ACN 107/20 - SEP 2020 GOVERNMENT INITIATED UNANNOUNCED EXERCISE (GIUE) PROGRAM REQUIREMENTS FOR FY21

ALCOAST COMMANDANT NOTICE                 CANCEL DATE 21 SEP 2021

R 221337 SEP 20
FM COMDT COGARD WASHINGTON DC//CG-5RI//
TO ALCOAST
UNCLAS //N16000//
ACN 107/20
SUBJ:  GOVERNMENT INITIATED UNANNOUNCED EXERCISE (GIUE) PROGRAM REQUIREMENTS FOR FY21
A. U.S. Coast Guard Marine Environmental Response and Preparedness Manual,
COMDTINST M16000.14A
B. COMDT COGARD WASHINGTON DC 031120 AUG 20/ALCOAST 297/20
1. Per REF (A), this ACN establishes the FY21 GIUE requirements for Sector and
Marine Safety Unit (MSU) Captains of the Port (COTP). Per REF (B), Preparedness for
Response Exercise Program (PREP) activities, should be conducted at operational
commander’s discretion with maximum flexibility.
2. GIUEs are a cornerstone of the area oil spill exercise cycle and a key tool for
COTPs to evaluate risk and measure oil spill response preparedness. The Office of
Marine Environmental Response Policy, (CG-MER) continues 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 must route a memo to COMDT (CG-MER), via their chain of
command, with adequate justification to support a reduction.
3. GIUE requirements are published annually. For the purposes of GIUE reporting
requirements, subsequent GIUEs on the same plan holder following an unsuccessful
GIUE do not count towards the COTP’s annual requirement.
FY21 GIUE Requirements:
   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 Christi   4   
   Sector Delaware Bay    4   
   Sector Detroit    2   
   Sector Guam     2   
   Sector Honolulu    3   
   Sector Houston-Galveston   4   
   Sector Jacksonville    4   
   Sector Juneau    4   
   Sector Key West           1 (every 3 years)   
   Sector Lake Michigan    4 
   Sector Long Island Sound   4   
   Sector Los Angeles-Long Beach  4   
   Sector Lower Mississippi River  4   
   Sector Maryland-National Capitol Region 4   
   Sector Miami     4   
   Sector Mobile    4   
   Sector New Orleans    4   
   Sector New York    4   
   Sector North Carolina   2   
   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 Southeastern New England  4   
   Sector Sault Ste. Marie   1   
   Sector St. Petersburg   4   
   Sector Upper Mississippi   4
   Sector Virginia    4   
   a. GIUEs are routinely reported to DHS and COMDT (CG-DCO) as service-wide
performance measures. Units should perform GIUEs throughout the year to facilitate
meeting requirements while also ensuring plan holders are capable of responding in
year-round conditions. Ideally, COTPs required to conduct four GIUEs per FY should
conduct one exercise each quarter. Units that cannot meet their FY21 GIUE
requirement must 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 requirement going forward. GIUE shortfall memos must be received by
COMDT (CG-MER) no later than November 30, 2021. A template is posted on the COMDT
(CG-MER-1) portal page:
(https://cg.portal.uscg.mil/units/cgmer/SitePages/Home.aspx).
   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 non-floating oil response. However, units must 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, adequate amounts of this
equipment should be deployed and observed in an operational state during a GIUE.
Containment boom, along with all necessary equipment for proper deployment, are to
be in place within one hour and skimming devices, including temporary storage,
within two hours. Units should keep in mind that these requirements specify
criteria to be used during the planning process and are not performance standards.
As such, units may grant some time variance based on actual exercise conditions.
   d. Coordinating GIUEs with other agencies benefits both plan holders and
governing agencies. Joint GIUEs are a success story as they achieve the goals of
testing industry, improving interagency relations, and providing training
opportunities, while 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
jointly completed. 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 must 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.
4. These changes will be incorporated into the next revision of REF (A), which
will be released within the next year.
5. POC: MST1 Hugo Gaytan, COMDT (CG-MER-1), 202-372-2265 or Hugo.A.Gaytan@uscg.mil.
6. Released by CAPT Kirsten R. Trego, Acting Director, Emergency Management.
7. Internet release is authorized.