CALIFORNIA'S GNOME TRAJECTORY INITIATIVE TODETERMINE BEST ACHIEVABLE PROTECTION FORSENSITIVE SHORELINE RESOURCES FROM VESSELOIL SPILLS

摘要

California has initiated a new approach to create an objectivernstandard and regulate best achievable protection (BAP) for sensitivernshoreline protection from vessel spills. The Oil Pollution Actrn(OPA 90) and California's Lempert-Keene-Seastrand Oil SpillrnPrevention and Response Act (SB 2040) mandate BAP as thernstandard for preparedness and response. BAP poses the criticalrnresponse planning questions: “How much response resourcesrnshould industry provide?” and “In what time frames should thosernresources be deployed?” Prior California regulations intended tornachieve BAP by relying on vessels to identify hazards, trajectories,rnenvironmental consequences, and response resource plans, producedrnless than optimal results in many instances. Though effectivernin theory, this approach resulted in fuzzy consequences andrnvague arrangements for adequate response. Because it was neitherrnclear what sites would be protected (and what response resourcesrnwould be required) nor at what time, and because it was consequentiallyrnnot clear what response resources would be engagedrnto execute protection, drilling C-plans became obtuse. This in turnrnfostered “paper tiger” OSROs and resulted in an uneven playingrnfield for business competitors. In California's new approach,rnOSPR used many of the original concepts to identify BAP by usingrnthe NOAA GNOME oil spill model for generic vessel risk threatsrnfor California ports and along the California coast. This paperrnexplains the theory, steps, and details. As a result of this process,rnBAP has been defined in terms of specific site deployments atrnspecific time intervals and presented in tables in regulation. Thisrnnew approach provides a number of benefits and solutions tornthe difficult issues in the former approach, including a standardrnfor BAP.