seventh district international offshore drilling …

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SEVENTH DISTRICT

INTERNATIONAL OFFSHORE DRILLING RESPONSE PLAN (IODRP)

TAB D TO APPENDIX 24 TO ANNEX C TO CCGDSEVEN OPLAN 9770-09

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COMMANDER SEVENTH COAST GUARD DISTRICT 909 S. E. FIRST AVENUE MIAMI, FL 33131-3050 06 Mar 2012 TAB D TO APPENDIX 24 TO ANNEX C TO CCGDSEVEN OPLAN 9770-09 (U) INTERNATIONAL OFFSHORE DRILLING RESPONSE PLAN (IODRP) (U) References: (a) National Oil and Hazardous Substances Contingency Plan (NCP) (40 CFR 300) (b) The National Response Framework (NRF) (c) Spills of National Significance Response Management System, COMDTINST 16465.1 (series) (d) Caribbean Island Oil Pollution Response and Cooperation (OPRC) Plan (e) Area Contingency Plan Organization, Content, Revision Cycle and Distribution, COMDTINST 16471.3 (series) (f) Memorandum on Area Contingency Plan Development (g) Federal Water Pollution Control Act, 33 USC 1321 (h) District 7 Marine Safety, Security and Environmental Protection Guidance (i) Coast Guard Incident Management Handbook (IMH), COMDTPUB 3120.17 (series) (j) Seventh District Incident Management Team (IMT), CGD SEVENINST 1601.1 (series) (k) Technical Operating Procedures for Resource Documentation, NPFC Instruction 16451.2 (series) (l) Atlantic Area Critical Information Requirements, LANTAREAINST 16125.1 (series) (m) Atlantic Area Marine Safety Incident Reporting Policy, LANTAREAINST 16451.1 (series) (n) Marine Transportation System Recovery, LANTAREAINST 16001.1 (series) (o) Deputy Commandant for Mission Support (DCMS) Atlantic Area Standard Operating Procedures (SOP) (p) DCMS Contingency Support Plan 9730 (series) (q) Coast Guard Standard After Action Information and Lessons Learned System (CG-SAILS), COMDTINST 3010.19 (series) (r) Marine Safety Manual, COMDTINST M16000 (series) (s) Commander, Atlantic Area SOP (t) Seventh District International Oil Spill Quick Response Sheet

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(u) Memorandum of Understanding (MOU) between the USCG, EPA and the Corporation for National and Community Service (CNCS) (v) CPB/USCG Joint Protocols for the Expeditious Recovery of Trade 1. (U) Situation. The Deepwater Horizon (DWH) incident has resulted in a significant number of lessons learned and elevated concerns regarding offshore drilling operations and the United States’ capabilities to respond to and mitigate the potential impacts from a Worst Case Discharge (WCD) in the offshore environment as envisioned in the National Contingency Plan (NCP). In addition, a number of neighboring countries have, or will shortly, initiate plans to conduct drilling operations that due to their close proximity to the United States coastline, will likely present an environmental threat to the United States Exclusive Economic Zone (EEZ), Territorial Seas, Coastal and Inland waterways and shorelines. The impacts from a WCD scenario in one of these neighboring country’s territorial seas would likely result in a Spill of National Significance (SONS) and would impact multiple Captain of the Port (COTP) zones within the Seventh District Area of Responsibility (AOR) during the course of the incident and resulting response operations.

a. (U) General. This International Offshore Drilling Response Plan (IODRP) primarily addresses the conduct of offshore operations in response to a WCD originating from an offshore source. This plan incorporates lessons learned from the DWH incident (DWH Lessons Learned Report, DWH Federal On-Scene Coordinator (FOSC) Report and the DWH Incident Specific Preparedness Review (ISPR)), as well as the SONS 2010 exercise After Action Report (AAR). This plan is in compliance with the requirements detailed in the NCP and the tenants of the National Response Framework (NRF). It is complementary to the associated Regional Contingency Plans and Area Contingency Plans (ACPs) that are in effect in the Seventh District AOR. This plan anticipates the need for close communication and coordination with the Regional Response Team (RRT) regarding response related issues as well as operational coordination between the offshore response organization and those stood up by each impacted Sector under their existing ACPs. This plan details the anticipated initial response organization and that it will need to evolve in a logical and structured manner to ensure it matches the needs of the incident. The response organization for a spill response under this plan also anticipates the possibility of the incident being declared a SONS and the designation of a


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National Incident Commander (NIC) and the associated SONS response organization as detailed in reference (c). b. (U) Area of Concern. The potentially impacted areas addressed by this plan include state waters along the coast, areas seaward of the shoreline to the outer edge of the US EEZ, and international waters adjacent to the EEZ. c. (U) Incident. The primary threat addressed by this plan is the risk of a significant oil spill resulting from an anticipated increase in the exploration activities for offshore oil and gas resources in the territorial seas of other nations adjacent to the United States. Trajectory modeling has indicated that a spill originating from these locations has the potential to impact US waters and shoreline areas depending on the amount and duration of the spill. If a WCD were released from a number of these sites the trajectory modeling suggests that the oil could reach US waters within 2-3 days and have potential shoreline impacts within 5-7 days. The windows of opportunity to disperse, burn and mechanically recovery the spilled product will depend on the specifics of the oil spilled and the environmental conditions at the time of the spill. Immediately following a spill the general windows of opportunity for the various response techniques will be determined to help in establishing response priorities. In addition to the issues associated with oil spill impacts in the marine and coastal environment, a WCD magnitude spill could disrupt maritime traffic through the impacted region causing Marine Transportation System (MTS) disruptions for the US and its trading partners. d. (U) Plan Implementation. For Marine Environmental incidents in US waters, Title 33 USC 1321 reference (a) requires the person in charge of a vessel, or an onshore or offshore facility to notify the appropriate agency of the U.S. Government of a discharge of oil or release of a Hazardous Material. For discharges originating outside of US jurisdiction, the Caribbean Island Oil Pollution Response and Cooperation (OPRC) Plan reference (d) details the reporting requirements in Chapter 4 – Dissemination of Information on Oil Spill Incidents. The Cartagena Convention, or Convention for the Protection and Development of the Marine Environment in the Wider Caribbean Region (WCR) also provides a legal framework for cooperative regional and national actions in the WCR.


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e. (U) Pre-Incident Preparations. Pre-incident preparations are outlined in the National Preparedness for Response Exercise Program (PREP), Sector Area Contingency Plans and Area Maritime Security Plans, the Region IV and the Caribbean Regional Contingency Plans, and local or regional Memorandums of Understanding or Agreements. In addition to those preparations an incident of this nature will require the following pre-incident preparations.

(1) (U) ACP and IODRP Coordination. All potentially impacted Sectors shall maintain an ACP in accordance with 40 CFR Part 300.210 (c), references (e) and (f). The Sector ACPs shall acknowledge the linkage between this plan and their ACP and ensure their respective stakeholder agencies are aware of coordination mechanisms between the plans. The anticipated division of responsibilities between this plan, the Sector ACP and any industry response plans is depicted in Exhibit 1. Specific areas that will require close coordination between the Offshore Operations organization and the Sector level response organizations include the following:

(a) (U) Vessel Decontamination. Decontamination of vessels that are either impacted by or engaged in response to, the incident will require close coordination. The establishment of vessel decontamination sites and the development of a regional approach to vessel decontamination plans will ensure a coordinated effort that meets all stakeholder requirements. Each Sector level vessel decontamination plan, as well as the regional vessel decontamination plan should be reviewed to ensure they can support anticipated vessel decontamination requirements associated with the offshore response organization. (b) (U) Waste Management. The offshore response operations envisioned under this plan will generate a waste stream which might not be anticipated under current Sector level waste management plans. Prior to an incident, each Sector should review their current waste management plans to ensure that adequate capacity exists to deal with anticipated offshore response waste streams that might be generated during a WCD in their Sector AOR.


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(c) (U) Identification of Vessels of Opportunity (VOO). VOO craft have been a valuable resource in a number of large scale oil spill response operations. They have been used effectively to provide Vessel of Opportunity Skimming System (VOSS) platforms, towing craft for in-situ burn operations, and platforms for other response related activities. It is important to identify potential VOO craft in advance in order to establish the makeup of the potential VOO fleet and work with the vessel owner/operator on any pre-incident preparations that can be accomplished. VOO craft supporting Sector response operations and IODRP offshore response operations will likely be sourced from the nearest Sector AOR. To ensure viable and adequate fleets of VOO craft are available, each Sector should solicit for vessels to serve in the VOO fleet and maintain an active list of vessels that can be activated to support response operations. (d) (U) Volunteer Management. The District will work with the Corporation for National and Community Service (CNCS)to pre-identify potential volunteer opportunities/activities and determine anticipated volunteer staffing needs to fill those needs.

(2) (U) RCP and IODRP Coordination. The RCP contains an International Annex (Annex I) which describes the roles and responsibilities of RRT Region IV members as well as a section describing the general pattern of the response. The Regional Response Team (RRT) Regional Vessel Decontamination Plan will also be addressed as part of the RCP and coordinated closely with the incident specific RRT. (3) (U) Exercises. To ensure the viability of this plan it should be fully exercised initially and then become part of an established exercise program.

(a) (U) Initiating Exercise(s). Because this is essentially a new plan which creates additional coordination issues, it should be exercised to ensure all stakeholder agencies are aware of the plan and have been afforded the opportunity to provide input. (b) (U) National Preparedness for Response Exercise Program (PREP). This plan shall be exercised regularly as part of the PREP exercise cycle. PREP


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Tabletop, Functional and Full-Scale exercises provide an opportunity for the District FOSC to exercise this plan to ensure all agencies tasked to support response operations are fully aware and capable of performing their assigned tasks.

(4) (U) Requests for Assistance (RFA) and Requests for Forces (RFF). In order to ensure a rapid and effective response operation a pre-scripted RFA (DOD assets) and RFF will be developed anticipating the types of personnel and equipment resources that will be needed to immediately engage in response operations. (5) (U) Staffing and Training. Identifying staff, and their reliefs, to fill positions in the initial response organization(s) will be accomplished using the District Watch, Quarter and Station Bill (WQSB). The WQSB will also identify any specific qualifications and or training requirements that might be desired and/or required to fill specific positions within the response organization(s). (6) (U) Pre-Incident Logistics Support. Pre-incident logistics support is critical to ensuring the success of this plan. There are a number of logistical arrangements that can be established prior to the incident which will ensure an effective and orderly process is in place to get the initial response resources on scene and working as quickly as practicable. Pre-incident logistical support is detailed in the Logistics Support enclosure, enclosure (3) to this plan.

f. (U) Support From Other Agencies. Subpart 300.175 of reference (a) lists the federal agencies which may be called upon for assistance with pollution response and describes their capabilities. The following agencies play a major role in oil spill response operations under this plan. See Annex V – Interagency Coordination.

(1) (U) Federal. The following federal agencies may be tasked under the NCP to support operations under this plan.

(a) (U) U. S. COAST GUARD (USCG). The USCG provides the National Response Team (NRT) vice-chair, co-chairs the RRTs, and serves as pre-designated FOSC for the coastal zone, as described in 40 CFR 300.120 (a) (1) of the NCP. The USCG is tasked with responding to all


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oil and hazardous substance releases into, or that threaten to go into, navigable waters within the coastal zone, including the Exclusive Economic Zone (EEZ) of the United States. Additionally, the USCG offers expertise in domestic and international fields of port safety and security, maritime law enforcement, ship navigation and construction, and the manning, operation, and safety of vessels and marine facilities. For the purposes of this plan, the USCG will provide: the National Incident Commander (NIC); Incident Commanders (IC) assigned to a Unified Area Command (UAC) or a Unified Command (UC); and associated response personnel. In addition, Coast Guard special teams include the District Response Group (DRG), Maritime Safety & Security Teams (MSSTs), National Strike Force (NSF) which includes the Atlantic, Gulf, and Pacific Strike Teams, Public Information Assist Team (PIAT), and National Strike Force Coordination Center (NSFCC). (b) (U) ENVIRONMENTAL PROTECTION AGENCY (EPA). The EPA provides the NRT vice chair, co-chairs the RRTS with the USCG, and serves as pre-designated FOSC for the inland zone, as described in 40 CFR 300.120(a)(1) of the NCP. EPA provides expertise on environmental effects of oil discharges or releases of hazardous substances, pollutants, or contaminants, and environmental pollution control techniques. (c) (U) DEPARTMENT OF DEFENSE (DOD). The DOD plans and handles all spills and releases from any facility or vessel under DOD control. In addition, DOD may also, upon request of the FOSC, provide locally deployed U.S. Navy oil spill equipment and provide assistance to the FOSC. The following DOD components have particularly relevant expertise.

1 (U) NORTHERN COMMAND (NORTHCOM). NORTHCOM conducts homeland defense, civil support and security cooperation to defend and secure the United States and its interests. Their AOR includes air, land and sea approaches and encompasses the continental United States, Alaska, Canada, Mexico and the surrounding water out to approximately 500 nautical miles. It also includes the Gulf of Mexico, the Straits of Florida, and portions of the Caribbean region to


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include The Bahamas, Puerto Rico, and the U.S. Virgin Islands. The command provides assistance to a Primary Agency when tasked by DOD. An emergency must exceed the capabilities of local, state and federal agencies before NORTHCOM becomes involved. In most cases, support will be limited, localized and specific. When the scope of the disaster is reduced to the point that the Primary Agency can again assume full control and management without military assistance, NORTHCOM assets will be demobilized. 2 (U) U. S. NAVY SUPERVISOR OF SALVAGE (SUPSALV). SUPSALV has an extensive array of specialized equipment and personnel available for use in these areas, as well as specialized containment, collection, and removal equipment specifically designed for salvage-related and open sea pollution incidents. SUPSALV also has a separate MOA with the Coast Guard to provide support outside of the established Defense Support for Civil Authorities mechanism. This MOA provides the USCG direct access to SUPSALV assets without going through a Defense Coordinating Officer (DCO). 3 (U) U. S. ARMY CORPS OF ENGINEERS (USACE). The USACE has specialized equipment and personnel for maintaining navigation channels, removing navigation obstructions, accomplishing structural repairs, and performing maintenance to hydropower electric generating equipment.

(d) (U) DEPARTMENT OF COMMERCE (DOC). The DOC would have several entities engaged with the response organization including:

1 (U) National Oceanographic and Atmospheric Administration (NOAA). NOAA has jurisdiction over and provides scientific support for response and contingency planning in coastal and marine areas, including assessment of hazards that may be involved, predictions of movement and dispersion of oil and hazardous substances through trajectory modeling, and information on the sensitivity of coastal environments to oil and hazardous substances. NOAA provides


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expertise on and has jurisdiction over living marine resources and their habitats, including endangered species. NOAA also provides information on actual and predicted meteorological, hydrological, and oceanographic conditions for marine, coastal, and inland waters. NOAA is a Federal trustee for living and non-living natural resources in coastal and marine areas. 2 (U) BUREAU OF INDUSTRY AND SECURITY (BIS). BIS involvement would be likely if the spill originated outside United States waters and United States companies needed to obtain a Commerce Export License. BIS controls extend to United States and foreign parties that would send items subject to BIS regulations to any country when BIS authorization is required.

(e) (U) DEPARTMENT OF THE INTERIOR (DOI). The DOI has expertise on, and jurisdiction over, a variety of natural resources, federal lands, federal waters, certain aspects related to Native American lands, and certain jurisdictions related to United States territories. The following bureaus and offices have relevant expertise as listed.

1 (U) FISH AND WILDLIFE SERVICE (FWS). The FWS manages habitat/fisheries for certain fish and wildlife, including endangered and threatened species; migratory birds; and certain marine mammals. They also manage waters and wetlands, monitor contaminants affecting habitat resources and specialized laboratory research facilities. 2 (U) BUREAU OF SAFETY AND ENVIRONMENTAL ENFORCEMENT (BSEE). BSEE enforces safety and environmental regulations. Their functions include permitting and research, inspections, offshore regulatory programs, oil spill response, and training and environmental compliance functions.

(f) (U) DEPARTMENT OF JUSTICE (DOJ). The DOJ can provide expert advice on complicated legal questions arising from discharges or releases and federal agency responses. In addition, DOJ represents the federal


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government in litigation relating to such discharges or releases. (g) (U) DEPARTMENT OF LABOR (DOL). The DOL through the Occupational Safety and Health Administration (OSHA) has authority to conduct safety and health inspections of hazardous waste sites to assure that employees are being protected and to determine if the site is in compliance with OSHA regulations. OSHA regulations related to spill response can be found in Title 29 CFR 1910.120 (Hazardous Waste Operations and Emergency Response (HAZWOPER) regulations). (h) (U) DEPARTMENT OF TRANSPORTATION (DOT). The DOT provides response expertise pertaining to transportation of oil, or hazardous substances, by all modes of transportation. Through the Research and Special Programs Administration (RSPA), DOT offers expertise in the requirements for packaging, handling, and transporting regulated hazardous materials. (i) (U) DEPARTMENT OF STATE (DOS). The DOS leads in development of international joint contingency plans. DOS will also help to coordinate an international response when discharges or releases cross international boundaries or involve foreign flag vessels. Additionally, DOS will coordinate requests for assistance from foreign governments and proposals from the United States for conducting research at incidents that occur in waters of other countries. DOS is also involved in the licensing of US companies to engage in business outside of the United States. (j) (U) DEPARTMENT OF THE TREASURY. Treasury has a role through its Office of Foreign Assets Control (OFAC). OFAC administers and enforces economic and trade sanctions based on United States foreign policy and national security goals against targeted foreign countries and regimes, terrorists, international narcotics traffickers, those engaged in activities related to the proliferation of weapons of mass destruction, and other threats to the national security, foreign policy or economy of the United States. OFAC acts under Presidential national emergency powers, as well as authority granted by specific legislation, to impose controls on transactions and freeze assets under United States


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jurisdiction. Many of the sanctions are based on United Nations and other international mandates, are multilateral in scope, and involve close cooperation with allied governments. (k) (U) GENERAL SERVICES ADMINISTRATION (GSA). GSA plays an essential role in providing facility and related logistical support for the response organization. In support of the IODRP Organization, GSA will be primarily engaged to locate and activate appropriate Incident Command Post (ICP) space to support the National Incident Command, Unified Area Command and the Unified Command.

(2) (U) State and Local Agencies. These include, but are not limited to, state environmental protection agencies, local emergency managers, and fire and health departments). The primary linkage to state, local, and tribal agencies will be through the existing ACPs. (3) (U) Multi-Agency Committees.

(a) (U) Emergency Support Function Leaders Group (ESFLG). The ESFLG is the principal body that addresses Federal response planning and implementation at the working level. It handles formulation and resolution of operational issues that require interagency resolution. This group would likely convene if the incident were designated a SONS and there were significant coordination needed where elements of the NRF were activated to support the response. (b) (U) National Response Team (NRT). The NRT is a multi-agency body that has authority under 40 CFR 300.110 of reference (a) for national oil spill and hazardous substance release strategic planning and coordination. The Environmental Protection Agency (EPA) chairs the NRT and the Coast Guard serves as vice-chair. During periods of activation for a coastal zone spill, including a SONS, the Coast Guard chairs an incident-specific NRT. (c) (U) NRT Incident-Specific Work Group (IWG). The IWG serves as an incident specific workgroup for the NRT to coordinate the “whole of government” policy and procedural recommendations for the NIC, UAC, and


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applicable UCs. The IWG coordinates between Federal agencies to de-conflict competing organizational goals, mandates, and statutory requirements so that the NIC and UAC(s) can speak with one voice. (d) (U) Regional Response Team (RRT). RRT membership parallels the NRT but also includes state and local representation. A regional EPA representative and Coast Guard District co-chair RRT Region IV and the Caribbean RRT. This team is available to the FOSC for supporting response efforts. Subpart 300.115 of reference (a) describes the role of the RRT in a typical response. During a SONS, the FOSC may request that incident-specific RRTs convene as an “incident specific team” per the NCP to include representatives from affected States. The FOSC should seek the assistance and counsel of the incident-specific RRT based on the operational requirements of the SONS, and may include requests for approval of the use of alternative countermeasures, assistance with policy determinations, and support in acquiring interagency resources. (e) (U) Area Committees (AC). ACs in the coastal zone are chaired by the cognizant FOSC and comprised of federal, state, and local agencies that assist the FOSC with response planning. The AC roles are described in the applicable ACPs.

(4) (U) Responsible Party (RP). The RP has the primary liability for responding to a pollution incident within United States waters as noted in the Federal Water Pollution Control Act. The RP's cleanup activities will be monitored and may be directed by the FOSC to ensure the response is conducted in accordance with the NCP. While taking responsible actions, the RP, or his/her representatives, will work alongside other responders and will be included in the response organization. In carrying out the response, the RP will either use his/her own equipment, hire an Oil Spill Removal Organization (OSRO), and/or use federal assets on a reimbursable basis. (5) (U) Responsible Entity. Responsible Entity refers to the owner or operator of an offshore facility or vessel that spills oil outside of United States waters and cannot legally be declared a RP under the NCP. The Responsible Entity’s cleanup activities will be monitored but cannot


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be directed by the FOSC. This plan anticipates close coordination between the Responsible Entity and the FOSC to ensure the status of source control and/or salvage operations is clearly communicated to assist the FOSC in planning response operations in or adjacent to United States waters. (6) (U) Cleanup Contractors/Oil Spill Removal Organizations (OSRO). OSROs may be hired by federal, state, local agencies, the responsible party, or the Coast Guard to cleanup a spill and recover the pollutant. The Shore Infrastructure Logistics Center (SILC) maintains contracts, called Basic Ordering Agreements (BOA), with pre-approved ORSOs for spill response. A BOA can only be activated by the FOSC or designated Deputy FOSC’s. SILC maintains a current listing of active BOAs at http://www.uscg.mil/SILC/emergency.asp.

g. (U) Assumptions. See Basic Plan – Assumptions. There are a number of assumptions that are necessary in order to plan for a response operation of this type and magnitude. The critical assumptions for this plan include the following:

(1) (U) The United States will receive timely notification of any incident that may impact United States waters. (2) (U) There will be adequate funding in the Oil Spill Liability Trust Fund (OSLTF) to sustain response operations for the duration of the effort even if a viable Responsible Party is not involved to cover the majority of the response costs. (3) (U) The United States will receive cooperation from the country where the spill originates regarding the details of the incident in order to properly plan/conduct response operations in United States waters. (4) (U) Responders will have to manage increased expectations and political pressures from the local elected officials.

h. (U) Definitions. See the Glossary for definitions applicable to pollution response that may be found in various laws and regulations. i. (U) Legal Considerations.


http://www.uscg.mil/SILC/emergency.asp

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(1) (U) Designation of FOSC. When several Sectors are impacted, the District Commander, or the Area Commander, may designate a more senior Coast Guard official to serve as FOSC regardless of whether a SONS is declared. In this case, commanders of impacted sectors and the commander of the Offshore Operations response organization shall be designated as Incident Commanders (ICs), in accordance with reference (a), and be delegated by the FOSC to direct and coordinate response activity in their areas of responsibility in support of the designated FOSC. The ICs shall be delegated authority by the FOSC in writing to direct and coordinate removal actions in his or her operational area, and should be given specifically delineated authority for spending, use of alternative countermeasures, and critical resource ordering. (2) (U) NCP versus the NRF. The response structures used in response to a Stafford Act incident may not be applicable during Non-Stafford Act Federal responses coordinated by the Secretary of Homeland Security. For incidents in which a Stafford Act declaration is not made, the department or agency with primary legal jurisdiction will activate the response structures appropriate to their authorities; these structures are organized around the concepts and principles established in the National Incident Management System (NIMS) which serves as the basis of the NRF. The Secretary of the Department of Homeland Security will coordinate with the head of the department or agency with primary legal jurisdiction, but retains the authority to activate the additional response structures the Secretary determines appropriate. The NCP is for pollution incidents that are not declared Stafford Act Disasters or Emergencies. That does not, however, preclude the NCP from being used in conjunction with the NRF. The typical funding stream for NCP oil pollution incidents is the OSLTF. If NRF elements are activated to support the incident there is a possibility that some of those activities that cannot be funded under the OSLTF may be funded under the Stafford Act.

2. (U) Mission. The designated commands shall develop and implement an effective response organization made up of Federal, State, Local, Tribal and Responsible Party (if applicable) stakeholders. The response organization shall make use of the best available oil spill response technologies to prosecute an offshore oil spill as far from the shore of the United States as possible. In addition, the response organization shall marshal


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and deploy assets to ensure the oil is managed/removed as far offshore as possible to protect US interests (economic, environmental, political, societal), and aggressively employ all pre-approved alternate response technologies while concurrently seeking approval for any viable technologies that are not pre-approved. 3. (U) Execution. In response to a potential SONS incident from a source outside of United States waters, the FOSC will establish the appropriate response organization(s) consisting of a FOSC, State On-Scene Coordinator (SOSC), the RP incident manager (if legally applicable) and any other entity that the FOSC deems necessary to facilitate response operations. In order to effectively respond to an incident of this nature, the overall response organization will likely include a National Incident Commander (NIC) function, a Unified Area Command (UAC) at the District level and a Unified Command (UC) at both the District and Sector levels to manage the actual operational response.

a. (U) Concept of Operations. See Basic Plan – Concept of Operations.

(1) (U) Commander’s Intent. See Basic Plan – Commander’s Intent. To ensure that any spill that threatens United States waters is prosecuted by a comprehensive response organization that has the necessary resources to accomplish the mission described in Section 2. In order to provide critical direction to the response organization, a set of initial response objectives have been established that are applicable to all types of oil spill response operations. The initial set of response objectives listed below will be modified and reworked with additional detail by the Unified Area/Incident Commanders to tune them to the actual incident during the initial operational periods.

(a) (U) Ensure the safety of citizens and response personnel. (b) (U) Control the source of the spill. (c) (U) Manage a coordinated response effort. (d) (U) Maximize protection of environmentally sensitive areas.


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(e) (U) Contain and recover spilled material. (f) (U) Recover and rehabilitate injured wildlife. (g) (U) Remove oil from impacted areas. (h) (U) Minimize economic impacts. (i) (U) Keep stakeholders informed of response activities. (j) (U) Keep the public informed of response activities. (k) (U) Develop and implement a comprehensive incident documentation plan.

(2) (U) General. Upon notification and confirmation of a major offshore spill, the District Commander will make a determination regarding the implementation of this plan. The most likely sequence of events would involve the deployment of Sector, District and then Area/HQ CG assets. The evolution of the full response organization is described in 3 phases and depicted in Exhibit 2. (3) (U) Employment.

(a) (U) Initial Response Activities. Initial response activities will be guided by the Execution Checklist, enclosure (1) and the Executive Checklist, Enclosure (2).

1 (U) Phase 1 – Initial Sector Response. The Sector with an AOR closest to the incident will initiate response operations based on the specifics of the reported incident. The initial CG activities will include activation of the appropriate ACP as well as other CG operational activities which may include Search & Rescue and/or other CG missions. Ongoing CG operations in the Sector AOR will be assessed to determine which operations may be impacted by the incident. Assets engaged in CG missions may be re-tasked to support incident response operations. When the type of incident dictates, the Sector will stand up their Unified Command.


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2 (U) Phase 2 – District/Sector Response. Once a decision to activate this plan is made, the initial elements of the Offshore Operations UC response organization will be activated and make preparations to begin operations. This phase could also include several more elements of the response organization standing up concurrently as other adjacent Sectors activate UC organizations and the UAC at the District is activated. 3 (U) Phase 3 – SONS Declaration. In accordance with reference (a), a Coast Guard Area or District Commander may recommend to the Commandant, that a SONS be declared. The Commandant alone is empowered to declare a SONS in the coastal zone. Once the Commandant declares a SONS within the Atlantic Area AOR and designates COMLANTAREA, or another individual as the National Incident Commander (NIC), the Federal On-Scene Coordinator covered by the NIC will be notified. 4 (U) Tab A to Appendix 43 to Annex P of reference (h) contains the location and inventory of the District’s pre-positioned pollution response equipment. 5 (U) During a pollution incident, assets may, under the direction of the responsible FOSC, be employed to:

a (U) Transport pollution response equipment to and from the scene. b (U) Deploy, operate, and recover pollution response equipment. c (U) Provide administrative and logistic support. d (U) Survey the area of the incident. e (U) Monitor and/or direct the activities of the responsible party or contractors.


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6 (U) Deployable teams may be tasked to provide assistance during an incident. Teams that may be activated include:

a (U) LANTAREA/PACAREA Incident Management Assist Teams (IMATs). IMATs can provide incident management service and can staff specified ICS positions. b (U) National Strike Force Elements.

(1) (U) Gulf Strike Team (GST). The GST provides technical expertise on oil spill response and will coordinate assistance from other strike teams. (2) (U) Public Information Assist Team (PIAT). The PIAT provides public affairs support. (3) (U) Marine Environmental Response Asset Line Field Office (MALFO). MALFO provides assistance with the use/maintenance of the prepositioned Vessel of Opportunity Skimming System (VOSS) and the Spilled Oil Recovery System (SORS) equipment deployment on buoy tenders.

c (U) Marine Safety and Security Teams (MSST). MSSTs can be used to provide waterside security and to resource daily Coast Guard mission sets if other assets are deployed to the incident.

7 (U) Volunteer Management. The focus of this plan is operations in the offshore environment which could potentially limit the use of volunteers to support this plan. If volunteers come forward, the first approach will be to direct them to the appropriate Sector Volunteer Coordinator for employment at the Sector level. If legitimate needs are identified that can be filled by volunteer forces the Offshore UC Planning Section Chief will develop a plan to train, equip and utilize those assets. The Offshore UC volunteer management plan will ensure the Coast Guard is in compliance with the MOA between the Coast Guard and the Corporation for


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National and Community Service (CNCS) included as reference (u).

(4) (U) Deployment. See Basic Plan – Deployment. (5) (U) Demobilization. Demobilization planning for a large scale response operation needs to begin almost immediately. The demobilization process includes the following:

(a) (U) All unit leaders in Planning, Logistics and Finance/Administration identify any surplus resources at least 24 hours in advance of their anticipated demobilization time. The Resources Unit Leader will work with the Operations Section Chief to identify operational resources. (b) (U) Surplus resources that have been identified for each Section should be given to the Section Chief who will then forward the tentative list of surplus resources to the Planning Section Demobilization Unit. (c) (U) The Demobilization Unit will compile a tentative release list of surplus resources from all Sections and send them to the Incident Commander/Unified Command via the Planning Section Chief. (d) (U) Incident Commander/Unified Command approves the list of resources to be demobilized. (e) (U) Approved demobilization list is sent to the Resources Unit and to the appropriate Section Chiefs. (f) (U) Section Chiefs notify the resources under their control that they have been approved for demobilization and the procedures to follow. (g) (U) Demobilization Unit ensures that the check-out process is followed. (h) (U) Demobilization Unit sends completed Demobilization Check-out Forms (ICS-221-CG) to the Documentation Unit for the historical record. (i) (U) For major incidents it is common to hold a Demobilization Planning meeting to gather functional


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requirements from Command, Command Staff and General Staff that would be included in the incident Demobilization Plan. Functional requirements could include: safety, logistic, and fiscal considerations and release priorities that would be addressed in the plan. (j) (U) The size and scale of response operations carried out under this plan will require additional coordination where critical resources are concerned. A critical resource is any type/kind of resource that, due the type of incident, is in high demand and short supply. One of the key roles the Unified Area Command plays when activated is to become the arbiter of any critical resources needed throughout the response organization. Additionally, there is Critical Resources Chief designated at the NIC level to coordinate international offers of assistance and arbitrate critical resources at the national level. The demobilization of a critical resource will follow the same process described above with the exception that any critical resources on the tentative release list would have to be approved at the UAC level in coordination with the NIC Critical Resources Chief.

b. (U) Tasks.

(1) (U) The District Commander has overall responsibility for a significant oil pollution incident, or the threat from a significant oil pollution incident to US waters, within the Seventh Coast Guard District. He/she is tasked with the following incident specific responsibilities:

(a) (U) Pre-designate Coast Guard Incident Commanders who will be responsible for coordinating incident response efforts within their AORs. (b) (U) Assume the duties of the Unified Area Commander (UAC) for the Coast Guard if the incident dictates the need for a Unified Area Command. (c) (U) Serve as the FOSC as noted in reference (a) if the incident is declared a SONS. (d) (U) Prepare and maintain an International Offshore Drilling Response Plan. This plan shall include


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logistics and personnel requirements, mutual support coordination, and international coordination. (e) (U) Receive, evaluate, and disseminate pertinent information to all Coast Guard units located within the Seventh District’s AOR. (f) (U) Support incident response operations. Provide logistical, personnel, and operational assistance to Coast Guard commands affected by the incident. Deploy personnel, as necessary, to assist with response operations. (g) (U) Provide material and personnel requirements anticipated for incident response support that is beyond Base Miami Beach’s (BMB) capabilities to the Director of Operational Logistics (DOL) via LANTIMT LSC or the DCMS watch. (h) (U) Ensure that expenditures by units within the District, which qualify for reimbursement under the Oil Spill Liability Trust Fund (OSLTF), are properly documented. (i) (U) Keep COMLANTAREA apprised of the incident status. (j) (U) Take actions as noted in the Executive Checklist, Enclosure (2) to this plan.

(2) (U) NIMS Unified Area Commander. The NIMS Unified Area Commander will have overall responsibility for the strategic management of the incident and for the setting of strategic priorities between multiple incidents or single incidents that impact more than one COTP Zone. The Unified Area Commander will ensure the timely identification and allocation of critical resources based on those priorities. The responsibilities include communicating with affected parties, the public, and coordinating federal, state, local, and international resources at the national level. If there is an incident that impacts more than one COTP Zone, the District may activate the D7 Area Command Incident Management Team (IMT) as necessary.

(a) (U) Unified Area Command Staff. The UAC will be staffed and will operate as detailed in the Coast


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Guard Incident Management Handbook (IMH), reference (i). The District Incident Management Team (IMT) will provide the primary staffing for the UAC and will operate as detailed in reference (j). In addition to the staffing noted in reference (i), the UAC staff will include the following additional positions or expanded position descriptions:

1 (U) Intelligence Officer (INTO). The responsibility of the UAC INTO is to provide Command intelligence information for the UAC that can have a direct impact on the response personnel and influence the disposition of maritime security assets involved in the response. Normally, detailed information regarding incident intelligence specifics will be referred to and handled by the appropriate on-scene INTO. The UAC INTO will generally provide information on overall intelligence issues and progress/status of the response from a regional or national perspective. 2 (U) Legal Technical Specialist. Legal advice will be required to support the UAC members due to the potential for significant legal issues associated with Major Incident Management activities and the potential for US assets to engage in response operations in or near another country’s territorial waters. 3 (U) NIMS Technical Specialist. Major Incident Management activities are by their nature more complex than typical response operations. The availability of a NIMS expert or experts to advise the UAC on process and management issues will enable more effective response operations. The NIMS expert(s) can also serve as very effective facilitators during some of the critical objective setting and key decision sessions where a neutral party who is focused entirely on the process may help the UAC gain consensus on a number of difficult issues. 4 (U) UAC Planning. In addition to the typical UAC Planning organization, this type of response will require some specialized planning elements at the UAC level:


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a (U) Advanced Incident Planning Team. In addition to the standard planning section units at the UAC level, this organization includes a Major Incident Management feature called Advanced Incident Planning. The Advanced Incident Planning team is charged with looking beyond the typical 1-2 operational periods and determining future challenges, issues, or major changes in the operational response. This type of activity is typically undertaken by a relatively small team of responders/planners who have the requisite knowledge and experience to be able to anticipate the evolution of the response and make recommendations to the UAC and incident level Incident Commanders. b (U) UAC MTS Recovery Unit (MTSRU). The MTS Recovery issues are typically dealt with at the Sector level during any incident that results in a disruption to the MTS within that Sector’s AOR. Due the potential for this type of incident to have significant economic impacts that extend beyond a single Sector’s AOR, the UAC will stand up a robust MTS Recovery Unit (MTSRU) and take the lead on MTS Recovery issues. If the incident creates a major disruption to the MTS, the UAC MTSRU may also be the focal point for any National level priorities that come out of discussions as a result of the CBP/USCG Joint Protocols for the Expeditious Recovery of Trade, reference (v). In addition to the typical MTS Recovery Unit responsibilities detailed in reference (i), the UAC MTS Recovery Unit will focus on the following specific areas:

(1) (U) Economic Impact of the Incident. The UAC MTSRU will engage state, local and industry representatives who can provide accurate and defendable economic impact assessments. By incorporating these representatives into the MTSRU, the UAC will ensure that economic impacts are accurately characterized and that strategies to mitigate or minimize economic impacts are


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built with significant input from the affected parties. (2) (U) Offshore Vessel Traffic. The UAC MTSRU will engage industry representatives who can provide expertise and advice regarding the routing of commercial offshore vessel traffic. The MTSRU will coordinate closely with impacted industries to ensure that all available federal, state, local and industry tools/resources are utilized to minimize the impacts of the incident. The tools available to the MTSRU could include USCG vessel tracking systems, USCG offshore assets, government and private sector notification systems (Notice to Mariner (NTM), Notice to Airmen (NOTAM), communications systems utilized by the industry, etc). The intent is for the MTSRU to take advantage of the agility of private sector systems for rerouting or rescheduling vessel traffic to minimize impacts. The MTSRU will be tasked with developing a Vessel Routing Plan that details strategies for handling the various types of commercial traffic that may be impacted by the incident. The Vessel Routing Plan should include strategies to enable vessels to transit the incident area and avoid the largest concentrations of spilled oil and in doing so, minimize the need for any type of decontamination. The Vessel Routing Plan will recommend courses of action to address, at a minimum, the following scenarios:

(a) (U) Commercial vessels transiting the impacted area that will call on a United States port. (b) (U) Commercial vessels transiting the impacted area that will not call on a United States port. (c) (U) Commercial vessels that will require some sort of decontamination prior to port entry. The MTSRU will need to work closely with the Sector in


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which the vessel will make their port call to ensure information is shared regarding vessels that will need to be decontaminated prior to port entry in accordance with the Regional or Sector specific Decontamination Plan.

5 (U) UAC Logistics – Communications Coordinator. The need for a Common Operational Picture (COP) was a frequent theme in all of the DWH after action reports. Given the importance of an effective COP to the overall success of the response operations the UAC should establish the position of Communications Coordinator (COMC). The COMC serves as the leadership function on the response for all C4IT. All the COMLs and the rest of the C4IT responders functionally report to him/her, while keeping their traditional ICS reporting chain through logistics. 6 (U) UAC Liaison Officers. Due to the significant number of agencies that may be called upon to support response operations of this nature, effective use of Liaison Officers will be crucial to the success of the operations. For agencies that do not meet the criteria for inclusion in the UAC, the proper place to include them in the organization would be as LNOs and/or Agency Representatives (AREP). The following agencies/entities should be represented with LNOs/AREPs at the UAC level.

a (U) DOD. The potential to employ a significant number of DOD resources (vessels, aircraft, Emergency Ship Salvage Material (ESSM) response equipment, etc.) dictate that a DOD representative be included as a LNO, if not designated as a member of the UAC. b (U) DOI – BSSE. Jurisdiction over the RP (if applicable) will be a key element in determining whether BSSE is part of the UAC or plays a role as a Liaison Officer or Assisting Agency. c (U) DOI – FWS. The FWS would be a key player in the determination of fishery closures and


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development of criteria for reopening. The potential for significant economic impact from extended fishery closures necessitates close coordination with FWS. d (U) Treasury Department – OFAC. OFAC administers and enforces economic and trade sanctions based on US foreign policy and national security goals against targeted foreign countries and regimes, terrorists, international narcotics traffickers, those engaged in activities related to the proliferation of weapons of mass destruction, and other threats to the national security, foreign policy or economy of the United States. e (U) DOS. The DOS would likely be engaged in any type of response which might involve significant impacts to the US from a spill originating in a foreign country. The DOS representation could range from a LNO as suggested in this organization to other more active roles depending on the nature of the response organizations anticipated interactions with a foreign government. f (U) DOC – BIS. BIS involvement would be likely if the spill originated outside US waters and US companies needed to obtain a Commerce Export License. BIS controls extend to US and foreign parties that would send items subject to BIS regulations to any country when BIS authorization is required. g (U) State Representatives. Depending on which State Agency takes the lead and assumes a role in the UAC, there may be other State Agencies that are fully engaged in the response operations and would need to have a dedicated LNO in addition to their representation on the UAC. h (U) NRT/RRT/CRRT. The nature of this type of incident and the numerous operational issues dictates the need for a Liaison to the National Response Team, Regional Response Team/Caribbean Regional Response Team.


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i (U) LNO to/from the Country of Spill Origin. Because of the potential for a spill of this nature to originate in a foreign country, there needs to be some consideration given to how that country might be represented in the response organization. This could be accomplished through a LNO deployed to the spill country, a LNO from the spill country or a combination of both. The level of engagement of the spill country will most likely dictate where they fit into the response organization.

(3) (U) Federal On-Scene Coordinator (FOSC). With a SONS declaration and the establishment of the NIC organization, the operational chain and the reporting on the status of the incident will occur through the NIC. A single FOSC will be designated at the District level and the Sector Commanders and the designated Offshore Operations IC will be designated as ICs and still retain responsibility for response operations within their AOR supporting the FOSC. (4) (U) Deputy Commandant for Mission Support (DCMS). DCMS shall be prepared to provide logistics support and function as a resource provider. The below DCMS units are tasked with the specific incident responsibilities in accordance with the Mission Support Handbook and reference (p):

(a) (U) Base Miami Beach (BMB). BMB will provide the District IMT with qualified personnel to fill the Logistics Section Chief position on the District’s IMT, as well as a Safety Officer from the Base HSWL Department and a C4IT SME from the Base ESU Department to work within the ICP’s Communications Unit. (b) (U) Depending on the equipment, support for emergency communications equipment will come from either the C4IT SC or LANT-36. Regardless, requests for such support will be routed to the LSC, who will consult with a C4IT SME from Base Miami Beach to determine to whom the request should be forwarded for action. The C4IT SME will be assigned to the Communications Unit and will assist the designated SITL with the establishment and maintenance of the hardware and software required to maintain the Common Operating Picture (COP).


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(c) (U) The Shore Infrastructure Logistic Center (SILC) shall be prepared to provide a Procurement Unit Leader (PROC) upon request. When assigned, the PROC will work in the Finance Section and document and submit for reimbursement expenditures by Coast Guard units that qualify under the OSLTF, as detailed in reference (c). Otherwise, all financial support will be the responsibility of Seventh District. (d) (U) Other DCMS units shall be prepared to provide upon request the Emergency Response Teams (ERT) as defined in reference (p). These teams will be requested via the normal RFF process and sourced in accordance with procedures established at the appropriate Logistic or Service Center.

(5) (U) Designated Coast Guard Incident Commanders (ICs) shall:

(a) (U) Be responsible for the overall management of the incident. The IC shall direct incident activities, including development and implementation of overall objectives and strategies, and approve ordering and releasing of non-critical resources for their assigned or designated AOR. He/she shall act as the Coast Guard representative to the Unified Command established in that AOR. (b) (U) As operations permit, alert the maritime community of the incident via Urgent Marine Information Broadcast (UMIB), Homeport, NTM, and the designated COP, in accordance with area plans. The Coast Guard is responsible for providing information to the maritime community. (c) (U) Identify and assess the severity of all Marine Transportation System (MTS) disruptions and work closely with the impacted maritime industry segments to resolve these issues. Coordinate closely with the UAC and ensure the CART database Executive Summary is updated to reflect the critical issues. (d) (U) Provide personnel, equipment, and assets to support incident response efforts.


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(e) (U) Ensure that expenditures for response operations that qualify for reimbursement under the OSLTF are properly documented. (f) (U) Ensure that the Coast Guard’s pre-positioned response equipment and other publicly owned response equipment are only used to supplement the oil and clean up industry’s response program or be used if the commercial industry does not have readily available resources, and only until such time that the Federal On-Scene Coordinator or the Unified Command decides to release the resources. (g) (U) Take actions as noted in the Execution Checklist (enclosure (1) to this plan) and if applicable the Executive Checklist (enclosure (2) to this plan.

(6) (U) Designated IC for Offshore Operations. The Offshore Operations IC is responsible for the overall management of the offshore portion of the incident. He/she will coordinate closely with Sector ICs to ensure that all on-water response AORs are clearly defined and that operations are closely monitored to ensure unity of effort. He/she shall act as the Coast Guard representative to the Unified Command established at the incident level for the Offshore AOR. He/she shall establish effective communications with the RP/Responsible Entity’s representatives to ensure that their operations and those conducted by the Offshore IC are coordinated. The Offshore UC will be staffed and will operate as detailed in the Coast Guard IMH (reference (i)). The initial staffing for the Offshore UC organization is detailed in the District Watch, Quarter and Station Bill. The steady-state staffing for the Offshore UC will be provided by the LANTAREA Incident Management Assist Team (IMAT). In addition to the staffing noted in reference (i), the Offshore UC staff will include the following additional positions or expanded position descriptions.

(a) (U) Unified Command. The Unified Command for the Offshore Organization would include at a minimum the D7 Offshore IC, a State representative, and a Responsible Party/Responsible Entity representative. The UC could also include representatives from other Federal stakeholder agencies, as necessary.


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(b) (U) Chief of Staff. The Chief of Staff position has been used very effectively to manage the Command Staff Officers and enable the Coast Guard IC to focus efforts on the response operations. (c) (U) Liaison Officer (LNO). There could be a wide range of LNO’s assigned given this type of scenario. LNO’s could be established with commercial shipping and other stakeholders that might be impacted by a large offshore spill. LNO positions that should be anticipated include:

1 (U) DOD – ESSM. Depending on the level of engagement of DOD assets the focus for this position could shift to the Unified Command or remain as a LNO. If there is an extensive deployment of ESSM equipment then there might be a need for ESSM representation on the UC vice at the LNO level. 2 (U) State Representatives. This part of the organization has the potential to be conducting response operations that are in or adjacent to state waters. Key decisions made regarding operations in the offshore area could either mitigate or exacerbate impacts to the state’s AOR and as such they are likely to be very interested in the offshore/nearshore operations. Additionally, the states may have assets that could be used to support the operations in the offshore AOR.

(d) (U) Technical Specialists. Given the nature of this type of response there could be a significant number of technical specialists assigned to support at various levels of the response organization. Some of the likely Technical Specialist includes:

1 (U) Environmental Specialist. This type of support would typically be provided by the NOAA Scientific Support Coordinator (SSC). Although the Environmental Unit is tasked with this type of support, the NOAA SSC typically plays a larger role in advising the UC than would be typical of someone at the Unit Leader level. For significant/complex response operations the NOAA SSC should be used in this capacity.


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2 (U) Dispersant and In-Situ Burn Operations Specialist. A spill that involved the widespread application of a number of response technologies including dispersants and in-situ burn, the employment of a technical specialist with operational experience in these areas is highly recommended. 3 (U) Risk Communications. A lesson learned during the DWH response was the entire response organization needed to be better versed in Risk Communications practices/techniques. This position should support the PIO in ensuring that the response organization is engaging in effective risk communication practices.

(e) (U) Operations Section. The Operations Section is the most dynamic of the sections as it will have to change to take into account a number of considerations. As the response organization grows, the use of Branches as span of control mechanisms is highly recommended. The expanded Operations Section and Air Operations Branch Organizations are described in greater detail in the Operations Section enclosure (enclosure (4)). (f) (U) Air Operations Branch. This element of the organization starts off at the Branch level due to the size and complexity of the anticipated Air Operations. The Air Operations for this type of scenario will involve providing air support to dispersant application operations (fixed wing primarily), skimming operations (primarily rotary wing), surveillance operations and perhaps even some logistical support as well. The lessons learned during DWH noted that as this part of the organization grew and became more complex, it required a dedicated location with the requisite communications and support equipment. The establishment of an Aviation Coordination Center (ACC) is a service that is being requested through DOD.

(7) (U) Coast Guard Offshore Assets. An incident of this type will employ a full range of Coast Guard assets. Supporting a large scale offshore response operation will likely require capabilities beyond what the typical


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response assets could provide. Offshore assets deployed to assist with response operations could be tasked to provide the following types of support:

(a) (U) Provide situational awareness of offshore environmental and security conditions, and issues affecting operational mission execution (status of search or recovery operations) in order to inform decision-making by the UC. (b) (U) Make recommendations to the IC to change the direction contained in the IAP based on local conditions (e.g., on scene weather, early completion of search areas, unanticipated rotation of ships/aircraft for logistics, etc.). (c) (U) Assume Tactical Control (TACON) of assigned USCG and other government agency (OGA) surface assets within the designated geographic AOR. (d) (U) Assume TACON of aircraft in the AOR as authorized by the Air Operations Branch Director and/or the Aviation Coordination Center (ACC) if established. (e) (U) Ensure IFF transponder codes for air operations in the vicinity of other nation’s air space are requested and assigned for helicopters embarked in cutters/ships assigned to the operation. (f) (U) Ensure mission tasking contained in the IAP or other directives (e.g., Daily OPTASK messages, Air tasking Orders, etc.) are tasked to appropriate subordinate (surface and air units), and cooperating OSRO or other commercial response vessels. (g) (U) Promulgate communications plan for on scene units via OPTASK or other message traffic. (h) (U) Ensure actions to locate and contain or recover oil (e.g., dispersants, burning, etc.) are conducted as directed in the IAP or other direction provided by the UC. (i) (U) Establish battle rhythm for report of operational activity, synched to the reporting deadlines established by the UC.


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(j) (U) Ensure appropriate safety information, warnings, and direction regarding oil and other hazardous materials (e.g., dispersants) is provided to units and vessels operating in the AOR. (k) (U) Ensure that appropriate rules of engagement (ROE) are obtained from the operational commander (D7), and communicated to response units. Ensure appropriate measures are taken, including requesting additional assistance, if security conditions warrant. (l) (U) Coordinate logistics for offshore vessels (i.e., delivery of critical parts/supplies offshore to afloat units); maintain a rotational schedule for cutters in the response operation (to facilitate refueling, re-provisioning, crew rest, etc.).

c. (U) Coordinating Instructions. See Basic Plan – Coordinating Instructions. d. (U) Situation Reports. See reference (l) for reporting requirements. See reference (m) for a sample SITREP message. Marine Transportation System Recovery issues will be reported in the Common Assessment and Reporting Tool (CART) application as detailed in reference (n) to this plan.

4. (U) Administration and Logistics.

a. (U) Concept of Support. As noted in paragraph 3.b.(4)(a) above, Base Miami Beach (BMB) will provide a Logistics Section Chief, a Safety Officer, and a C4IT SME to the District IMT, which will be used to staff the Unified Area Command. Requests for additional personnel and equipment shall be made using the standard RFF process in accordance with COMDTINST M5400.1 (series). All other personnel and logistics requirements shall be coordinated through the lowest possible Logistics Section Chief (UC or UAC). If required, these requests will be forwarded to the LANT IMT, or if not established, to the DCMS Watch. The LANT IMT LSC or LANT-4 will then validate the request and vet it through the appropriate DCMS unit or LANTAREA Office for sourcing. It is expected, given the potential size of this type of event, that the Surge Staffing Branch (SSB) of the Personnel Service Center (PSC) will source RFFs for Individual Augmentations (IA) from throughout the Coast Guard.


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b. (U) Logistics/Finance. The Logistics function for a Type 1 or Type 2 incident must recognize and leverage existing logistical support processes. While the Logistics Section Chief is ultimately responsible for the logistical support of the event, the Responsible Party, the Coast Guard, Assisting & Cooperating Agencies, and others who are engaged in the response effort will likely bring their own existing logistics to support their participation in the response. The challenge for the LSC will be to ensure that each of these agency/entity specific logistics streams is coordinated so as to ensure they work in concert with each other and without wasteful overlap.

(1) (U) Coast Guard units will charge all expenses related to a response governed by this plan using unit funding, unless specific guidance regarding financial policy and accounting information is provided via CG message traffic from District 7 or higher CG authority. Unit Commanders, as well as the ICs and ACs, will ensure their units follow all provided guidance and retain complete documentation and justification for all purchases subject to reimbursement by the RP, if available. As a reminder; if the OSLTF is opened, only the FOSC has authority to approve expenditures against the OSLTF account. (2) (U) ACs and ICs are responsible to track resource cost documentation in accordance with the National Pollution Fund Center standards for incidents with or without a responsible party. (3) (U) For additional information, see Annex D – Logistics.

c. (U) Personnel. With the exception of positions staffed by Base Miami Beach, positions in the initial response organization(s) will be filled by pre-designated D7 personnel as noted in the WQSB. The WQSB also lists the likely candidates (title/organization) that will relieve the initial personnel. In the event the incident is designated a SONS, the SONS Response Management Instruction (reference (c) calls for the establishment of an AC Critical Personnel Resources Unit that, in coordination with the Surge Staffing Branch (SSB) of the Personnel Service Center (PSC), will utilize the Mobilization Readiness Tracking Tool (MRTT) to ID and assign personnel with the appropriate skill sets. In addition, the SONS instruction calls for the development of an incident specific assignment policy that assigns personnel to key


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positions for the duration of the response and establishes a sufficient relief/rotation schedule. Although this requirement is currently specific to the SONS instruction, that same approach will be used to support extended operations that are not designated as SONS incidents. For shorter duration incidents a scaled down approach will be used which takes advantage of the MRRT and local/regional expertise to support the response operations and ensure the best continuity possible.

(1) (U) Any requests for additional personnel support that are beyond the Seventh District’s capabilities shall be made using the standard RFF process in accordance with COMDTINST M5400.1 (series). If required, these requests will be forwarded to the LANT IMT, or if not established, to the DCMS Watch. The LANT IMT LSC or LANT-4 will then validate the request and vet it through the appropriate DCMS unit or LANTAREA Office or when appropriate to the SSB for sourcing. (2) (U) Coast Guard Selected Reservists and Auxiliarists may be used to backfill the active duty personnel involved in response operations per current guidance.

(a) (U) Subordinate Command Response Personnel Requirements. FOSCs requiring additional operational or support personnel shall make requests to D7 via the Area Command LSC. If the District is unable to meet these personnel needs, the request will be forwarded to LANTAREA via the LANT IMT LSC or the DCMS Watch for action. (b) (U) If requested, the Seventh District will assist FOSCs/ICs in finding Auxiliary members to support response operations.

(3) (U) If an evacuation of personnel or operational units becomes a requirement, guidance will be provided by the Seventh District via record message traffic in the form of a EVACORDER.

d. (U) Public Affairs. The NIMS Unified Area Command staff shall establish policies and procedures for dealing with the national news media. The UAC staff shall ensure that the entire Joint Information System (JIS) set of capabilities to organize, integrate and coordinate the delivery of public information is utilized. The NIMS Unified Area Command


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Public Information Officer (PIO) will coordinate with the designated ICs to ensure consistency in news releases and stories. Where appropriate, a Joint Information Center (JIC) will be established using the NRT JIC model as a guideline.

(1) (U) The District Commander shall deploy public affairs teams to assist the Coast Guard Incident Commanders if requested. These personnel will maintain liaison with local and national press interests keeping them advised of Coast Guard involvement in the response operation. District External Affairs may request support from the National Strike Force Public Information Assist Teams (PIATs). (2) (U) For more detailed Public Affairs information and the Joint Information System (JIS), See Annex F – Public Affairs.

e. (U) Funding. The most likely scenario under this plan will not involve a Responsible Party that is subject to United States jurisdiction. As such, the primary funding source for operations under this plan will be the Oil Spill Liability Trust Fund (OSLTF). The Coast Guard, specifically the National Pollution Funds Center (NPFC), manages the OSLTF for oil related incidents. During a catastrophic pollution incident, additional funds are made available to carry out and support the response in accordance with reference (k). Contracts for resources, including equipment, personnel, messing, berthing, maintenance, repair, and cleaning, may be purchased or enacted by the FOSC with funds from the OSLTF utilizing BOAs. Pre-approval from a SILC contracting warrant is required for all non-BOA contract procurements. If due to an after-hours emergent situation, a non-BOA contract was purchased, the SILC contracting warrant must be contacted as soon as possible to complete a BOA conversion.

(1) (U) Cost Documentation. It is the responsibility of the FOSC and the designated ICs to accurately document reimbursable costs for future recovery for replenishment of the OSLTF by the responsible party or responsible entity if an actual RP does not exist. Costs are documented in accordance with policy from the National Pollution Funds Center (NPFC).

f. (U) Protocol. The NIMS Unified Area Command staff shall carry out protocol functions and establish procedures for dealing with all VIPs. The function of the protocol staff is


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to shield the designated ICs from VIP activities while keeping them informed. g. (U) Meteorological and Oceanographic Services. The NOAA Scientific Support Coordinator (SSC) typically provides access to this information during response operations. See Annex H – Meteorology and Oceanographic Services. h. (U) Medical Services. Medical services for responders are the responsibility of the Logistics Section within each Unified Command organization. See Annex Q – Medical Services. i. (U) Administrative Reports. See Annex R – Reports.

(1) (U) Reference (b), when implemented, requires each federal department and agency involved in the response to keep records of their activities to assist in preparing the After Action Report. (2) (U) After Action Reports and Lessons Learned shall be submitted within 21 days of the end of incident response operations in accordance with reference (q). The Contingency Preparedness System, including CG-SAILS, can be accessed on the CG intranet at: http://llintra.comdt.uscg.mil/CPS/. (3) (U) Pollution Situation Reports (SITREP POL). SITREP POLs shall be submitted to NIMS Unified Area Commander using the general POLREP format guidelines in Section 7.B.6.b.(l) of Volume VI of reference (q). Post all SITREP POLs on Homeland Security Information Network (HSIN). A sample SITREP POL can be found in reference (m). (4) (U) Marine Informational Safety and Law Enforcement (MISLE) Entries. MISLE entries will be made in accordance with Section 7.B.6.b.2 of Volume VI of reference (q). (5) (U) Common Assessment and Reporting Tool (CART). Information regarding MTS impacts shall be reported using CART as noted in reference (n) of this plan. Additional incident specific guidance on the entry and maintenance of CART data will be promulgated by the UAC.

5. (U) Command and Control.


http://llintra.comdt.uscg.mil/CPS/

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a. (U) Command Relationships. See Annex J – Command Relationships.

(1) (U) The operational chain of command will flow from Commander, Atlantic Area, through the District Commander, to the Coast Guard Incident Commander pre-designated for incident response operations. (2) (U) The support chain of command will flow from DCMS through DOL and the Logistic and Service Center Commanders to Base Miami Beach. Requests by units for logistics and support will be made using ICS procedures and in accordance with COMDTINST 5400.1 (series). (3) (U) When the Commandant, U.S. Coast Guard declares a SONS and designates a NIC, the NIC will have overall responsibility for incident strategic management. FOSCs / Incident Commanders will report to the NIC, and the NIC is accountable to the Commandant. (4) (U) Federal On-Scene Coordinators retain responsibility for response operations, as described in Subpart 300.120 of reference (a) within their AOR.

b. (U) Command Posts. Several Incident Command Posts (ICPs) will be established to support response operations under this plan. Specific command post requirements are detailed in the Logistics Support enclosure (enclosure (3)).

(1) (U) UAC Command Post. The UAC command post will be located in the Greater Miami area and be sized and equipped to support UAC operations as well as the UAC Joint Information Center. The UAC command post will not be collocated with the Offshore UC command post. (2) (U) Offshore Operations Unified Command Post. The Offshore UC Command Post will be in the Greater Miami area and be sized and equipped to support UC operations as well as the UC Joint Information Center.

c. (U) Succession to Command. See Basic Plan – Succession to Command. d. (U) Command, Control, and Communications. See Annex K – Command, Control, and Communications and reference (s).


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EXHIBITS: 1 – PLAN COORDINATION 2 – PHASED ORGANIZATION ENCLOSURES: 1 – EXECUTION CHECKLIST FOR 0-24, 24-48, 48-96 HOURS 2 – EXECUTIVE CHECKLIST FOR 0-24, 24-48, 48-96 HOURS 3 – LOGISTICS SUPPORT 4 – OPERATIONS ORGANIZATION 5 – SAMPLE DELEGATION OF AUTHORITY 6 – OPERATIONAL FRAMEWORK


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EXHIBIT 1 TO TAB D TO APPENDIX 24 TO ANNEX C TO CCGDSEVEN OPLAN 9770-09 (U) PLAN COORDINATION (U)

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EXHIBIT 2 TO TAB D TO APPENDIX 24 TO ANNEX C TO CCGDSEVEN OPLAN 9770-09 (U) PHASED ORGANIZATION (U)


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ENCLOSURE 1 TO TAB D TO APPENDIX 24 TO ANNEX C TO CCGDSEVEN OPLAN 9770-09 (U) EXECUTION CHECKLIST (U) 1. (U) Execution Checklist. The following checklists cover initial response actions that should occur within the time frames of 0-24 hours, 24-48 hours, and 48-96 hours. 2. (U) IODRP Execution Checklist 0-24 Hours. Upon Notification of an International Offshore Spill complete the following actions:

a. (U) Seventh District Command Center (DRMC).

(1) (U) Complete the International Oil Spill Quick Response Sheet (reference (t)) and determine if any key pieces of information are missing. (2) (U) Initiate Commandant’s Critical Information Reporting (CCIR) notifications as required by current Coast Guard directives. (3) (U) Command Duty Officer (CDO) – Verify all notifications (including RRT IV) are completed and updates are provided as new information is received. (4) (U) Place selected Offshore Unified Command response organization members on standby (use established notification group in Homeport based on WQSB). (5) (U) Issue NOTAM and NTM and update as necessary.

b. (U) Seventh District Staff & Subordinate Commands.

(1) (U) Recommend standing up the IMT. (2) (U) IMT – Conduct initial assessment of the severity of the incident by determining the following:

(a) (U) Current status of release and efforts at source control. (b) (U) Projected trajectory based on WCD from spill location – request NOAA Scientific Support Coordinator (SSC) run a WCD trajectory model from the reported spill location.

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(c) (U) Current and project weather in the response area.

(3) (U) Seventh District Staff provides an assessment on whether the incident will likely be a Tier 1, Tier 2, or Tier 3 incident as further described in reference (d). The table below provides a crosswalk between the definitions in reference (d) and the terminology used in the NCP.

Oil Spill Amount Reporting OPRC Definitions NCP Definitions (Coastal Spill)

Tier 1 Accidental discharges occurring at or near a facility as a result of routine operations. Impacts are low and in-house response capability is adequate.(0 to 4200 Gallons)

Minor Less than 10,000 Gallons

Tier 2 Medium-sized spills occurring in the vicinity of a facility as a result of a non-routine event. Significant impacts are possible and external (regional) support for adequate spill response is required. (4200 to 210,000 Gallons)

Medium 10,000 to 100,000 Gallons

Tier 3 Large spills occurring either near or remote from a facility as a result of a non-routine event, and requiring substantial resources and support from national or world-wide spill co-operatives to mitigate effects perceived to be wide-reaching, i.e., of national or international significance. (Over 210,000 Gallons)

Major Over 100,000 Gallons

(4) (U) Initiate aerial over-flights/establish over flight schedule (first light flight). Initial flight should be SSC or qualified representative. (5) (U) Activate Federal Project Number (FPN) through NPFC if not already established. Determine ceiling. (May be completed at the unit level) (6) (U) Activate SILC, establish funding/purchase limits.


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(7) (U) Engage with Sectors to: (a) (U) Ensure staging areas are activated to support on-water operations. (b) (U) Activate local BOAs and examine need of identified Tidal Inlet Protection Strategies (TIPS) per ACPs.

(8) (U) Activate GIS-Corp staff for display processing. (9) (U) Activate NOAA/USF imaging capabilities. (10) (U) Engage with State CNCS/OSHA representative at USF to ensure established training facilities for volunteer responders. (11) (U) Initiate incident documentation to ensure all key response decisions are captured and properly documented. (12) (U) DMT – Create incident specific e-mail account and send notification for users to send copies of incident materials to that account. (13) (U) SSC – Based on reported information develop the initial spill trajectory and fates and effects to include identification of potential windows of opportunity for using dispersants and in-situ burn. (14) (U) SSC – Run a worst case scenario trajectory using the WCD for the location in question to determine potential impacts if source is not secured. (15) (U) Based on NOAA projected impacts, distribute mass notification:

(a) (U) Local/Regional Emergency Operations Centers (for command post participation). (b) (U) Local/Regional response agencies. (c) (U) Coast Guard DRATs.

(16) (U) Activate tactical resource cascade plans. See Enclosure 6 – Operational Framework.


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(17) (U) IMT – Place appropriate special teams/assist teams on standby and update as the situation progresses including the following:

(a) (U) Gulf Strike Team/NSFCC (Public Information Assist Team (PIAT), Response Resource Inventory (RRI) specialist, SMART monitoring capabilities). (b) (U) District Response Advisory Team (DRAT)/District Response Group (DRG). (c) (U) LANTAREA/PACAREA Incident Management Assist Teams (IMATs). (d) (U) Intelligence Coordination Center (ICC) and Maritime Intelligence Fusion Center (MIFC) LANT.

(18) (U) Initiate resource tracking if not already in progress. (19) (U) IMT – Determine status/availability of and place on standby CG assets in D7, D5, and D8 that can deploy Spilled Oil Recovery Systems (SORS) and Vessel of Opportunity Skimming Systems (VOSS). (20) (U) Determine status/availability of CG aviation assets that can carry the Airborne Dispersants Delivery System Package (ADDS-Pack) and place them on standby. Request LANTAREA reach out to BOA contractors with dispersant application capabilities. (21) (U) IMT – Activate the MTS Recovery Unit and develop an initial assessment of potential MTS impacts by gathering data from stakeholders. Open up an event in CART and begin to populate the appropriate Essential Elements of Information (EEIs). Ensure subordinate commands are made aware of the CART event and do not create duplicate events. (22) (U) IMT – Notify DOD assets described in this plan of the incident and determine their status:

(a) (U) Navy Supervisor of Salvage open water response equipment.


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(b) (U) NORTHCOM assets including location/staffing for the Aviation Coordination Center (ACC), location for any Incident Bases that will be needed.

c. (U) Unified Commander – Offshore Operations & Staff.

(1) (U) When notified of need to activate the Phase 1 response organization, ensure key Command & General Staff members activated and provide tasking as they arrive on-scene. (2) (U) Estimate personnel and equipment required for initial response priorities; anticipate the need for relief personnel. Complete PRFF for personnel and equipment and forward to LANT IMT or DCMS Watch. (3) (U) Determine timeline for getting initial aerial dispersant capabilities on-scene via a commercial provider and through the implementation of existing BOAs or MOAs. (4) (U) Initiate incident documentation to ensure all key response decisions are captured and properly documented.

(a) (U) Request deployment of Response Documentation technical specialists.

(5) (U) Institute Operational Risk Management (ORM) for all personnel involved in the response, including civilian OSRO personnel. (6) (U) Validate requirements for UAC and UC Offshore Operations ICP. If required coordinate with USCG SOUTCOM LNO to gain access to pre-designated spaces, activating supporting ICP Standup Checklist. (7) (U) Coordinate with SILC/GSA, providing long term facility requirements for UAC and Offshore Operations ICP if required. (8) (U) Arrange for initial over flight with appropriate observers (UAC/UC/Situation Unit Leader). Consider IR camera and video link to help document the over flight results. (9) (U) Review results of the over flight with UC/UAC staff and determine future air operations needs with the Planning Section Chief/Air Operations Branch Director.


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3. (U) IODRP Execution Checklist 24-48 Hours.


(1) (U) Monitor the situation and provide the IMT Situation Unit with the latest information to ensure an accurate status picture is maintained in the IMT.


(1) (U) IMT – Initiate the Area Command Operating Cycle as described in the IMH and determine UAC expectations with regard to the timing of the cycle and the products delivered. (2) (U) IMT – Establish and maintain an accurate and current situation status board that displays all pertinent response information as noted in the IMH. (3) (U) D7 Staff – Assess impact of incident on other mission areas and determine if actions need to be taken to reinforce other mission areas (i.e., AMIO show of force might be advisable to reinforce CG presence, or increased scrutiny of Marine Environmental Protection in the offshore area to discourage spiller of opportunity). (4) (U) IMT - Publish incident documentation procedures to ensure all key response documentation is captured and all staff members are aware of documentation requirements. (5) (U) SSC – Based on latest/updated information run spill trajectories and update windows of opportunity for using dispersants and in-situ burn. (6) (U) – When instructed, activate selected special/assist teams and determine ETA’s for each:

(a) (U) Gulf Strike Team/NSFCC. Request that NSFCC update the Response Resource Inventory (RRI) database and gather information on available resources. (b) (U) LANTAREA Incident Management Assist Team (IMAT).

(7) (U) IMT – Maintain status/availability and ETA (if activated) of CG assets in D7, D5, and D8 that can deploy


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Spilled Oil Recovery Systems (SORS) and Vessel of Opportunity Skimming Systems (VOSS). Pass information to UC Resources Unit Leader (RUL) and Situation Status Unit Leader (SITL). (8) (U) Maintain status/availability and ETA (if activated) of CG aviation assets that can carry the Airborne Dispersants Delivery System Package (ADDS-Pack) and pass information onto the UC RUL and SITL as they stand up. (9) (U) IMT - Maintain status/availability and ETA (if activated) of DOD assets/capabilities:

(a) (U) Navy Supervisor of Salvage open water response equipment. (b) (U) NORTHCOM assets including location/staffing for the Aviation Coordination Center (ACC), location for any Incident Bases that will be needed.

(10) (U) IMT (Planning) – Develop initial list of potential critical resources that will need to be managed by the UAC. For response operations under this plan consider the following as a starting point for potential critical resources:

(a) (U) Dispersant application aircraft. (b) (U) Offshore capable response vessels. (c) (U) Well Capping Resources/Services. (d) (U) Dispersant Chemicals (approved for use). (e) (U) Vessel of Opportunity Craft. (f) (U) Incident Management Assist Team members. (g) (U) Fire Boom. (h) (U) Oil Boom. (i) (U) Vessel of Opportunity Skimming Systems (VOSS). (j) (U) Spilled Oil Recovery System (SORS) equipped vessels.


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(k) (U) Environmental Response Management Application (ERMA) Common Operational Picture (COP) operators.

(11) (U) IMT (MTS Recovery Unit) – Provide initial assessment of potential Marine Transportation System impacts based on data gathering and stakeholder input. Update CART with latest information and establish a process for filling out the CART Executive Summary.


(1) (U) Initiate ICS Planning Processes described in the IMH. (2) (U) Conduct initial Unified Command (UC) Meeting. In addition to the established agenda ensure that a set of clearly defined response boundaries are established in consultation with D7 (d) because of potential response operations outside of US waters. (3) (U) Conduct initial Command & General Staff Meeting. (4) (U) OSC - Determine status of resources (staffing and equipment) to meet initial response objectives and adjust as necessary. Based on incident updates continue to assess adequacy of response efforts during current operational period. (5) (U) OSC/PSC - Conduct Tactics Meeting to plan for next operational period response activities. (6) (U) Direct the delivery and deployment of the first equipment to arrive on-scene IAW with priorities for the current operational period. (7) (U) PSC - Conduct Planning Meeting to present IAP for next operational period. (8) (U) Publish incident documentation procedures to ensure all key response documentation is captured and all staff members are aware of documentation requirements. (9) (U) Reinforce Operational Risk Management (ORM) practices and ensure designated Safety Officer is tasked to reinforce the use of ORM.


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(10) (U) Determine status of efforts to activate the UC ICP spaces and update timeline for moving response organization into the spaces. (11) (U) Make initial inquires to determine requirements for establishing a restricted airspace, as needed to safely conduct response operations. Pass monitoring responsibilities to the Aviation Coordination Center as it stands up. (12) (U) Approve/sign the IAP for the next operational period.

4. (U) IODRP Execution Checklist 48-96 Hours.


(1) (U) Monitor the situation and provide the IMT Situation Unit with the latest information to ensure an accurate status picture is maintained in the IMT.


(1) (U) IMT – Monitor the information needs of the UAC members and ensure the Situation Status Board displays all pertinent response information as noted in the IMH. Incorporate any COP output as well to ensure a single integrated Situation Status is maintained. (2) (U) IMT – Reinforce incident documentation procedures/requirements. (3) (U) SSC - Provide updated spill trajectories and windows of opportunity for using dispersants and in-situ burn. Provide recommendations for potential initial operating areas based on oil trajectories and over flight information. (4) (U) IMT (Planning) – Monitor list of potential critical resources and determine demobilization procedures for critical and non-critical resources. (5) (U) IMT (MTS Recovery Unit) – Monitor and brief up any potential Marine Transportation System impacts based on data gathering and stakeholder input. Update the EEI’s in CART with the latest incident information and provides updated info in the CART Executive Summary.


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(1) (U) Continue to follow the ICS Planning Processes described in the IMH and transition from the response checklist to the ICS Planning Process to drive activities. (2) (U) Reinforce incident documentation procedures to ensure all key response documentation is captured and all staff members are aware of documentation requirements. (3) (U) Reinforce Operational Risk Management (ORM) practices and ensure designated Safety Officer is tasked to reinforce the use of ORM. (4) (U) Determine status of efforts to activate the UC Offshore Operations ICP spaces and update timeline for moving response organization into the spaces. (5) (U) Develop/approve/sign the IAP for the next operational period.

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ENCLOSURE 2 TO TAB D TO APPENDIX 24 TO ANNEX C TO CCGDSEVEN OPLAN 9770-09 (U) EXECUTIVE CHECKLIST (U) 1. (U) Executive Checklist. The following checklists cover initial response actions for the Senior Management that should occur within the time frames of 0-24 hours, 24-48 hours, and 48-96 hours. 2. (U) IODRP Executive Checklist 0-24 Hours. Upon Notification of an International Offshore Spill complete the following actions:

a. (U) Unified Area Commander and/or D7 (d).

(1) (U) Brief LANTAREA on initial/intended response actions and provide recommendation on whether incident will meet SONS criteria. (2) (U) Ensure all stakeholders have been notified and begin discussions with the State Reps on initial response actions. (3) (U) Enact existing strategic communications plans and ensure all subordinate organizations are aware of communications protocols for the response. (4) (U) Initiate incident documentation to ensure all key response decisions are captured and properly documented.

(a) (U) Designate an authoritative system to collect and manage incident data and documentation and establish mechanisms and protocols for the use of the documentation system. (b) (U) Deploy technical specialists to set up and manage the system. (c) (U) Request deployment of Response Documentation technical specialists (if not already initiated).

(5) (U) Contact Department of State (DOS) and initiate process to gain permission for the US to engage in active response operations in the EEZ of another country.


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(6) (U) Determine status of spill country’s willingness to cooperate and establish outer limit of operational area for US Coast Guard assets including any airspace issues. (7) (U) Convene and brief the RRT on key operational issues – request they determine and communicate the requirements for the approval to use dispersants and in-situ burn as response strategies for areas without a pre-approval. (8) (U) Request deployment of NPFC case officer and OSLTF technical specialist via the National Response Center to assess current status of the Fund and project potential response costs to evaluate the need for funds transfers into the Emergency Fund and/or initiate appropriate actions to address potential Emergency Fund shortfalls. (9) (U) Discuss response requirements under OPA90 or CERCLA funding with the RP (if applicable) and determine where the lack of legal applicability may modify RP response efforts. (10) (U) Coordinate with the RP (if applicable) or Responsible Entity response team when they are identified and determine intentions regarding location of their ICP. Consider deployment of a CG Liaison Officer and support team to the remote ICP if established. (11) (U) Determine need to stand up UC-Offshore Operations Organization. (12) (U) Assess need to stand up the Unified Area Command (UAC) organization and activate if necessary. (13) (U) After consultation with the COMDT, establish a single Common Operational Picture (COP) and communicate the decision to the response organization. Bring in appropriate technical specialists to set up and manage the COP. (14) (U) Establish processes/mechanism to ensure mobilization of response personnel that can effectively:

(a) (U) Determine personnel needed for response, and identify source of personnel.


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(b) (U) Ensure personnel are properly trained, and health and safety issues are addressed.

3. (U) IODRP Executive Checklist 24-48 Hours.

a. (U) Unified Area Commander and/or D7 (d) – (assumes UAC Org stood up).

(1) (U) Update LANTAREA on response actions and provide recommendation on whether incident will meet SONS criteria (if not already designated). (2) (U) Monitor effectiveness of strategic communications plans and adjust as necessary. (3) (U) Reinforce importance of incident documentation to ensure all key response decisions are captured and properly documented and determine status of standing up comprehensive documentation system. (4) (U) Set up a schedule to brief the RRT on key operational issues. Determine status of the requirements for the approval to use dispersants and in-situ burn as response strategies. (5) (U) Conduct the Initial Area Command Meeting IAW with the IMH and ensure the following key decisions are made/documented:

(a) (U) Jurisdictional boundaries for the response operations. (b) (U) Location of the UAC Command Post (ACP). (c) (U) AC operating period length/start time. (d) (U) Lead organization for AC Planning Chief, Information, Safety, Intelligence and Liaison Officers, and other key staff positions, as needed. (e) (U) Procedures for the following:

1 (U) Managing sensitive information. 2 (U) Resource Ordering. 3 (U) Cost Sharing.


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4 (U) Cost Accounting. 5 (U) Operational Security Issues.

(6) (U) Conduct initial meeting with the UC(s):

(a) (U) Provide direction from LANTAREA and/or the COMDT regarding the overall response priorities. (b) (U) Communicate UAC priorities, overall objectives. (c) (U) Provide information reporting thresholds/requirements. (d) (U) Provide cost sharing/accounting requirements. (e) (U) Get briefing from UCs on the following:

1 (U) Resources at Risk. 2 (U) Incident Objectives/Priorities. 3 (U) Critical Resource needs. 4 (U) Anticipated timeframes for Geographic Response Plan (GRP) implementation (if applicable).

(7) (U) Based on updated operations information, project potential response costs to evaluate the need for funds transfers into the Emergency Fund and/or initiate appropriate actions to address potential Emergency Fund shortfalls. (8) (U) If Responsible Entity has established a remote ICP, determine makeup and staffing of Liaison Team and deploy them to the remote ICP location. Prior to deployment establish UAC expectations for the following:

(a) (U) Roles and Responsibilities (including CG authorities). (b) (U) Communications/Briefing schedule. (c) (U) Critical information needs.


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(d) (U) Emergent event briefing policy.

(9) (U) As the UAC develop incident specific guidance on the posting/sharing of information using the Common Operational Picture (COP) and communicate the guidance to the response organization. Ensure guidance covers the following:

(a) (U) Who has the authority to post information. (b) (U) Approval process for information to be posted. (c) (U) Levels of access. (d) (U) Archiving/documentation of posted materials. (e) (U) Schedule for posting new/updated information.

(10) (U) Publish the COP website address and ensure response stakeholders (including the public) have access. Monitor feedback on COP website to determine adequacy of information posted.

4. (U) IODRP Executive Checklist 48-96 Hours.

a. (U) Unified Area Commander.

(1) (U) Update LANTAREA on response actions and provide recommendation on whether incident will meet SONS criteria (if not already designated). (2) (U) Participate in the Area Command Operating Cycle and transition from Executive Checklists to the Operating Cycle to drive activities. (3) (U) Monitor effectiveness of strategic communications plans and adjust as necessary. (4) (U) Get feedback from the UAC members and other response stakeholders on the utility of the COP and update as necessary to ensure it is an effective communications tool. (5) (U) Continue to reinforce importance of incident documentation to ensure all key response decisions are captured and properly documented. Assess utility of the


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system of record established to support response documentation. (6) (U) Monitor the Emergency Fund and/or initiate appropriate actions to address potential Emergency Fund shortfalls.

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ENCLOSURE 3 TO TAB D TO APPENDIX 24 TO ANNEX C TO CCGDSEVEN OPLAN 9770-09 (U) LOGISTICS SUPPORT (U) 1. (U) Logistics. The Logistics Section for this type of response will be required to support diverse operations over a very wide geographic area. In addition to the typical logistics functions described in references (i), (o), and (p), there are additional specialized functions and capabilities described in this annex that will have to be addressed by the Logistics Section.

a. (U) Pre-Incident Logistics. A number of logistical arrangements can be made prior to an incident that will enable a more agile response when the incident occurs. Making arrangements for necessary response equipment, having BOAs in place and identifying pre-designated Incident Command Post (ICP) options can help ensure the Logistics Section can ramp up quickly to support response operations.

(1) (U) Basic Ordering Agreements (BOA). The best way to ensure quick access to the necessary response equipment and expertise is to have BOAs in place with the appropriate Oil Spill Removal Organizations (OSROs) and ensure they address the type of equipment and technical experts that will be necessary to respond to the incident. The Emergency Response Contracting Branch (PCB) of the SILC maintains these BOAs, and a list of active participants is available at http://www.uscg.mil/SILC/emergency.asp. (2) (U) Pre-Positioned Equipment Movement. There are a number of options for getting pre-positioned equipment to the site of the incident.

(a) (U) The best option to ensure pre-positioned government equipment can be moved quickly is for each of the DRAT Equipment Specialists (who are the VOSS property custodians) to ensure that they have commercial BOAs in place to cover the immediate transport of their equipment to and from each of their sites. (b) (U) The next option would be to have Strike Team commercial truck drivers deliver the equipment which may be challenging if the Strike Teams are fully engaged in other response operations.


http://www.uscg.mil/SILC/emergency.asp

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(c) (U) The third option would be to have the National Maintenance Contract (NMC) include the option to have the equipment shipped in the event of an incident. The Contracting Warrants in the SILC-PCB can assist in reviewing the NMC.

(3) (U) Support from Department of Defense (DOD) Assets. The extensive employment of DOD assets during the DWH incident resulted in a number of significant lessons learned around the request for, use of, and funding of DOD resources working under the Defense Support for Civil Authorities (DSCA) mission area. The primary avenue for obtaining DOD DSCA support will continue to be through close coordination with LANTAREA on the implementation of the process. The DSCA Plan does not currently have an annex that addresses support during a major oil spill. In order to ensure consistent and repeatable processes are in place, a DSCA SOP will be developed to address the areas described below and memorialize the lessons learned from DWH.

(a) (U) DSCA Support SOP. Several recommendations from previous incidents focused on the need for the development of established processes that could be quickly established and published to the response organization. The SOP should address the following areas:

1 (U) Describes the overall Request for Assistance (RFA) process and detail roles and responsibilities for involved agencies. 2 (U) Ensures that RFA tracking numbers are sourced from the Defense Support to Civil Authority, Automated Support System (DDASS) so that the USCG is using the DDASS number rather than a manually generated one. 3 (U) Ensures alignment between the OSLTF and current DOD process for funding of reimbursable budget authority based on an RFA and allows for centralized issuance and tracking of this authority. 4 (U) Incorporates the DOD Defense Coordinating Officers input and establishes costs for


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services, including unique and seldom used naval assets that will then have pre-established costs associated with their deployment 5 (U) Establishes a process that ensures RFAs for Incident Awareness and Assessment (IAA) capability/resources are routed through Remote Sensing Coordinator (or overall incident IAA collection requirements manager) in order to be properly vetted and approved.

(4) (U) Incident Support Bases. Identification of Incident Support Base locations is critical in order to ensure there is a pre-identified location where initial response and follow-on resources can be sent. Basic considerations when establishing a base include the following:

(a) (U) Access to Major Transportation Routes. Good access ensures resources can be easily delivered to the base and deployed from that location. (b) (U) Proximity to the Area of Operations. The base should be located in close proximity to where resources might need to be deployed but not so close as to be impacted by the incident. (c) (U) Available space. The base should have sufficient area/space to hold the amount of resources expected to be stored/serviced at that location. (d) (U) Security/Access Control. The base should be in a location, preferably fenced, where access to the facility can be controlled and resources can be adequately secured. (e) (U) Support Equipment. The base should be sufficient to allow access and operation of large support equipment such as cranes and forklifts which may be needed to load/offload certain types of resources.

(5) (U) Incident Command Posts (ICPs). During a protracted response operation the location and functionality of the ICPs is a critical consideration. The following are a list of considerations that should be taken into account for all ICPs and then some facility


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specific considerations for both the UAC ICP and the UC ICPs.

(a) (U) ICP Requirements. If there is an identified Responsible Party (RP), they will typically take care of the logistics of setting up the ICP and make arrangements for the spaces necessary for all responding agencies and stakeholders. In the absence of an identified RP, The General Services Administration (GSA) is responsible to provide this type of support during declared disasters and operations under the NCP. Section 300.175 of the NCP states that the GSA will provide logistic and telecommunications support to federal agencies. The type of support provided might include leasing and furnishing office space, setting up telecommunications and transportation services, and advisory assistance. Prior to an incident, the CG and GSA work together to identify appropriate locations for the ICPs and to establish the baseline support requirements to stand up the required facilities. These requirements should include timelines for activating and having the spaces at Initial Operating Capability (IOC) and Full Operating Capability (FOC). (b) (U) General Considerations for Selecting an ICP Location.

1 (U) Check existing Federal/State building space, local armories, GSA leased spaces and Military bases for possible locations. 2 (U) Determine proximity requirements (i.e. how close to incident does the facility need to be?). 3 (U) Ensure spaces are not in the 100 year flood plain. 4 (U) Are there adequate support services nearby (hotels, airports, restaurants, rental car locations, office supply stores, computer supplies, etc.). 5 (U) Are the spaces accessible for the anticipated ICP workers?


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6 (U) Can the facility be obtained/set up in an acceptable timeframe? 7 (U) Need to identify a COOP site as well as the initial ICP.

(c) (U) Requirements for all ICP Locations.

1 (U) Unrestricted access to spaces and parking areas 24/7. 2 (U) Emergency Lighting. 3 (U) Compliance with Life Safety Code 101 and the Americans with Disabilities Act (ADA). 4 (U) Adequate on-site parking or in close proximity to the facility. 5 (U) Restrooms (adequate numbers, capacity). 6 (U) Adequate utilities based on anticipated use. 7 (U) Not in a high crime area. 8 (U) If practical, Electronic Access Control capable of being expanded to ICP locations. 9 (U) Sound structure. 10 (U) Controlled access to the network room. 11 (U) Controlled access to the conference rooms. 12 (U) Capability to expand spaces if needed. 13 (U) Adequate meeting spaces. 14 (U) Adequate IT support areas.

a (U) Adequate numbers of outlets. b (U) Adequate numbers of IT connections. c (U) Network room with adequate HVAC system.


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d (U) Existing wiring or capability to wire a system to support the ICP. e (U) Existing phone jacks or capability to add as needed.

(d) (U) Lease Considerations.

1 (U) Can GSA negotiate a full service lease? 2 (U) What lease lengths are possible? 3 (U) Lease consideration during demob – turning spaces back as they are no longer needed. 4 (U) Utility costs. 5 (U) Who pays for necessary upgrades (IT connections, phone lines, other services) and are they left in place at the end of the lease. Future preference for access given based on improvement paid for during previous incidents? 6 (U) Availability of security services, janitorial services, etc. 7 (U) Maintenance support 24/7. 8 (U) Availability of space for expansion. 9 (U) Ability to get copies of the floor plan to CEU Miami for assistance in laying out the ICP spaces.

(e) (U) Considerations for the Unified Area Command ICP.

1 (U) Could be in close proximity to but should not be collocated with any of the Incident ICPs. 2 (U) With high level agency personnel in this ICP, there will be a need for dedicated private spaces for UAC agencies to utilize. 3 (U) Secure conference rooms are likely to be needed.


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4 (U) Security for senior agency personnel. 5 (U) SCIF needs – should rely on existing SCIF capabilities to the extent they can support the response operations.

(f) (U) Other Necessary Services.

1 (U) Office Furniture and Equipment. To allow for the timely opening of the ICP, the required office furniture and equipment will be provided from sources that will be timely and as cost effective to the Government as possible. Sources used can be excess or surplus inventories of the Federal Government; but will likely be a lease or purchase from commercial sources determined by the General Services Administration (GSA) to be in the Government's best interest. 2 (U) Office Supplies. Office supplies and other expendable items will be provided from either GSA or commercial sources. If from commercial sources, blanket purchase agreements (BPAs) should be used with local vendors unless another method is determined to be more advantageous by the supporting agency contracting officer. BPAs should be used with local vendors for purchases under $25,000.

(g) (U) Space Requirements. The space requirements for both the UAC ICP and the UC ICP are further detailed in Exhibit 1 to this enclosure.

b. (U) Post Incident Logistics. Following an incident the Logistics Section will be responsible for a number of support services. In addition to the normal logistical functions described in references (i), (o), and (p), there are some additional functions and capabilities based on Deepwater Horizon lessons learned that will need to be addressed by the Logistics Section.

(1) (U) Logistics Positions.

(a) (U) Communications Unit Leader (COML). The COML position took on a much larger role during the Deepwater Horizon incident with the advent of a Common Operational Picture (COP) as a key communications


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tool. In addition, the COML is tasked with establishing and maintaining the C4IT systems that will be used to capture all Coast Guard response documentation during an incident. These functions are in addition to the normal COML duties defined in the Coast Guard IMH.

(2) (U) Logistics Capabilities. The Logistics Section, through the COML position is tasked to establish two important systems in support of the response operation, one is the COP and the other is a system of record for capturing response documentation.

(a) (U) Common Operating Picture (COP). The COP used to support response operations under this plan is the Environmental Response Management Application (ERMA) is an online mapping tool that integrates both static and real-time data, such as Environmental Sensitivity Index (ESI) maps, ship locations, weather, and ocean currents, in a centralized, easy-to-use format for environmental responders and decision-makers. ERMA enables a user to quickly and securely upload, manipulate, export, and display spatial data in a Geographic Information System (GIS) map. This tool provides environmental resource managers with the data necessary to make informed decisions for emergencies. The COP is a critical tool used to communicate incident related information to wide range of stakeholders including the public. (b) (U) Homeland Security Information System. The Homeland Security Information System (HSIN) has been designated as the system of record for capturing response documentation. The COML will need to ensure that responders have access to the system and that instructions are in place to ensure that all users understand what information is required to be retained and how to archive that incident information in the HSIN network established for the specific incident.

EXHIBITS: 1 – UAC AND UC ICP STAFFING MATRICES

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EXHIBIT 1 TO ENCLOSURE 3 TO TAB D TO APPENDIX 24 TO ANNEX C TO CCGDSEVEN OPLAN 9770-09 (U) UAC AND UC ICP STAFFING MATRICES (U) 1. (U) UAC ICP Staffing Matrix. The staffing matrix below estimates the number of personnel in the UAC during a Type 1 or Type 2 incident. Each component/section would need their own, distinct spaces which would not have to be separated by floor to ceiling walls with the exception of the Unified Area Command meeting space and any private conference rooms. With a Type 1 or SONS incident the NIC will likely stand up as well.

ICP Component Size of Incident/Level of Activation

Type 2 – Regional (# personnel/shift)

Type 1 – SONS (# personnel/shift)

Unified Area Command UAC Members 6 8 UC Command Staff 8 12 Technical Specialists 3 4 Joint Information Center (JIC)1 50 150 UAC Planning Section UAC PSC/Deputy UAC PSC 4 8 Resource Unit 2 4 Situation Unit 4 8 Documentation Unit 2 4 MTS Recovery Unit 4 6 Technical Specialists 2 3 UAC Logistics Section UAC LSC/Deputy UAC LSC 2 3 Comms Unit 2 4 Facilities Unit 2 4 Technical Specialists 1 2 Finance/Administration Section Finance/Adm Section Chief/Deputy 2 4 Technical Specialists 2 4

Total1 96 (JIC = 50) 228 (JIC =150)

C-24-D-ENCLOSURE 3-EXHIBIT 1-1 UNCLASSIFIED

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2. (U) UC ICP Staffing Matrix. The staffing matrix below estimates the number of personnel in the UC (Offshore Ops) during a Type 1 or Type 2 incident. Each component/section would need their own, distinct spaces which would not have to be separated by floor to ceiling walls with the exception of the Unified Command meeting space and any private conference rooms.

ICP Component Size of Incident/Level of Activation

Type 2 – Regional (# personnel/shift)

Type 1 – SONS (# personnel/shift)

Unified Command 6 10 UC Command Staff 8 12 Technical Specialists 3 6 Operations Section2 Offshore Operations Section Chief/Deputy

2 4

Technical Specialists 3 6 Planning Section PSC/Deputy PSC 2 4 Resource Unit 5 10 Situation Unit 5 10 Documentation Unit 4 8 Demobilization Unit 1 2 Environmental Unit 12 18 MTS Recovery Unit 2 4 Technical Specialists 3 6 Logistics Section LSC/Deputy 2 4 Comms Unit 4 8 Medical Unit 2 4 Food Unit 2 4 Supply Unit 3 6 Vessel Support 2 4 Technical Specialists 2 4 Finance/Administration Section Finance/Adm Section Chief/Deputy 2 4 Time Unit 2 4 Procurement Unit 3 6 Compensation/Claims Unit 8 16


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Cost Unit 2 4 Technical Specialists 2 4

Total3 92 172 1 Dedicated space that is adjacent to but not part of the ICP – these numbers reflect the assumption that this ICP will have significant press focus and attention and will need a correspondingly larger JIC to deal with the increased media attention. 2 Majority of the Operations Section is in the field and is not reflected in these numbers. 3 These numbers assume participation by primarily RP and CG members with lighter participation by State/Local/Tribal stakeholders due to the offshore focus for this ICP.


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ENCLOSURE 4 TO TAB D TO APPENDIX 24 TO ANNEX C TO CCGDSEVEN OPLAN 9770-09 (U) OPERATIONS ORGANIZATION (U) 1. (U) Operations. The Operation Section for this type of response operation will be substantial and will require significant support from the other ICS sections in order to perform its assigned tasking. In a typical response, the Operations Section would grow from the bottom up and expand to meet the needs of the response. Because this plan is designed to address a large offshore spill, and taking into account lessons learned from the DWH incident, there are certain elements of the operations organization that we can anticipate being established. This enclosure builds out and describes the anticipated elements of the initial operations section with the understanding that the final version of the operations section could look substantially different. The staffing of these organizational elements will also be dependent upon the type and number of agencies engaged in the response operations. 2. (U) Offshore Organization. The on-scene maritime response to a major international oil spill in the Florida Straits will be coordinated and executed using a combination of pre-designated ICs (Sector Commanders) and an incident specific IC (Offshore Operations) who all report to the Unified Area Commander (District 7 Commander). The response will be divided into at least two predefined geographic areas including the Offshore Area (outside of State waters) which will be managed by the IC Offshore Operations, and the Nearshore Area (State waters inward) which will be managed by the cognizant Sector. These response operations will be coordinated closely with the D7 Sectors which have potential impacts and are executing their own ACP’s. If span of control starts to be an issue as multiple groups are established the organization can continue to expand using Branches to manage span of control issues. In addition to the Offshore Operations Section an Air Operations Branch will be established to support response operations. The initial organization chart envisioned for this plan is illustrated in Exhibit 1 to this enclosure.

a. (U) Offshore Operations Section Chief (OSC). Operations on the high seas between State water (measured from the U.S. baseline) and the limit set by the UC/UAC (which could include high seas up to the limit of the territorial seas of a foreign country), will be coordinated by the Offshore Operations Section. The Offshore OSC will take daily tasking and make reports to the UC - Offshore Operations.


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The UC - Offshore Operations will promulgate tasking to the maritime response organization via Incident Action Plans (IAPs) and other ICS-compliant forms. b. (U) Source Control Group. The Source Control Group is responsible for all operations geared toward controlling the source of the spill. This could include well capping operations, firefighting operations, salvage operations, or any other activities that are designed to eliminate and/or minimize the discharge. Several different scenarios are possible for efforts led by an Offshore Driller/RP or Foreign Government:

(1) (U) Operations managed from another ICP. These source control operations may be part of an effort that is managed from a different location than where the UC – Offshore Operations organization is located. In that case, there may not be a Source Control Group as part of the UC - Offshore Operations organization. The UC - Offshore Operations would monitor progress with source control operations using their coordination mechanisms or those of the Unified Area Command and use the information to assess the potential impacts of the release on US waters. (2) (U) Operations Managed from UC-Surface Ops ICP. In this case the Source Control Group would be established and their activities/progress monitored by the Offshore OPS and reported back up through the chain of command to keep the UC/UAC/NIC organizations appraised of Source Control operations/progress. If there is a viable RP then the expectation is that the majority of Source Control activities would be carried out by their resources with oversight/direction from the UC – Offshore Operations as necessary.

c. (U) Offshore Skimming Group. The Offshore Skimming Group is responsible for the mechanical recovery of free floating oil encountered in the offshore AOR. Given the expected environmental conditions in this area, and based on lessons learned from the DWH incident, the resources assigned to work in this AOR will typically be larger open water skimming vessels that can safely and effectively operate in this environment and that have sufficient onboard storage or oily water treatment capabilities to operate offshore for extended periods of time. The daily tasking for these assets will be


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based largely on observations from surveillance over flights identifying concentrations of recoverable oil. d. (U) In-Situ Burn (ISB) Group. The In-Situ Burn Group is responsible for conducting ISB operations in the offshore AOR in compliance the RRT/NRT policy in force during the response operation and under the direction of an approved In-Situ Burn Operations Plan. Given the expected environmental conditions in this area, and based on lessons learned from the DWH incident, the resources assigned to work in this AOR will typically be larger vessels that can safely and effectively operate in this environment and have sufficient stores to operate offshore for extended periods of time. The daily tasking for these assets will be based largely on observations from surveillance over flights identifying concentrations of recoverable/burnable oil. e. (U) Surface/Sub-Surface Dispersant Group. The Dispersant Group is responsible for the application of dispersants to the spill in compliance the RRT/NRT policy in force during the response operation and under the direction of an approved Dispersant Operations Plan. This group overseas waterborne (vessel spraying systems), airborne (aerial dispersant delivery systems) dispersant application operations and subsurface dispersant applications, if applicable. In the event that the Group Supervisor determines that it is necessary to split the operations, separate waterborne, aerial, and subsurface dispersant groups may be created. The daily tasking for these assets will be based largely on observations from surveillance over flights and reports from previous aerial dispersant applications identifying concentrations of dispersible oil. f. (U) Special Monitoring of Applied Response Technologies (SMART) Group. The SMART Group is tasked with monitoring and reporting on the efficacy of the Applied Response Technologies (Dispersant applications and In-Situ Burn Operations) that are being utilized in the Offshore AOR. SMART establishes a monitoring system for rapid collection and reporting of real-time, scientifically based information, in order to assist the Unified Command with decision-making during in situ burning or dispersant operations. SMART recommends monitoring methods, equipment, personnel training, and command and control procedures that strike a balance between the operational demand for rapid response and the Unified Command's need for feedback from the field in order to make informed decisions. The SMART Group will be guided


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in their monitoring activities by the last version of the SMART Protocols. g. (U) Decontamination Group. The Decontamination (Decon) Group is responsible for the on-water decon of all vessels in the Offshore AOR. This includes vessels engaged in the response operations as well as vessels that are transiting the response AOR and are in need of decon. Depending on the amount of vessel traffic that is transiting the response AOR there may be a significant number of non-response vessels in need of decon. If that is the case, this Group could be divided into several Groups with some tasked with response vessel decon and some tasked with non-response vessel decon. The method and products used for decon in the offshore environment will have to be used and incorporated into an approved Decontamination Plan.

3. (U) Air Operations Branch. The Air Operations (AirOps) Branch is managed by the AirOps Branch Director. For large, complex responses the AirOps function typically starts out at the Branch Level as depicted in Exhibit 2 to this enclosure to ensure that this type of inherently risky operations are closely managed and provided the proper level of oversight. In addition to the standard Air Operations Organization detailed in reference (i), this plan established additional coordination mechanisms for air traffic in and around the response operation. This coordination is vital given the sheer amount and type of aircraft traffic that was required to support the ongoing response operations in multiple geographic divisions and in support of multiple functional groups. In order to ensure that all aspects of air support are coordinated and that issues regarding the de-confliction of US and other non-US aviation assets, the initial Air Operations will be managed by the District. The District will work closely with Air Operations Branch(es) at the Sector level. Additionally, to address the need for increased coordination of air assets, the Aviation Coordination Center (ACC) concept was established as part of the Air Support Group. The ACC is responsible for overall coordination of air assets assigned to the response operations as well as providing airspace governance typically through the establishment of a Temporary Flight Restriction in the airspace above the response area. The type of support envisioned from the ACC will likely require the assistance of Department of Defense assets to locate, staff, and manage the responsibilities of the ACC.


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EXHIBITS: 1 – OFFSHORE OPERATIONS ORGANIZATION 2 – AIR OPERATIONS ORGANIZATION


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EXHIBIT 1 TO ENCLOSURE 4 TO TAB D TO APPENDIX 24 TO ANNEX C TO CCGDSEVEN OPLAN 9770-09 (U) OFFSHORE OPERATIONS ORGANIZATION (U) 1. (U) Offshore Operations Organization. The typical Offshore Operations Section is depicted below. The initial (0-24 or 24-48 hour) organization might be somewhat different depending on how the incident develops.

VSL DECON GROUP

SMART GROUP

OFFSHORE OPS SECTION CHIEF

AIR OPERATIONS

BRANCH

SOURCE CONTROL

GROUP

OFFSHORE SKIMMING GROUP

ISB GROUP

SURFACE/ SUBSURFACE DISPERSANT

GROUP


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EXHIBIT 2 TO ENCLOSURE 4 TO TAB D TO APPENDIX 24 TO ANNEX C TO CCGDSEVEN OPLAN 9770-09 (U) AIR OPERATIONS ORGANIZATION (U) 1. (U) Air Operations Organization.

AIR OPERATIONSBRANCH DIRECTOR

AIR TACTICAL GROUP

AIR SUPPORT GROUP

Aerial Dispersant Tech Specialist

Aerial Dispersant Task Force

Skimming Support Task Force

ISB Support Task Force

Special Missions Task Force

Aviation Coordination Center


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ENCLOSURE 5 TO TAB D TO APPENDIX 24 TO ANNEX C TO CCGDSEVEN OPLAN 9770-09 (U) SAMPLE DELEGATION OF AUTHORITY (U)

Commander (d) Seventh Coast Guard District

909 S.E. First Ave, Rm 802Miami, FL 33131 Staff Symbol: d Phone: (305) 415-6870 Fax: (305) 415-6848 12981 DD MMM YYYY

MEMORANDUM From: A. B. SEA, RADM, USCG

CGD Seven (d) Reply toAttn of:

To: X. Y. ZEE, CAPT, USCG

Subj: DELEGATION OF AUTHORITY

1. In accordance with the provisions in the National Contingency Plan (NCP) (40 CFR 300), as of [INSERT DATE], I hereby designate you as an Incident Commander (IC) for the [INSERT INCIDENT NAME] Incident. You will perform the duties as described below: a. Area of Responsibility (AOR): [INSERT AOR DESCRIPTION]

b. Authority: As the designated Federal On-Scene Coordinator (FOSC), I am

delegating you the authority to direct and coordinate all response activity within your assigned AOR. This authority allows you to commit resources and expend the funds necessary to conduct response operations consistent with the NCP, other response guidance provided by current Coast Guard directives and publications, and the objectives approved by the Unified Area Command (UAC).

c. Notifications: You shall immediately notify me in the event of any of the following:

A life threatening injury or death of a responder. Issues with assisting or cooperating agencies, or stakeholders that cannot be

resolved at the Unified Command (UC) level.

d. Priorities: [INSERT RESPONSE PRIORITIES ESTABLISHED BY THE UAC]

e. Public Information: [INSERT PUBLIC AFFAIRS GUIDANCE]

f. Incident Evaluation/Updates: During the daily UAC IC/UC meeting, you will provide a status update on response operations in your AOR.

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ENCLOSURE 6 TO TAB D TO APPENDIX 24 TO ANNEX C TO CCGDSEVEN OPLAN 9770-09 (U) OPERATIONAL FRAMEWORK (U) 1. (U) Operational Framework. The IODRP Operational Framework is designed to provide additional detail regarding how the plan will be implemented during the first 96 hours. In addition, Operational Framework describes the initial response actions and details the development of the response organization, deployment of tactical resources, and the staffing necessary to support operations during the first 96 hours. Following the first 96 hours the response organization should have established an effective planning cycle that will drive the organizational development and the associated tactical resource and staffing needs. For each of the time frames a set of initial response objectives are proposed. The Operational Framework includes a general discussion on the approach to cascading personnel and tactical resources to meet the initial response objectives. The Operational Framework also includes a Work Analysis Matrix (ICS-234) for the 0-24, 24-48 and 48-96 hour timeframes to lay out the anticipated activities to meet the initial response objectives. For each timeframe there is a representative response organization and finally a set of proposed staff to fill each critical position during the initial response. 2. (U) D7 (drm) maintains the Operational Framework, along with sample Incident Action Plans (IAPs) and a sample Area Command Operating Guide. These documents are posted in the IODRP folder on the Homeland Security Information Network (HSIN) at https://government.hsin.gov/sites/USCG/D7/default.aspx.


https://government.hsin.gov/sites/USCG/D7/default.aspx

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