Task Force Comments

Pacific States/British Columbia Oil Spill Task Force comments on the U.S. Coast Guard NPRM for MARPOL Amendments.
(pdf file, 426k);

Feb. 14, 2012: The Oil Spill Task Force submits letters to U.S. EPAPHMSAand BOEM petitioning for rulemaking to increase facility Limits of Liability.
Letter to U.S. EPA(pdf file, 430k)Letter to PHMSA(pdf file, 426k)Letter to BOEM(pdf file, 426k);

12/7/11 Comments to the U.S. Coast Guard on their Proposed Rule regarding Inspection of Towing Vessels
All member agencies of the Pacific States/BC Oil Spill Task Force appreciate the U.S. Coast Guard’s efforts to improve the safety of towing vessels operations…
(pdf file, 377k)

Comments on the USCG/EPA Emergency Rule
Temporary Suspension of Certain Oil Spill Response Time Requirements To Support Deepwater Horizon Oil Spill of National Significance (SONS) Response; Emergency Temporary Interim Rule…
(pdf file, 312k)

May 19th, 2010 Task Force Statement to the Interagency Coordinating Committee on Oil Pollution Research (ICCOPR)
The Pacific States/British Columbia Oil Spill Task Force was established in 1989 by a Memorandum of Cooperation (MOC) signed by the Governors of Alaska, Washington, Oregon, and California as well as the Premier of British Columbia…
(pdf file, 224k)

Nov. 30, 2009 comments submitted on the Non-tank Vessel Oil Spill Response Plans and Other Vessel Response Plan Requirements, Notice of Proposed Rulemaking
These comments are submitted on behalf of the Pacific States/British Columbia Oil Spill Task Force, whose membership includes the oil spill regulatory agencies… (pdf file, 364k)

May 1, 2008 comments submitted on the U.S. Coast Guard’s Notice of Proposed Rulemaking regarding Financial Responsibility for Water Pollution (vessels) and OPA 90 Limits of Liability (Vessels and Deepwater Ports)
Our U.S. member agencies’ ability to respond to oil spills relies in part on response partnerships with the U.S. Coast Guard and U.S. EPA, which are funded by the Oil Spill Liability Trust Fund (OSLTF or the Fund)… (pdf file, 108k)

Comments: (USCG- 2004-18939) Pollution Prevention Equipment, Notice of Proposed Rulemaking Request for Comments, published November 3, 2005, Federal Register
The effect of the proposed rulemaking is the incorporation of new International Maritime Organization (IMO) pollution prevention standards that close some loopholes, thus resulting in less pollution… (pdf file, 95k)

Comments: Oil Spill Task Force petitions the US Coast Guard to raise Limits of Liability
I am writing on behalf of the U.S. member agencies of the Pacific States/British Columbia Oil Spill Task Force to petition that the U.S. Coast Guard take rulemaking action to increase the Limits of Liability…
(pdf file, 83k)

Comments: Task Force comments to the US Coast Guard regarding contingency plans for non-tank vessels.
Non-tank Vessel Oil Spill Response Plans, Notice and Request for Comments, published June 24, 2005, Federal Register…
(pdf file, 103k)

Comments: “Strawman Towing Industry Safety System” As amended by the Pacific States/BC Oil Spill Task Force
Goal: Develop and implement a safety system for the towing …
(pdf file, 109k)

Comments: Inspection of Towing Vessels
Should the USCG use the existing standards for towing vessels of 300 GT or larger, or for other inspected vessels? If so, which ones?
(pdf file, 90k)

Comments: Advance Notice of Proposed Rulemaking (ANPRM) to require additional navigation safety measures for Buzzards Bay.
It is our position that U.S. v Locke (529 U.S. 89) clearly affirmed that when a Stateis exercise of its police power is challenged under the Supremacy Clause, the assumption is that the historic police powers of a State are not superseded by Federal law unless there is the clear and manifest purpose of Congress…
(pdf file, 106k)

Comments: Automatic Identification System: Expansion of Carriage Requirements for US Waters (2003)
The Oil Spill Task Force co-chaired a project with the US Coast Guard Pacific Area from1999 to 2002 called the West Coast Offshore Vessel Traffic Risk Management Project.
(pdf file, 104k)

Comments: Mandatory Ballast Water Management Program for US Waters (2003)
Citing data and recommendations from the West Coast Offshore Vessel Traffic Risk Management Project report, we recommend that coastwise vessel transits not be exempted from ballast water management requirements. (pdf file, 134k)

Comments: Removal Equipment Requirements and Alternative Technology (2003)
The Task Force supports the proposal to include dispersant capabilities but objects to proposed offsets in mechanical equipment for investments in ISB, recommends ISB exercises where appropriate, and opposes changes to existing government/private sector agreements for delivery of ADDS packs. (pdf file, 120k)

Comments: Setting the Environmental Agenda of the Coast Guard for Oil Pollution Prevention, Preparedness, and Response in the 21st Century (2003)
The Task Force recommends that the US Coast Guard stress preparedness by emphasizing unannounced drills and performance standards in addition to planning standards. We also recommend that more stringent regulatory standards apply to the tank barge industry, that the USCG work with state oil spill programs to establish a team approach to preventing operational discharges, that the Office of Pipeline Safety focus on aging pipelines, mapping, and improved information regarding causes of past pipeline spills, and that consideration be given to the unique problems associated with offshore platforms. We advocate for continued private sector response capability and comment on the need for improved causal data.
(pdf file, 136k)

Comments: Salvage and Marine Firefighting Requirements (2002)
Task Force comments focus on the draft rule language and also offer general observations and recommendations, including comments regarding the applicability of generic response times, the exclusion of Group V oils, response times and bollard pull requirements for rescue tugs, considerations for dedicated tugs in lieu of compliance waivers, the need for salvage requirements to include non-tank vessels, and the need for the US Coast Guard to coordinate with the Canadian Coast Guard on these regulations.
(pdf file, 100k)

Statement to the US Commission on Ocean Policy (2002)
The Task Force recommends tself as a model for regional coordination on ocean policy issues, and – in the area of oil spill policy – recommends that non-tank vessels be required to have oil spill contingency plans and that the Oil Spill Liability Trust Fund be used for oil spill prevention as well as for response.
(pdf file, 134k)