NOAA NATIONAL MARINE SANCTUARIES AS RESOURCE TRUSTEES IN THE UNIFIED COMMAND: GOOD OR BAD?

摘要

The National Oceanic and Atmospheric Administration (NOAA) is a federal trustee within the National Contingency Plan (NCP) in addition to providing scientific and technical support to the Incident Command System (ICS) during a response. NOAA is also the home of the National Marine Sanctuary Program (NMSP), a system of 14 marine protected areas that encompass 150,000 square miles of coastal and oceanic waters. NOAA is increasing its capacity for addressing a significant incident through participating in and leading spill response exercises. One of the most intense aspects of those experiences is often the discussion of the role of NOAA as a trustee and whether they should be part of the Unified Command (UC). While the NCP outlines the expectations of Regional Response Team (RRT) members from the Department of the Interior and the Department of Commerce (NOAA), it provides the Federal On Scene Coordinator (FOSC) considerable flexibility in determining whether to include trustees within the UC or working with the Liaison or through the Environmental , Unit. A recent Technical Assistance Document from the National Response Team speaks directly to this issue and provides RRT's more specific guidance. There are some RRT's that feel strongly that the only trustee in the UC should be the states. NOAA and the DOI believe that they should be afforded the same considerations in the marine and coastal environment as trustees or landowners in the terrestrial environment. Both the Safe Sanctuaries 2005 in Florida and the Safe Seas 2006 in California provided a forum for dialogue on this issue. In both instances, the FOSC did engage the trustees in the UC. It is not always necessary or appropriate for NOAA to participate as a member of the UC. In some situations it could be more effective to participate in other capacities within the ICS and NOAA may not be the trustee with the most significant resources at risk. When participating in a UC, it is incumbent upon the NOAA representative to work with other members of the UC to manage the response under a single, collaborative approach.