Delivering Legal Services Executing the Mission Delivering Legal Services Executing the Mission Tulane Admiralty Law Institute March 11 – 13, 2015 New.

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Presentation transcript:

Delivering Legal Services Executing the Mission Delivering Legal Services Executing the Mission Tulane Admiralty Law Institute March 11 – 13, 2015 New Orleans, Louisiana

Delivering Legal Services Executing the Mission Government Regulations & Class Society Rules Post-Deepwater Horizon RADM Steven D. Poulin Judge Advocate General U.S. Coast Guard

Delivering Legal Services Executing the MissionBackground Joint Investigation Team Report of Investigation on MODU Deepwater Horizon Joint Investigation Team Report of Investigation on MODU Deepwater Horizon Volume I: U.S. Coast Guard Final Volume I: U.S. Coast Guard Final Action Memo (FAM) Volume II: BOEMRE (now-BSEE) Volume II: BOEMRE (now-BSEE) OCS Area Matrix Team (OCSAMT) OCS Area Matrix Team (OCSAMT) Chartered May 2011 Chartered May 2011 Multi-unit, multidisciplinary team Multi-unit, multidisciplinary team Identify needs in standards, regulations, Identify needs in standards, regulations, policies, and proficiencies policies, and proficiencies 3

Delivering Legal Services Executing the Mission OCSAMT Target Areas Standards Regulations Policies Voluntary Guidelines Competency Enhanced Training Programs Updated Personal Qualification Standards Outreach Active engagement with industry associations and partnerships Close coordination with BSEE and NOSAC Oversight OCS OCMI Increased Resources Risk-Based Targeting

Delivering Legal Services Executing the Mission 5 Standards: Regulatory Projects

Delivering Legal Services Executing the Mission 6 Regulatory Projects (continued)

Delivering Legal Services Executing the Mission 7 Standards: Policies & Guidance Accommodation Service Provided on Vessels Engaged in OCS Activities Accommodation Service Provided on Vessels Engaged in OCS Activities Feb 2012, 77 FR 5039 Feb 2012, 77 FR 5039 Dynamic Positioning (DP) Operations Guidance for non- MODUs on OCS Dynamic Positioning (DP) Operations Guidance for non- MODUs on OCS Oct 2012, 77 FR Oct 2012, 77 FR Lifesaving & Firefighting Equipment and Drills for Offshore Facilities & MODUs Lifesaving & Firefighting Equipment and Drills for Offshore Facilities & MODUs Nov 2012, 77 FR Nov 2012, 77 FR MODU DP Guidance MODU DP Guidance May 2012, 77 FR May 2012, 77 FR MODU Electrical Equipment Certification MODU Electrical Equipment Certification Dec 2012, 77 FR Dec 2012, 77 FR 71607

Delivering Legal Services Executing the Mission 8 Standards: Recent Policies & Alerts Voluntary Reporting of DP Incidents Guidance Voluntary Reporting of DP Incidents Guidance Jun 2013, CG-INV Policy Jun 2013, CG-INV Policy Alternate Design & Equipment Standards for FOIs and FPSO Units Guidance Alternate Design & Equipment Standards for FOIs and FPSO Units Guidance Jun 2013, CG-ENG Policy Jun 2013, CG-ENG Policy Outer Continental Shelf Units—Fire and Explosion Analyses Outer Continental Shelf Units—Fire and Explosion Analyses May 2014, 79 FR May 2014, 79 FR Marine Safety Manual, Vol. II: OCS Section updated Marine Safety Manual, Vol. II: OCS Section updated Marine Safety Alert: DP System Failures Marine Safety Alert: DP System Failures Feb 2015 Feb 2015

Delivering Legal Services Executing the Mission 9 Standards: International Efforts Recognized Organizations Code (RO Code) Recognized Organizations Code (RO Code) Amendments to the Guidelines for vessels with dynamic positioning (DP) systems Amendments to the Guidelines for vessels with dynamic positioning (DP) systems Proposed amendments to the 2009 MODU Code and related instruments in light of the investigation reports of the 2010 DEEPWATER HORIZON incident Proposed amendments to the 2009 MODU Code and related instruments in light of the investigation reports of the 2010 DEEPWATER HORIZON incident Review of the adequacy of the 2009 MODU Code, the Life- Saving Appliance (LSA) Code, and Measures to prevent accidents with lifeboats in light of the investigations of the 2010 "Deepwater Horizon" incident Review of the adequacy of the 2009 MODU Code, the Life- Saving Appliance (LSA) Code, and Measures to prevent accidents with lifeboats in light of the investigations of the 2010 "Deepwater Horizon" incident

Delivering Legal Services Executing the Mission Enhanced Personnel Qualification Standards Enhanced Personnel Qualification Standards OSV PQS OSV PQS Foreign MODU PQS Foreign MODU PQS OCS Inspector Course OCS Inspector Course Intensive focus on core qualifications, including instruction on drilling, well control, DP and cranes Intensive focus on core qualifications, including instruction on drilling, well control, DP and cranes Review CG authorities, applicable regulations, deficiency documentation, and issuance of certificates Review CG authorities, applicable regulations, deficiency documentation, and issuance of certificates Future course: July 2015 Future course: July Competencies on Prevention

Delivering Legal Services Executing the Mission Competencies for Pollution Response Instituted formal USCG training for Federal On Scene Coordinator-Representatives (FOSC-R) Instituted formal USCG training for Federal On Scene Coordinator-Representatives (FOSC-R) Emphasis on smaller spills and building strong baseline knowledge Emphasis on smaller spills and building strong baseline knowledge Created a deployable Incident Management Assistance Team (IMAT) Created a deployable Incident Management Assistance Team (IMAT) Highly-specialized USCG personnel to provide ICS support Highly-specialized USCG personnel to provide ICS support Established permanent Regional Response Team (RRT) Co-chairs Established permanent Regional Response Team (RRT) Co-chairs 11

Delivering Legal Services Executing the Mission Bureau of Safety and Environmental Enforcement (BSEE) Bureau of Safety and Environmental Enforcement (BSEE) USCG-BSEE Prevention Working Group USCG-BSEE Prevention Working Group Updated USCG-BSEE Memorandum of Understanding (MOU), signed 27 November 2012 Updated USCG-BSEE Memorandum of Understanding (MOU), signed 27 November 2012 Also updating eight existing MOUs, and developing new MOUs Also updating eight existing MOUs, and developing new MOUs Industry Partners Industry Partners Presence at Offshore Technology Conference (OTC) Presence at Offshore Technology Conference (OTC) Active engagement with advisory committees (NOSAC) Active engagement with advisory committees (NOSAC) Partnerships to improve training Partnerships to improve training 12 Outreach on Prevention

Delivering Legal Services Executing the Mission Outreach on Response Interagency Coordinating Committee on Oil Pollution Research (ICCOPR) Interagency Coordinating Committee on Oil Pollution Research (ICCOPR) Focus on pollution response research and development Focus on pollution response research and development Spill of National Significance/National Incident Commander policy Spill of National Significance/National Incident Commander policy Policy includes fortification through interagency partnerships Policy includes fortification through interagency partnerships USCG Incident Specific Preparedness Review USCG Incident Specific Preparedness Review 13

Delivering Legal Services Executing the Mission OCS OCMI OCS OCMI “One Shelf, One Standard” “One Shelf, One Standard” Resource Proposals Resource Proposals Increased funding for regulatory and policy development Increased funding for regulatory and policy development Increased funding to enhance inspections Increased funding to enhance inspections Risk-based oversight program for MODUs Risk-based oversight program for MODUs Policy Letter 11-06, Jul 2011, 76 FR Policy Letter 11-06, Jul 2011, 76 FR Oversight

Delivering Legal Services Executing the Mission Area Contingency Plan Revisions Result of lessons learned with dispersants Result of lessons learned with dispersants Endangered Species Act (ESA) national-level workgroup on approaches to ACP consultation Endangered Species Act (ESA) national-level workgroup on approaches to ACP consultation Future policy development on ESA Section 7 and other laws Future policy development on ESA Section 7 and other laws Central clearing house for Biological Assessment inputs and examples Central clearing house for Biological Assessment inputs and examples 15

Delivering Legal Services Executing the Mission 16 Questions?