Providing coverage of Alaska and northern Canada's oil and gas industry
February 2018

Vol. 23, No.8 Week of February 25, 2018

Simplifying the spill response planning

The state and federal governments are reorganizing regional contingency plans to simplify the plan organization and maintenance

Alan Bailey

Petroleum News

The federal and state governments are engaged in a project to reorganize and simplify the arrangements for maintaining government oil spill contingency plans for Alaska, officials told the Alaska Forum on the Environment on Feb. 15.

The agencies are “trying to streamline the framework of government spill response plans in Alaska and bring them into closer consistency with national and agency-level laws and regulations,” Nick Knowles, the Environmental Protection Agency’s Alaska area planner, told conference attendees.

Although any entity handling oil must maintain an oil spill contingency plan, backed up by the availability of appropriate spill response resources, the state and federal governments also maintain plans. The government plans help ensure that there are adequate arrangements in place for dealing with an oil spill, that adequate response resources are available and that there are specific tactics for dealing with spilled oil, taking into account the concerns of communities that may be impacted.

The government plans provide a framework within which individual entity contingency plans can be designed, ensuring that the various plans meet government and community requirements.

Goes back to Exxon Valdez

The current government planning system dates back to the period following the Exxon Valdez oil spill, when over a period of a few years the federal government and the state of Alaska engaged in parallel efforts to create spill response plans. As a consequence of working independently, with Alaska moving ahead first, the two government organizations came up with two different plan frameworks. But the federal framework drove response planning arrangements in states other than Alaska. The federal system is driven top-down, from a national contingency plan through regional and area contingency plans within the states.

Those differences between Alaska’s plans and plans elsewhere persist. For example, although the state, in common with the federal government, uses a set of procedures and standards under what is called the incident command system for oil spill response, the state plan documents do not conform to the ICS standard as employed in the national plan, Knowles commented.

Moreover, Alaska now has a unified plan for the whole state and a set of 10 subarea plans, under the unified plan, for different parts of the state. The unified plan contains statewide policies and response procedures, while each subarea plan contains information specific to a subarea. There is a regional response team that oversees maintenance of the unified plan and subarea plans, while each subarea plan has an area committee that is pulled together periodically for plan updates. The concept is that communities provide input to the plans through the subarea committees.

It is, however, difficult to keep all the Alaska plans updated when, for example, the federal government issues new planning directives, especially given the number of subarea plans and the fact that an ad-hoc committee must be formed to update each plan. Policy changes can arise, for example, as a result of incidents such as a terrorist attack or a major spill such as the Deepwater Horizon disaster, Knowles said.

Restructuring the Alaska system

The envisaged reforms to the system involve reconstituting the state’s unified plan as an Alaska regional plan and, instead of having 10 subarea plans, there would be just four area plans. Four standing committees, rather than the previous 10 ad-hoc committees, will maintain the area plans, thus enabling plans to be updated annually, rather than at the multiyear intervals that result from the current arrangements. And the rejigged plans would have a format consistent with that of the national contingency plan and those of other states, thus simplifying the ability of out-of-state personnel to work with the Alaska documentation.

The four planning areas in Alaska would consist of three offshore areas and the entire Alaska landmass, more than 1,000 yards inland from the shore. The three offshore areas, Southeast Alaska, Prince William Sound, and western and Arctic Alaska, would generally correspond to the U.S. Coast Guard’s captain of the port regions: The Coast Guard provides federal oversight for offshore spill responses, while the Environmental Protection Agency is responsible for onshore federal oversight. In the event of a spill, the appropriate federal agency would participate in a unified command for the response, together with the state, any appropriate local government entity and the party responsible for the spill.

Underneath the area plans come more specific plans, such as industry contingency plans and plans for protecting specific geographic locations - the area plans can help ensure consistency between these various specific plans, Knowles explained.

The action plan

Shannon Miller, interagency coordinator from the Alaska Department of Environmental Conservation, said that the EPA, the Coast Guard and DEC have worked together to build a plan of action for transitioning to the new contingency plan arrangements.

A key step will be the establishment of the four committees for the Alaska planning areas, to maintain the new area plans. The plan rework will involve recasting information from the existing plans into the new plan format. And each offshore area plan will have an assigned on-scene commander from the Coast Guard, she said. Once the new plans are adopted, the old plans will become redundant.

A statewide planning committee, which has already met, is coordinating the planning effort, ensuring plan consistency.

DEC is resource constrained but wants to see the new Alaska regional plan and four area plans written and signed off by the coming fall. The intent is to have the committee for the western Alaska and Arctic area meet in fall, and then have the other committees meet by the fall of 2019, Miller said.

Role of the committees

Lt. Cmdr. Matt Hobbie, chief of planning and resource readiness for the U.S. Coast Guard sector Anchorage, commented that the expectation is that the new area committees will provide the flexibility to deal with Alaska spill response issues. The committees, in addition to appointed standing members from federal, state, local and tribal governments, will have members at large representing entities such as the oil industry, regional citizens’ advisory councils, oil spill response organizations and non-government organizations. The standing committees will meet at least twice per year, to consider plan updates based on new knowledge, and will be expected to produce annual reports and updates, Hobbie said.

Given the very large geographic scale of some of the new planning areas, the group working on the Alaska contingency plan reorganization did consider the possibility of establishing more than one standing committee for some areas. However, the group determined that this would be impractical, given the limited resources available to conduct the substantial work and reporting that each standing committee has to carry out, Hobbie said.

However, although there will only be one plan and one standing committee for each planning area, a standing committee could set up subcommittees or an ad-hoc committee to address specific issues in an area, he said.

Flexibility to adapt

Ultimately, the standing committees, with their focus on improving the area contingency plans, will become the most important component of the system, Hobbie said. The expectation is that the new committee structure will be able to more rapidly and effectively accommodate the changing needs for response capabilities in Alaska than is possible under the current arrangements. But the effectiveness of the committees will depend on help, especially help from the communities that the contingency plans are designed to protect, he said.

And the speakers emphasized their desire to conduct outreach, to communicate with communities about the planning work.

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