Regulatory: Coast Guard Introduction

1. Regulatory: Coast GuardIntroduction CAPT David Nichols US Coast Eighth District Outer Continental Shelf Division

2. Environmental Conventions and Regulations: Coast Guard • Introduction: • New OCS Division on the Eighth District Staff • Collaborative Relationship with BSEE

3. Environmental Conventions and Regulations: Coast Guard • DEEPWATER HORIZON lessons learned: • Commandant’s Final Action Memo • Prevention is key to environmental protection • “One Gulf, One Standard” • Regulatory and policy changes

4. Regulations: Coast GuardActive Pre-Rule: OCS Training • DWH Investigation CG Final Action: 1B, 1C, 3E , 3F • BSEE/USCG MOA OCS-08 on (MODUs) signed 4 June 2013 • Key Points: • Marine Crew training could prevent or mitigate environmental incidents • Marine crew should be capable of mitigating/responding to blowouts/fires should safety systems or procedures fail • Coast Guard checks compliance during exams

5. Regulations: Coast GuardVoluntary Guidance: Fixed Firefighting • DWH Investigation CG Final Action: 2D • Notice of Interim Voluntary Guidance (77 FR 70172) • Key Points: • Consideration should be given to automatic operation of a fixed deluge system on drill floor and adjacent areas upon gas detection • Could prevent ignition and potential loss of well control

6. Regulations: Coast GuardGuidance & Proposed Rule: Electrical Equipment • DWH Investigation CG Final Action: 1A • Notice of Policy (77 FR 71607) • Notice of Proposed Rulemaking (78 FR 37760) • Key Points: • Would provide uniformity for all MODU’s operating on the U.S. OCS • Would require that certification of electrical equipment intended for use in hazardous areas be test by a competent independent lab IAW 2009 IMO MODU Code

7. Regulatory Policy Needs: Coast GuardGuidance: Dynamic Positioning • DWH Investigation CG Final Action: 1B, 1C, 3E , 3F • NOSAC Task Statements (2010, 2013) • Notice of Interim Voluntary Guidance (77 FR 62247) • Key Points: • Position Loss on DP Vessel is environmental concern • During “Critical OCS Activity;” environmental concern greater • Recommends use of Marine Technology Guidelines

8. Regulatory Policy Needs: Coast GuardProposed Rule: Casualty Reporting • 33 CFR Subchapter N – OCS Activities • 46 CFR Part 4 – Navigable U.S. waters • Notice of Proposed Rulemaking (79 FR 1780) • Voluntary Reporting policy (CG-5PC letter of June 19, 2013) • Key Points: • Harmonizes casualty reporting requirements for U.S. and foreign operators on the OCS • Enhances knowledge of potential problem areas so that a proactive approach can be taken • Voluntary reporting for dynamically positioned MODU’s not currently required to report

9. Regulatory Policy Needs: Coast Guard Active Pre-Rule: SMS On OCS vessels • Attention to safety procedures/systems prevents environmental incidents • DWH Investigation CG Final Action: 1A, 5D, 5I, 5K, 5L • BSEE/USCG MOA OCS-07 on SEMS and SMS signed 30 April 2013 • Advanced Notice of Proposed Rulemaking (78 FR 55230) • Key points: • How should a vessel SMS interface with an Operators SEMS plan? • How should authority over vessel interface with authority over OCS activity?

10. Regulatory Policy Needs: Coast GuardWrap up Questions?