ALCOAST 387/22 - OCT 2022 GOVERNMENT INITIATED UNANNOUNCED EXERCISE (GIUE) PROGRAM REQUIREMENTS FOR FY23

R 121243Z OCT 22 MID600052357111U
FM COMDT COGARD WASHINGTON DC
TO ALCOAST
BT
UNCLAS
ALCOAST 387/22
SSIC 16000
SUBJ: GOVERNMENT INITIATED UNANNOUNCED EXERCISE (GIUE) PROGRAM
REQUIREMENTS FOR FY23
A. U.S. Coast Guard Marine Environmental Response and Preparedness
Manual, COMDTINST M16000.14A
1. Per REF (A), this ALCOAST establishes the FY23 GIUE requirements
for Sector and Marine Safety Unit (MSU) Captains of the Port (COTP).
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 Preparedness for Response Exercise Program
(PREP) Guidelines, while also taking into account the total number
of candidates available within each COTP Zone. Candidates include
fixed and mobile Marine Transportation Related (MTR) facilities and
tank and non-tank vessels required to have response plans. Units
that wish to adjust their requirements shall 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.
FY23 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 River 4
Sector Virginia 4
a. GIUEs are routinely reported to DHS and COMDT (CG-DCO) as
service-wide performance measure. 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 GIUE requirement shall route a memo to COMDT (CG-MER), through
their District and Area, outlining the reasons the unit could not
complete the required exercises and how they intend to meet the
requirement going forward. GIUE shortfall memos should be received
by COMDT (CG-MER) no later than November 30, 2023. A template is
posted on the COMDT (CG-MER-1) sharepoint page:
(Copy and Paste URL Below into Browser)

https://uscg.sharepoint-mil.us/sites/cgmer/mer1/GIUE/Forms/
AllItems.aspx

b. Requirements for AMPD equipment are defined in
33 C.F.R. Section 154.1045(c), 33 C.F.R. Section 155.1050(d), and
33 C.F.R. Section 155.5050(d). Plan holders do not meet these
requirements by merely staging the equipment onsite. One of the
exercises that plan holders 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.
c. 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 joint GIUEs, the District GIUE
Reporting sharepoint 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 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) sharepoint page for COMDT (CG-MER) reporting purposes.
4. The following was added as a new subparagraph in Chapter 6 of
this Manual: COTPs are encouraged to evaluate Vessel Response Plan
(VRP) holders as candidates for GIUE participation according the
risk-based selection process identified in REF (A). Per REF (A),
tank vessels moored at an MTR facility should not be considered for
a GIUE due to the regulatory requirement that permits vessels to
rely on the MTR facility for AMPD coverage. Non-tank vessels are
only required to have AMPD coverage when the vessel is carrying oil
as cargo in accordance with 33 C.F.R Section 155.5050(p). GIUEs
should generally target tank vessel plan holders over non-tank
vessel plan holders due to the higher risk that they pose to the
environment. COTPs may conduct a GIUE on a tank vessel before,
during, or after lightering operations while at anchorage, in order
to evaluate both notification and Oil Spill Removal Organization
equipment deployment. COTPs should aim to conduct at least one of
their required GIUEs on a VRP. Any vessel that satisfactorily
completes a Coast Guard GIUE is not required to participate in
another Coast Guard GIUE for 36 months. All other vessels approved
under the same plan will receive credit for the COTP Zone in which
the satisfactory GIUE was conducted for 36 months.
a. COMDT (CG-MER) is in the process of creating a VRP GIUE
workbook to outline additional requirements and guidance for
conducting GIUEs on VRPs. The workbook will be available at the
COMDT (CG-MER) SharePoint website by Summer 2023.
b. VRPs and vessel GIUE history can be accessed using VRP
Express. COMDT (CG-MER-1) VRP personnel can provide additional
guidance and training on VRP Express and VRP information upon
request by emailing VRP@uscg.mil or by calling 202-372-1005.
5. These changes will be made to REF (A) which will be released
within the next year.
6. This message will be cancelled on 11 OCT 2023.
7. POC: LT Allison Rychtanek, COMDT (CG-MER-1), 202-372-2248 or
Allison.L.Rychtanek@uscg.mil.
8. Ms. Dana S. Tulis, Director, Emergency Management (CG-5RI),
sends.
9. Internet release is authorized.