2014 NAMEPA: Winds of Change in Offshore Oil & Gas Regulatory: Coast Guard Introduction CAPT David Nichols US Coast Eighth District Outer Continental Shelf Division

2014 NAMEPA: Winds of Change in Offshore Oil & Gas Environmental Conventions and Regulations: Coast Guard Introduction: New OCS Division on the Eighth District Staff Collaborative Relationship with BSEE

2014 NAMEPA: Winds of Change in Offshore Oil & Gas Environmental Conventions and Regulations: Coast Guard DEEPWATER HORIZON lessons learned: Commandants Final Action Memo Prevention is key to environmental protection One Gulf, One Standard Regulatory and policy changes

2014 NAMEPA: Winds of Change in Offshore Oil & Gas Regulations: Coast Guard Active 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: 1.Marine Crew training could prevent or mitigate environmental incidents 2.Marine crew should be capable of mitigating/responding to blowouts/fires should safety systems or procedures fail 3.Coast Guard checks compliance during exams

2014 NAMEPA: Winds of Change in Offshore Oil & Gas Regulations: Coast Guard Voluntary Guidance: Fixed Firefighting DWH Investigation CG Final Action: 2D Notice of Interim Voluntary Guidance (77 FR 70172) Key Points: 1.Consideration should be given to automatic operation of a fixed deluge system on drill floor and adjacent areas upon gas detection 2.Could prevent ignition and potential loss of well control

2014 NAMEPA: Winds of Change in Offshore Oil & Gas Regulations: Coast Guard Guidance & 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: 1.Would provide uniformity for all MODUs operating on the U.S. OCS 2.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

2014 NAMEPA: Winds of Change in Offshore Oil & Gas Regulatory Policy Needs: Coast Guard Guidance: 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: 1.Position Loss on DP Vessel is environmental concern 2.During Critical OCS Activity; environmental concern greater 3.Recommends use of Marine Technology Guidelines

2014 NAMEPA: Winds of Change in Offshore Oil & Gas Regulatory Policy Needs: Coast Guard Proposed 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: 1.Harmonizes casualty reporting requirements for U.S. and foreign operators on the OCS 2.Enhances knowledge of potential problem areas so that a proactive approach can be taken 3.Voluntary reporting for dynamically positioned MODUs not currently required to report

2014 NAMEPA: Winds of Change in Offshore Oil & Gas 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: 1.How should a vessel SMS interface with an Operators SEMS plan? 2.How should authority over vessel interface with authority over OCS activity?

2014 NAMEPA: Winds of Change in Offshore Oil & Gas Regulatory Policy Needs: Coast Guard Wrap up Questions?