by the applicable government authorities and/or resource trustees. This
