ACN 104/18 - SEP 2018 GOVERNMENT INITIATED UNANNOUNCED EXERCISE (GIUE) PROGRAM REQUIREMENTS FOR FY19

united states coast guard

ALCOAST COMMANDANT NOTICE                                          CANCEL DATE 24 SEP 2019


R 250803 SEP 18
FM COMDT COGARD WASHINGTON DC//CG-5RI//
TO ALCOAST
UNCLAS //N16000//
ACN 104/18
SUBJ: GOVERNMENT INITIATED UNANNOUNCED EXERCISE (GIUE) PROGRAM REQUIREMENTS FOR FY19
A. U.S. Coast Guard Marine Environmental Response and Preparedness Manual,
COMDTINST M16000.14 (series)
1. In 2015, the Office of Marine Environmental Response Policy, Commandant (CG-MER)
reinvigorated the Coast Guard GIUE program by releasing new GIUE policy which has
since been incorporated into REF (A). This policy established consistent exercise
design, execution and documentation across the Coast Guard. It also defined the
number of GIUEs required at each unit. This ACN establishes the FY19 GIUE
requirements for Sector and Marine Safety Unit (MSU) Captains of the Port (COTP).
2. As stated in REF (A), GIUEs are a cornerstone of the area oil spill exercise
cycle and a key tool for COTPs to evaluate oil spill response preparedness.
COMDT (CG-MER) will continue to require the maximum number of GIUEs permitted
under regulation and the National Preparedness for Response Exercise Program (PREP)
Guidelines, while also taking into account the number of candidates available
within each COTP Zone. Units that wish to adjust their requirements should route
a memo to COMDT (CG-MER), via their chain of command, with adequate justification
to support a reduction. GIUE requirements are published annually.
FY19 GIUE Targets:
MSU Duluth 1
MSU Houma 4
MSU Pittsburgh 4
MSU Port Arthur 4
MSU Savannah 2
MSU Valdez 1
Sector Anchorage 4
Sector Buffalo 2
Sector Boston 4
Sector Charleston 2
Sector Columbia River 4
Sector Corpus 4
Sector Delaware Bay 4
Sector Detroit 2
Sector Guam 2
Sector Hampton Roads 4
Sector Honolulu 4
Sector Houston-Galveston 4
Sector Jacksonville 4
Sector Juneau 4
Sector Key West 1 every 3 years
Sector Lake Michigan 4
Sector Long Island 4
Sector Los Angeles-Long Beach 4
Sector Lower Mississippi 4
Sector Maryland-National Capitol Region 4
Sector Miami 4
Sector Mobile 4
Sector New Orleans 4
Sector New York 4
Sector North Carolina 4
Sector Northern New England 4
Sector Ohio Valley 4
Sector Puget Sound 4
Sector San Diego 2
Sector San Francisco 4
Sector San Juan 4
Sector Southeast New England 4
Sector Sault Ste. Marie 1
Sector St. Petersburg 4
Sector Upper Mississippi 4
    A. GIUEs (conducted and successfully completed) are routinely reported to DHS
and COMDT (CG-DCO) as service-wide performance measures. It is unsatisfactory for
units not to meet their GIUE requirements. Units should perform GIUEs throughout
the year. Ideally, COTPs required to conduct four GIUEs per FY should conduct one
exercise each quarter. This facilitates meeting minimum requirements while also
ensuring plan holders are capable of responding in year-round conditions. Units
that fail to meet their FY19 GIUE target shall route a memo to COMDT (CG-MER),
through their District and Area, outlining why they did not complete the required
exercises and how they intend to meet the requirements going forward. GIUE
shortfall memos should be received by COMDT (CG-MER) within 60 days of the end
of each FY. A template is posted on the COMDT (CG-MER-1) portal page.
    B. One of the key benefits of the GIUE program is the ability for units to
identify their biggest risk and apply a structured average most probable discharge
(AMPD) exercise to analyze the plan holder’s capabilities. Some units have expressed
interest in performing GIUEs on Group V petroleum oil facilities due to the
complexity of a sinking oil response. COMDT (CG-MER) is establishing a workgroup to
assess the feasibility and policy for these GIUEs. Unit shall not test a plan
holder’s ability to respond to a Group V oil until new policy is published.
    C. Requirements for AMPD equipment are defined in 33 C.F.R. § 154.1045(c) and
33 C.F.R. § 155.1050(d). Plan holders do not meet these requirements by merely staging
the equipment onsite. One of the exercises that plan holder’s receive credit for is
an equipment deployment exercise. Therefore, this equipment should be observed in
an operational state. Containment boom, along with all necessary equipment for proper
deployment, are to be in place within one hour and skimming device, including
temporary storage, within two hours. Keep in mind that these are planning standards
and that units may grant some time variance.
    D. Coordinating GIUEs with other agencies benefits both plan holders and governing
agencies alike. Joint GIUEs are a success story as they achieve the goals of testing
industry, improve interagency relations and training opportunities, while
concurrently reducing industry’s exercise burden. It is a priority for Incident
Management Divisions (IMD) to conduct joint exercises when possible. To accurately
capture the frequency of the joint GIUEs, the District GIUE Reporting portal page
has been updated to include a column to indicate if the exercise was joint or not.
To facilitate joint GIUEs when partnering agencies have lengthy documentation
procedures, units may delay issuing the results letter to the plan holder when
requested by the other exercise evaluating agencies. Normally, Federal On-Scene
Coordinators (FOSC) have 10 business days to complete the documentation, but at the
request of another agency, the FOSC may coordinate to issue the documentation at
similar times. When this occurs, the FOSC shall inform their District within 10 days
of the completed GIUE stating the details, to include the exercise results and
reason for the delay. This allows the District to log the completed GIUE in the
COMDT (CG-MER-1) portal page for COMDT (CG-MER) reporting purposes.
3. These changes will be incorporated into the next revision of REF (A), which
will be released within the next year.
4. POC: MST1 Hugo Gaytan, COMDT (CG-MER-1), 202-372-2265 or hugo.a.gaytan@uscg.mil.
5. Released by Ms. Dana S. Tulis, Director of Incident Management and
Preparedness Policy.
6. Internet release authorized.