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Notes & Reports
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| Task Force Comments & Correspondence | |
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Comments: (USCG- 2004-18939) Pollution Prevention Equipment, Notice of Proposed Rulemaking Request for Comments, published November 3, 2005, Federal Register
read entire article (pdf file 95k) |
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Comments: Oil Spill Task Force petitions the US Coast Guard to raise Limits of Liability
read entire article (pdf file 83k) |
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Comments: Task Force comments to the US Coast Guard regarding
contingency plans for non-tank vessels.
Non-tank Vessel Oil Spill Response Plans, Notice and Request for Comments, published June 24, 2005, Federal Register... read entire article (pdf file 103k) |
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Comments: "Strawman Towing Industry Safety System" As amended by the Pacific States/BC Oil Spill Task Force
Goal: Develop and implement a safety system for the towing ... read entire article (pdf file 109k) |
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Comments: Inspection of Towing Vessels
Should the USCG use the existing standards for towing vessels of 300 GT or larger, or for other inspected vessels? If so, which ones? read entire article (pdf file 90k) |
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Comments: Advance Notice of Proposed Rulemaking (ANPRM) to require additional navigation safety measures for Buzzards Bay.
It is our position that U.S. v Locke (529 U.S. 89) clearly affirmed that when a State’s exercise of its police power is challenged under the Supremacy Clause, the assumption is that the historic police powers of a State are not superseded by Federal law unless there is the clear and manifest purpose of Congress... read entire article (pdf file 106k) |
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Comments: Automatic Identification System: Expansion of Carriage Requirements for US Waters (2003)
The Oil Spill Task Force co-chaired a project with the US Coast Guard Pacific Area from1999 to 2002 called the West Coast Offshore Vessel Traffic Risk Management Project. read entire article (pdf file 104k) |
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Comments: Mandatory Ballast Water Management Program for US Waters (2003)
Citing data and recommendations from the West Coast Offshore Vessel Traffic Risk Management Project report, we recommend that coastwise vessel transits not be exempted from ballast water management requirements. read entire article (pdf file 134k) |
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Comments: Removal Equipment Requirements and Alternative Technology (2003)
The Task Force supports the proposal to include dispersant capabilities but objects to proposed offsets in mechanical equipment for investments in ISB, recommends ISB exercises where appropriate, and opposes changes to existing government/private sector agreements for delivery of ADDS packs. read entire article (pdf file 120k) |
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Comments: Setting the Environmental Agenda of the Coast Guard for Oil Pollution Prevention, Preparedness, and Response in the 21st Century (2003)
The Task Force recommends that the US Coast Guard stress preparedness by emphasizing unannounced drills and performance standards in addition to planning standards. We also recommend that more stringent regulatory standards apply to the tank barge industry, that the USCG work with state oil spill programs to establish a team approach to preventing operational discharges, that the Office of Pipeline Safety focus on aging pipelines, mapping, and improved information regarding causes of past pipeline spills, and that consideration be given to the unique problems associated with offshore platforms. We advocate for continued private sector response capability and comment on the need for improved causal data. read entire article (pdf file 136k) |
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Comments: Salvage and Marine Firefighting Requirements (2002)
Task Force comments focus on the draft rule language and also offer general observations and recommendations, including comments regarding the applicability of generic response times, the exclusion of Group V oils, response times and bollard pull requirements for rescue tugs, considerations for dedicated tugs in lieu of compliance waivers, the need for salvage requirements to include non-tank vessels, and the need for the US Coast Guard to coordinate with the Canadian Coast Guard on these regulations. read entire article (pdf file 100k) |
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Statement to the US Commission on Ocean Policy (2002)
The Task Force recommends itself as a model for regional coordination on ocean policy issues, and - in the area of oil spill policy - recommends that non-tank vessels be required to have oil spill contingency plans and that the Oil Spill Liability Trust Fund be used for oil spill prevention as well as for response. read entire article (pdf file 134k) |
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