HWCG supports regulations that provide clarity on the use of proven response tactics by providing the authority to decision makers responsible for source control. We believe regulations should be revised to allow the use of approved subsea dispersants on a temporary basis (i.e., “Temporary Pre-Approval”), with the decision-maker being the Federal On-Scene Coordinator “FOSC”. The goal of Temporary Pre-Approval is to allow the FOSC to grant approval to the Operator, who is held totally responsible for the incident response, to use subsea dispersants immediately upon arrival at the incident site for a maximum of 5-days in order to expedite capping operations needed to control the source. Temporary Pre-Approval would eliminate potential political interference from the decision process and help ensure the source control mission is fulfilled in a timely manner. During the temporary approval period, the Authorization Request and plans required for dispersant use can be approved through normal channels.
Please share with your friends and colleagues, and state and federal legislators, in order to help maintain the GOM as a superior province delivering America’s Energy and Seafood Security by improving regulations to assure offshore deepwater responses are efficient, effective, and aligned with America's National Response Priorities (§40CFR300.317): 1) Safety of human life, 2) Securing the source, and 3) Use all necessary containment and removal tactics.