On Scene 

Coordinator Report

Deepwater Horizon 

Oil Spill

Submitted to the 

National Response Team 

September 2011
We would like to thank the agencies listed below and all of the agencies, companies, 

organizations, and individuals that contributed to the Deepwater Horizon response efforts.
The Man in the Arena

It is not the critic who counts; not the man who points 

out how the strong man stumbles, or where the doer of 

deeds could have done them better. The credit belongs to 

the man who is actually in the arena, whose face is marred 

by dust and sweat and blood; who strives valiantly; who errs, 

who comes short again and again, because there is no eff ort 

without error and shortcoming; but who does actually strive 

to do the deeds; who knows great enthusiasms, the great 

devotions; who spends himself in a worthy cause; who at the 

best knows in the end the triumph of high achievement, and 

who at the worst, if he fails, at least fails while daring greatly, 

so that his place shall never be with those cold and timid 

souls who neither know victory nor defeat.

 Theodore Roosevelt 

 April 23, 1910
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Executive Summary

v

The purpose of this report is to document the 

response to the oil spill that resulted from the 

explosion on the Deepwater Horizon mobile 

offshore drilling unit on April 20, 2010. 

On November 18, 2010, the National Response Team 

(NRT) requested submission of an On-Scene Coordinator (OSC) Report for the Deepwater Horizon

spill to the NRT Response Committee, pursuant to 

the National Contingency Plan (NCP). The NRT’s 

request listed 33 specifi c topics be addressed in the 

report. The list of specifi c topics addressed in the 

report expanded to 56 to cover additional focus areas 

of the Federal On-Scene Coordinators (FOSCs). 

Organization of the Report

The NCP directs that OSC Report record the situation as it developed, the actions taken, the resources 

committed, and the challenges encountered (40 CFR 

300.165(b)). This report consists of ten chapters that 

generally apply these themes to the 56 topics. The 

fi rst of the NCP requirements is to account for the 

situation as it developed. Chapter 1 is a brief summary of signifi cant events. At the end of the report 

is a much more detailed and comprehensive daily 

chronology of events to address the situation as it 

developed. Beginning with Chapter 2, the report is 

organized by the Incident Command System (ICS) 

structure: Command (Chapter 2), Operations (Chapter 3), Planning (Chapter 5), Logistics (Chapter 6), 

and Finance (Chapter 7). There is a separate chapter 

on Health and Safety (Chapter 4) although health and 

safety is usually within the Command Section under 

ICS. The Safety program was a signifi cant FOSC 

focus. Given the scale of the response, and unique 

public health aspects, it merited a chapter of its own. 

Three other chapters that could have been included 

under existing ICS based chapters were covered in 

separate chapters. Natural Resources and Wildlife 

(Chapter 8) normally falls within the operations section, yet there was such a signifi cant component of 

the response dealing with these issues that the subject stands on its own. This chapter also includes a 

discussion of Section 106 of the National Historic 

Preservation Act compliance, normally found under 

the Planning Section, as trustee agencies central to 

wildlife activities were also critical to historic preservation efforts. Government Personnel staffi ng is 

addressed in Chapter 9 to capture the challenges in 

sustaining the requisite number of trained personnel 

for a response of this scope and duration. Finally, 

Communications (Chapter 10) includes knowledge 

management and communication with elected offi -

cials, the public, and the media, which were a key 

part of the response given the national and global 

level of interest in the disaster. 

The report relies heavily on the written documentary 

record and the experiences of subject matter experts 

directly involved in the response. More than 200 

people participating in the response, including Coast 

Guard members, representatives of other federal and 

state agencies, and private organizations, provided 

written input to be used in this report. Where needed, 

the Report Writing Team, consisting of the Deputy 

FOSC, four other Coast Guard offi cers, a petty offi -

cer, and three contract technical writers and design 

specialists, provided research assistance in extracting 

archived and response generated documents stored 

on the Homeland Security Information Network, the 

dedicated response server established by the Coast 

Guard, and federal government websites such as 

RestoreTheGulf.gov. 

The report covers the period of April 20, 2010, the 

day the explosion took place on the Deepwater Horizon mobile offshore drilling unit, through March 

1, 2011. Although the detailed chronology stops at 

January 31, 2011 and shoreline clean-up operations 

continue, this report does not capture operations 

occurring since March 1. 

The FOSC is responsible for directing and coordinating actions to remove the oil from the environment. 

Restoration and recovery action taken to repair damage caused by the spill are outside the scope of the 

FOSC’s responsibility and thus are not covered by 

this report. 

Chapter 1 and the Chronology: Situation as 

it Developed

The report addresses the requirement to describe 

the situation as it developed in two parts. Chapter 1 

contains a short timeline of the spill and describes the 

efforts to contain and fi nally seal the Macondo well. 

Appendix I provides a much more detailed chronology, listing major response activities from April 20, 

2010 through the end of January 2011. The magnitude of the spill cleanup can be surmised to a certain 

degree by the number of resources committed, and its 

impacts. Oil fl owed from the well for 87 days. Two 

drilling ships, numerous oil containment vessels, 

and a fl otilla of support vessels were deployed to 

control the source of the well, while 835 skimmers 

and approximately 9000 vessels were involved in 
vi

Executive Summary

the cleanup. On the single most demanding day of 

the response, over 6000 vessels, 82 helicopters and 

20 fi xed wing aircraft and over 47,849 personnel/

responders were assigned; 88,522 square miles of 

fi sheries were closed; 168 visibly oiled wildlife were 

collected; 3,795,985 feet of containment boom was 

deployed; 26 controlled in situ burns were conducted, 

burning 59,550 barrels of oil; 181 miles of shoreline 

were heavily to moderately oiled; 68,530 gallons 

(1632 barrels) of dispersant were applied, and 27,097 

barrels of oil were recovered.

Chapter 2: Command and Control

The states viewed the spill as a disaster, declared 

states of emergency, and activated their emergency 

response agencies. Each of the Gulf Coast states and 

local governments were accustomed to the Stafford 

Act process. Emergencies that fall under the Stafford 

Act give state and local governments a lead role in 

organizing response, paid largely, but not entirely, by 

the federal government. The NCP that governs oil 

spill response, however, gives the federal government 

lead, impacted states a role in the unifi ed command, 

and the Responsible Party (RP) a role in cleaning up 

the spill in terms of funding and participation in the 

unifi ed command. The difference between these two 

frameworks was not well known or understood outside of the spill response community, and contributed 

to challenges and delays in the integration between 

federal, state, and local response efforts. 

The FOSC is the lead federal offi cial for oil removal 

and response operations in accordance with the NCP. 

The role of the National Incident Commander (NIC) 

is described from the perspective of the FOSC and 

the working relationship between the two. The working relationship between the NIC and the FOSC is 

designed to unburden the FOSC in the event of a 

Spill of National Signifi cance (SONS). The SONS 

exercise process prepared the Coast Guard for the 

establishment of the National Incident Command, 

provided an understanding of the role of the NIC, 

and how the NIC supported the FOSC. From the 

FOSC perspective, the NIC stand up and assumption 

of responsibilities was very smooth, although there 

was constant readjustment of roles as the response 

progressed. 

An exercise environment, however, is not the same 

as a bona fi de Spill of National Signifi cance. Actual 

establishment of an NIC was unprecedented. The 

exercise process did not emphasize the federal governance structure for oil spill response. The NCP 

process was not familiar to the impacted communities. Through repeated natural disasters and 

emergency declarations, they were accustomed to a 

state-centric response organization as outlined under 

the Stafford Act. The NCP also did not address all of 

the key issues that came to the forefront during the 

response. The NIC, interacting with cabinet-level 

offi cials, was well positioned to adjudicate some 

of these issues. An example was seafood sampling 

and testing to ensure the safety of Gulf of Mexico 

seafood. 

The FOSC served as the Unifi ed Area Commander 

in accordance with established incident command 

doctrine, and under the Unifi ed Area Command 

(UAC) eventually there were fi ve Incident Command Posts (ICPs): Houston, Galveston, Houma, 

Mobile, and Miami. Houston focused on source 

control, while Galveston and Miami remained relatively small operations as the impact from the spill 

on their operating areas was limited. Houma and 

Mobile, however, became very large incident command posts, with many, large geographic branches 

reporting to them. The branches became so large that 

they became incident management teams of their 

own, and the sheer scale of the operation stretched 

existing ICS doctrine. 

The size of the operation, duration of the spill, and 

public and political interest in the spill impacted 

the operation of the incident command structure in 

other ways. Regional Response Teams (RRTs), and 

the NRT assist the FOSC during the course of large 

spills. Because of the involvement of senior offi cials 

in each participating agency and the state and federal 

governments the NRT role was effectively subsumed 

into a NIC staff element called the Interagency Solutions Group. The RRTs also functioned in a manner different from previous spills due to the need to 

coordinate agency positions with very senior agency 

offi cials. State and local participation also differed, 

with senior state offi cials rather than the state spill 

response agencies often participating in the decision 

making process. The senior state offi cials and local 

offi cials did not fully integrate into the unifi ed command construct in each case. 

Chapter 3: Operations

Response operations took place in four zones: at the 

source of the spill, offshore, near shore, and in shore. 

At the source, the drilling rigs and remotely operated vehicles necessary for deep water drilling were 

the only means of accessing the well. Offshore, as 
Executive Summary

vii

close to the source as possible, the response focused 

on removal of the oil. Key to these operations was 

large skimmers and in situ burn task forces. Skimmers, storage for the oil recovered by the skimmers, and fi re boom were key resources. When oil 

could not be removed through these means due to 

environmental conditions (such as sea conditions), 

aerial application of dispersants was used. Near shore 

operations focused on skimming and the use of boom 

to protect sensitive areas, and later the protection of 

as much of the shoreline as possible. Obtaining as 

much boom as possible was a central concern of near 

shore operations. In shore operations used barriers 

such as Hesco Baskets to minimize shoreline impact. 

Once oil reached the shore, the long, arduous, labor 

intensive process of shoreline cleanup began. After 

the well was capped shoreline cleanup became the 

focus of continued response operations. 

A key to effective response was understanding the oil. 

The Macondo well released Louisiana sweet crude 

oil. The term “sweet” refers to the low amount of 

sulfur. “Light” indicates the oil has many lighter ends, 

which evaporate quickly. Thus the oil was not as 

persistent as some other forms of crude oil, making 

it easier to remove. 

Source Control. In any oil spill response, one of 

the fi rst priorities is to secure the source. The NIC 

and FOSC directly participated in the efforts to stop 

and contain the oil fl owing from the Macondo well, 

ensuring federal government involvement in the 

decision-making process for source control efforts 

in Houston. Next, the National Oceanic and Atmospheric Administration (NOAA) and other agencies 

applied many modeling techniques to provide the 

FOSC with information on oil spill trajectory to aid 

in planning response operations, and the fl ow rate 

to estimate the amount being spilled. Those agencies also participated in the development of the Oil 

Budget, to produce a scientifi c estimate of the fate 

of the oil spilled. The source control effort was a 

whole-of-government and industry response. The 

Department of Energy (DOE), Department of Interior (DOI), U.S. Geological Survey (USGS), and 

Coast Guard engaged extensively with the RP in 

these efforts. Other oil companies, including Shell 

and Exxon-Mobil, assisted with source control strategy discussions. 

Dispersants. Dispersant was applied during this spill 

in three ways: 

• subsea, at the source of the spill, 

• on the surface, by vessels and support ships 

working at the well site near the drill rigs in 

order to control Volatile Organic Compounds 

(VOCs) that posed a health and safety threat to 

those crews, and

• aerially, to disperse oil slicks more than fi ve 

nautical miles from the source control effort. 

On May 26, 2010, after discussions with the Environmental Protection Agency (EPA), the FOSC issued 

Addendum III to existing directives on dispersants 

that required a signifi cant reduction in dispersant use. 

The FOSC continued to approve the use of dispersants applied sub-sea, and on the surface by vessels 

for the control of VOCs in the vicinity of vessels at 

well site. Aerial applications were pre-authorized by 

the RRT, and approved by the FOSC on days when 

weather and sea conditions limited the effectiveness of skimming or in situ burns, or when slicks 

were headed toward land and alternative response 

methods would not be able to combat the slick in 

time. Surface application took place well away from 

shore. Dispersants effectiveness decreases dramatically within hours of the oil being released. Thus 

dispersant application near shore would have been 

ineffective, as the oil would then have been on the 

surface for days. Additionally, no dispersant was 

applied within 3 miles of shore in accordance with 

the existing preapproval criteria. 

In Situ Burning. Signifi cant in situ burning (411) 

operations were conducted during the course of the 

response that removed an estimated 250,000 barrels of oil. The in situ burn operation eventually 

grew to include three task forces each consisting of 

a three vessel ignition team, two task force vessels, 

one supply vessel, a safety team, and fi ve fi re boom 

teams. The task forces were directed to targets by 

spotter aircraft. There was also a complex process to 

make sure skimming teams, dispersant operations, 

and in situ burn teams stayed clear of one another. 

There were no injuries as a result of in situ burns 

and air quality testing near the burns was conducted 

to ensure worker safety. 

Skimming. Skimming operations were divided into 

several different types: 

• Offshore near the spill source (three nautical 

miles in the vicinity of the source and the leading edge of any observed oil slicks), 

• Near shore (within three nautical miles), and 

• Inshore at beaches, bays, and marshes. 
viii

Executive Summary

Different types of skimming equipment were needed 

depending on location, sea conditions, and type of 

operation. Oil skimmers were the most critical oil 

removal resource at the peak of the response. 

Oil coverage was not uniform. Rather than covering large areas of the open ocean as was perceived, 

recoverable oil away from surface waters just above 

the source could be found only in a very small percentage of the impacted northern Gulf of Mexico’s 

surface waters. Offshore skimming required aircraft 

surveillance support and maneuverable vessels to 

locate and follow the streamers and tendrils of oil. 

These streamers were anywhere from a meter to several hundred meters in width.

Shoreline Protection. Protecting the shorelines of 

the impacted states was a critical part of the response 

operation. Containment boom was another critical 

resource. The desire of state and local governments to 

obtain and deploy boom led to negotiation of booming plans in the midst of the response. Generally, Area 

Contingency Plans identify sensitive areas and habitats for booming. The renegotiation process brought 

beaches used by the public within the scope of areas 

that had to be boomed. Many other protection strategies were used, including piling projects, water fi lled 

boom lined on the shore, and Hesco Baskets fi lled 

with sand. Louisiana also obtained funding from 

the RP at FOSC direction and permitting approval 

from the Army Corps of Engineers, to build sand 

berms along barrier islands, at an estimated cost of 

$360 million dollars. Alabama also obtained funding for smaller berm projects including a barrier for 

Katrina Cut. 

Search and Respond Standards and Quick 

Reaction Forces. The Unifi ed Incident Command 

developed a system, modeled after launch times for 

search and rescue assets, to use Coast Guard Maritime Safety and Security Team resources to do an 

on-scene assessment of new reports of oiling and 

allow cleanup assets to be prioritized based on that 

information. In order to ensure the highest priority 

impacts could be promptly addressed, Houma created Quick Reaction Forces and assigned response 

resources to them. These teams, mostly consisting of 

contract Oil Spill Response Organization personnel, 

could respond wherever most needed and were not 

tied to specifi c jurisdictions. Because of the competition among local governments for response assets, 

the initial work of these forces was complicated. 

However, once they proved their effectiveness and 

demonstrated that they kept response assets in reserve 

in staging areas outside impacted jurisdictions, they 

became less problematic to local offi cials. 

National Guard and Department of Defense Support. The National Guard provided support in many 

ways throughout the response, from helping to place 

barriers along the shoreline, to transportation, and 

coordinating emergency response communications. 

The process of obtaining National Guard and other 

Department of Defense (DOD) support involved 

arranging for payment of funding in advance, coordination with the Assistant Secretary of Defense for 

Homeland and America’s Defense, the Joint Staff, 

NORTHCOM, the National Guard Bureau, and each 

state’s Adjutant General. For the National Guard, 

Oil Spill Liability Trust Fund (OSLTF) funds were 

provided to fund activation under Title 32, thus the 

personnel worked for their respective states. This 

bifurcated process posed a challenge to the establishment of unity of effort within the federally-led 

Unifi ed Area Command. Navy Supervisor of Diving 

and Salvage participated signifi cantly. DOD also 

provided planners, public affairs support, and transportation resources. Tyndall Air Force Base provided 

the resources necessary to establish and operate the 

Aviation Coordination Center to prevent confl iction 

within the airspace above response operations, most 

particularly near the offshore source control efforts. 

Shoreline Cleanup Assessment Technique and 

Shoreline Cleanup Operations. Shoreline Cleanup 

Assessment Technique (SCAT) is the method for 

determining the most appropriate shoreline cleanup 

techniques weighing many variables for any given 

shoreline segment. These variables included amount 

of oil, type of shoreline, wildlife habitat, types and 

numbers of species present, archeological or historic properties concerns, etc. The teams consisted 

of representatives from the Coast Guard, NOAA, 

Fish and Wildlife Service (FWS) Section 7, National 

Park Service Section 106 Archeologists, other natural 

resource trustees, and state representatives. They 

ensured appropriate stakeholder review during the 

assessment process. Tribal liaisons and local government representatives participated whenever possible. 

SCAT experienced two signifi cant challenges during the response: the amount of shoreline impacted, 

and the duration of the spill. SCAT was divided into 

three stages. Stage I covered the period while oil 

still fl owed from the well. The primary focus was 

initial assessment to determine the scope of impact 

and review for re-oiling. Stage II focused on initial 

cleanup of bulk oil impacts. Stage III addressed the 
Executive Summary

ix

entire shoreline in the fall 2010 after oil fl ow stopped 

and after initial cleanup efforts were well under way. 

Scale created many challenges for SCAT. First, simply because of the amount of shoreline involved, 

there was significant demand for appropriately 

trained team members. Second, the breadth of 

impacted area led to signifi cant challenges. Garnering consensus across fi ve states on best management 

practices, shoreline treatment recommendations, and 

recommendations for no further treatment, which 

was complex. There were also signifi cant logistics 

challenges to surveying all of the impacted shoreline. Many areas were remote. Some could only be 

accessed at certain points in the tide cycle. Some 

unique SCAT methods were also used. Because of 

the concerns about oil impacts to beaches used by 

the public, identifi cation of tar mats just off shore 

was important as a means of identifying beach areas 

that needed to be closely watched for recurring tar 

balls. Snorkel SCAT used swimmers in these near 

shore locations to identify submerged tar mats and 

thus target shoreline cleanup resources. 

Actual shoreline cleanup was a long, arduous process. The cleanup methods and concerns of the 

public were very different, depending on the type 

of shoreline. There were two predominant types of 

shoreline impacted by the oil, sandy beaches and 

marshes. Beach cleanup involved work crews sifting 

sand, removing tar balls, and digging out tar mats. 

Mechanical cleanup devices such as the Sand Shark, 

a mechanical digger and sifter that scooped sand, 

sifted tar balls through screens of different sizes, and 

put clean sand back on the beach, were also used. In 

beach areas used by the public, the biggest cleanup 

concern was to remove as much oil as possible in 

order to encourage the public to return to the beaches. 

On beach land managed by federal truste agencies the 

concern was more to ensure cleanup did not damage 

sensitive habitat. 

Marshes posed different cleanup problems. Some 

marsh areas were heavily oiled. But many cleanup 

techniques posed signifi cant risk of killing marsh 

grasses and thus accelerating shoreline erosion. Several minimally invasive techniques, such as swabbing 

with sorbents or low pressure fl ushing, were tried. 

But in certain areas, the environmentally prudent 

recommendation was “no further treatment” and to 

leave an oiled marsh alone. 

Alternative Technologies. During the response more 

than 3,900 proposals for means of stopping the spill 

or cleaning up the oil were presented to the FOSC, 

NIC, the RP and state leaders. The NIC assembled 

the Interagency Technology Assessment Program to 

evaluate these proposals. Ninety-six percent of the 

proposals were evaluated. The A Whale, a 1,100-

foot cargo ship, serves as an example of the challenges posed by the process. The A Whale owners 

modifi ed the ship in an attempt to convert it into a 

giant weir skimmer. They hired a publicist to help 

generate interest in their proposal. Despite several 

modifi cations and attempts to skim oil offshore with 

government engineers on board to witness the evolution, the concept proved ineffective. 

Concurrent Response and Natural Resource 

Damage Assessment. Federal and state natural 

resource trustees and wildlife agencies played an 

important role in the spill response. These personnel aided the FOSC in understanding impacts and 

helped ensure response actions did not cause further 

damage to wildlife and their habitats. These agencies were the lead agencies in the Natural Resource 

Damage Assessment (NRDA), the cost of which is 

reimbursed by the RP. In this spill the NRDA process functioned in parallel with ongoing on-water 

and shoreline cleanup activities that stretched the 

resources of trustee agencies. 

Chapter 4: Health and Safety

Health and Safety was the number one strategic goal 

throughout this response and was refl ected in:

1. Efforts made to address potential public health 

impacts of the spill, and 

2. The remarkably low injury rate for responders 

across the operation. 

Air testing and monitoring were done along the Gulf 

Coast to address concerns about the fumes from oil 

on the shore lines and other response activities. Waste 

and air toxicity testing were performed to monitor 

the potential impacts of in situ burns. NOAA and 

the Food and Drug Administration closed much of 

federal fi sheries waters in the Gulf of Mexico during the spill out of concern that oil and dispersants 

might impact the suitability of fi sh caught in those 

areas for human consumption. NOAA and FDA conducted a robust seafood safety analysis program and 

established rigorous protocols for re-opening closed 

areas on a grid-by-grid basis. 

At the peak, there were 47,000 people working on 

the response, from those drilling relief wells on ships 

fi fty miles off-shore, to those working on skimming 
x

Executive Summary

and booming vessels, to work crews cleaning the 

shoreline. Thousands of personnel also worked to 

decontaminate oiled boom, vessels, and equipment. 

A signifi cant safety organization staffed by federal 

agencies including the Occupational Safety and 

Health Administration, Public Health Service, Coast 

Guard, state, and private safety experts oversaw and 

examined broad aspects of worker safety. Some were 

not novel, such as awareness of slips, trips, and falls. 

These types of basic safety measures took on uncommon importance when, for example, vessels working boom and skimmers had their decks covered in 

oil for days at a time. Some safety measures were 

unusual, at least in their scale—air quality monitoring for VOCs for those working to control the well 

source was vitally important. The EPA worked with 

the State of Louisiana to increase the frequency of air 

sampling from the Louisiana shoreline air monitoring 

stations, and provided a website for citizens to be 

able to review for full transparency of information. 

Heat was a signifi cant, overarching concern across 

the response. While the oil fl owed from the well and 

for the fi rst month after the well was capped, the heat 

index was frequently over 100 degrees Fahrenheit, 

which required careful planning to minimize heat 

related injuries. 

Chapter 5: Planning

There were two signifi cant aspects of planning during the course of the response, beyond the daily ICS 

planning necessary to run such a large response organization. Existing plans, such as the Area Contingency Plans and the Marine Transportation System 

Recovery (MTSR) plans, were used. As oil reached 

the shore, and oil continued to fl ow from the well, the 

ACPs were modifi ed and enhanced as the response 

continued. One new strategic plan was the Gulf-Wide 

Strategy that sought to enhance and replace the One 

Gulf Plan. The Gulf-Wide Strategy established ICP 

Miami consolidating operations from ICP St. Petersburg and ICP Key West into one command center. 

The Strategy also established the large equipment 

staging sites such as Theodore, Ala., and Gonzales, 

La. Not all the booming strategies in existing ACPs 

had been tested and not all plans identifi ed sensitive 

areas. Containment boom and oil skimmers were 

critical resources in high demand, and became areas 

of particular concern. Boom amounts had to be brokered between jurisdictions, each wanting as much 

boom and other response resources as possible. The 

MTSR plan was activated, and proactive communication with the industry identifying the location of 

oil was carried out, along with prompt establishment 

of stations to decontaminate vessels. These steps 

ensured the spill did not cause an unnecessary disruption to the movement of commerce in the marine 

transportation system.

The response also triggered new plans. Acquiring 

critical resources such as boom, skimmers and personnel started the strategic planning process, beyond 

the required ICS planning cycle. Severe weather had 

to be accounted for, as this was critical to personnel 

safety during this long response. With such a large 

operation that had grown dramatically just as hurricane season started, the FOSC had to ensure plans for 

dealing with severe weather were in place. Once the 

well was capped, planning was required to enable the 

orderly transition of response operations to a focus on 

shoreline cleanup, and to gain acceptance of transition plans from the affected states and communities. 

After such a protracted spill, reduction in the size of 

the response required careful coordination with state 

and local leaders. As part of the appropriate scaling of 

the response, the fi ve incident command posts were 

consolidated into a single incident management team. 

As shoreline cleanup progressed into the winter, the 

stand down of the Unifi ed Area Command required 

detailed planning and explanation. As the SCAT process determined which shoreline segments required 

no further treatment for the winter months, a plan was 

required to continue monitoring those shorelines for 

signs of oil exposed by winter storms, as well as a 

plan of action to respond to such reports.

Development of the administrative record of an oil 

spill response is required by the NCP. The fi ve command posts and multiple branches and staging areas 

generated more than 27 million documents. Also, 

because of the potential for litigation surrounding 

the spill, federal responders saved all electronically 

stored information for possible electronic discovery. 

Chapter 6: Logistics

Several logistics matters were instrumental to operational success of the response. Given that BP, as RP, 

accepted responsibility for oil spill removal, signifi -

cant logistical commitments and challenges were 

largely addressed by the RP with federal oversight. 

The FOSC and Unifi ed Area Command (UAC) initially identifi ed boom, skimmers, and personnel as 

critical resources. Due to a limited supply of the dispersant Corexit, it became a controversial resource. 

In addition to seeking those resources, the NIC and 

FOSC also received offers of assistance, many from 

overseas. As a result, the NIC and FOSC developed 
Executive Summary

xi

processes for receiving and processing such offers. 

When assistance involved foreign fl agged vessels, 

potential confl ict arose with the Jones Act, which 

requires trade between U.S. ports be on U.S. fl agged 

vessels. The requirements of the Jones Act can be 

waived. In the end, only seven Jones Act waivers 

were issued, primarily for specialized vessels working to contain oil from the well, and the Jones Act 

was not an impediment to the response. 

Vessels of Opportunity. Several thousand Vessels of Opportunity (VOOs) and their crews were 

employed. These were private vessels hired by the 

RP to assist with the spill response. They performed 

duties such as placing boom, skimming oil, and onwater transportation and support services. The size 

of the VOO fl eet required extensive coordination 

at both ICP Houma and ICP Mobile. Concern over 

equitable opportunities for work, use of commercial 

vessels only, and efforts to hire those from the local 

area to assist response efforts, made management of 

the VOO fl eet complicated. This led to development 

of a VOO policy issued by the FOSC—a policy that 

standardized VOO usage and organizational structure, and established training and safety measures and 

contractual and logistical requirements. Despite these 

efforts, there were communications challenges with 

VOO, some due to language barriers and others due 

to the disparity of communication equipment installed 

in the vessels. As the response operation contracted, 

the generous day rates paid by the RP complicated 

efforts to reduce the size of the VOO fl eet. 

Aviation Coordination. At the height of the spill, 

aircraft shuttled people and supplies to the small city 

of vessels working to control the source, overfl ew 

skimming and in situ burn operations to direct surface 

assets onto concentrations of oil, applied dispersants 

where appropriate, surveyed shoreline impacts, and 

provided public affairs opportunities. All these operations put a large number of aircraft in close proximity and thus created risks. The FOSC worked with 

the FAA to develop a Temporary Flight Restriction 

(TFR) over response operations. Enforcing the TFR 

required visibility of aircraft in the area, to include 

those out near the source. Working with the UAC and 

the ICPs Air Operations Branch, Tyndall Air Force 

Base was able to provide the resources and technical 

expertise to improve aviation coordination over the 

operating area. ICP Houma and ICP Mobile established the priorities and aircraft tasking through the 

aircraft branch of the Operations Sections and set out 

in the Incident Action Plans (IAPs). By late June, the 

Aviation Coordination Center used the prioritization 

set out in the IAPs to safely manage and prevent 

confl iction within the airspace. 

Vessel Decontamination. More than 9,000 vessels 

participated in the response. Some never touched oil 

and could quickly be released when they were no 

longer needed. Others spent weeks in the midst of 

oil. To clean vessels that came in contact with oil, the 

FOSC and RP set up signifi cant vessel and equipment 

decontamination operating facilities across the Gulf 

Coast. Some smaller vessels and equipment could be 

pulled out of the water and pressure washed in containment pools. Larger vessels involved in oil skimming required dry docking with extensive cleaning of 

hulls, ballast tanks, and salt water service systems. In 

order to make the process effi cient, the FOSC defi ned 

standards for decontamination, and employed Coast 

Guard marine inspectors and other trained personnel, 

providing a just-in-time training process to certify 

completion of the decontamination process. 

Other logistics concerns had signifi cant impact on 

response operations. Most logistics matters, including 

waste management and boom disposal, were handled by the RP. Sustaining government responders 

fell partly outside the RP’s logistics arrangements. 

Communications and computer connectivity were 

limited in many areas impacted by the spill. The 

response operation also set up incident command 

posts, branches, and staging areas across fi ve states, 

which required computer connectivity to operate. 

Communications had to be established with the thousands of vessels and hundreds of aircraft employed. 

The Coast Guard procured dedicated servers to fulfi ll its obligations to preserve electronically stored 

information. 

The FOSC established policies for government specifi c logistics matters beyond communications. The 

RP provided lodging, transportation, food, limited 

medical, and command post facilities; government 

logistics ensured that the needs of government 

response personnel were taken into account. With the 

numbers of personnel cycling through the response, 

systems had to be established to track people when 

they checked in and methods to demobilize them. 

Property acquired by the government for the response 

had to be accounted for just as any other form of 

government property.

Chapter 7: Finance

When the spill began, the Oil Spill Liability Trust 

Fund (OSLTF) had a response expenditure cap 

of $100 million per incident. Relatively soon, it 
xii

Executive Summary

became apparent government expenditures would 

soon exceed that amount, and Congressional action 

was necessary to increase the per response cap. This 

was enacted and as of February 2011, the cap for 

the Deepwater Horizon response was $700 million. 

It was, however, but a small fraction of the total 

costs the RP has paid to date. The solvency of the 

RP was pivotal in sustaining the unprecedented level 

of response. 

The RP reimbursed the OSLTF for expenditures 

against the fund, although that did not act as a credit 

against the per incident cap. An RP is also responsible 

for claims arising from the spill. The National Pollution Funds Center directed the RP to take required 

steps to advertise the ability to make claims. These 

advertisements notifi ed the public that if their claim 

was denied or they were unsatisfi ed with the RP’s 

offer, injured parties could make a claim to the 

National Pollution Funds Center (NPFC). 

Finance personnel were assigned to the UAC, the 

ICPs, and the Branches. Decentralized fi nance sections allowed greater fl exibility to the response, but 

complicated documenting costs. Military Interdepartmental Purchase Requests (MIPRs) and Pollution Removal Funding Authorizations (PRFAs) 

authorize funding from the OSLTF for federal and 

state agency participation in a response. The Finance 

Section negotiated details of the MIPRS and PRFAs 

during the response, including assessing agency participation when the FOSC so directed. The process of 

tracking the costs associated with these arrangements 

required great attention to detail as the daily costs 

for various categories of government support had to 

be manually entered into electronic documentation 

workbooks. Tracking costs associated with credit 

card expenditures, travel orders, and reserve orders 

involved development of new, detailed methods and 

processes to ensure accurate accounting. 

Chapter 8: Natural Resources and Wildlife

Marine Mammals. There are 29 species of marine 

mammals and fi ve species of sea turtles that inhabit 

the areas impacted by the spill. NOAA and the FWS 

established the marine Mammal and Sea Turtle 

Group within the Wildlife Branch of the Operations 

Section. The group coordinated its activities with 

existing marine mammal and sea turtle organizations 

of the Gulf Coast and elsewhere within the United 

States. Working with these organizations, protocols 

were developed for handling oiled animals and to 

take in reports of marine mammals and sea turtles 

impacted by oil. In addition, the spill occurred just 

as the sea turtle nesting season was beginning across 

the shores of the northern Gulf of Mexico. In order 

to minimize the threat of losing many nests to oil 

impacts, sea turtles nests were excavated and relocated to Florida. Although initial observations found 

few dolphins stranded with externally visible oil, in 

early 2011 NOAA declared an unusual mortality 

event (UME) for dolphins in the northern Gulf of 

Mexico, and they continue to investigate the causes. 

The role that the spill may have played in the UME 

is as yet unknown

Migratory Birds. Similarly robust operations were 

established to respond to impacts on migratory birds. 

The FWS and state agencies coordinated efforts with 

the Audubon Society and existing networks of organizations working with migratory birds in the region. 

Coordination of volunteers, and ensuring volunteers 

had appropriate experience and training to assist with 

migratory birds eventually was performed by mutual 

agreement with the Audubon Society. Among the 

efforts to attempt to lessen the impacts to migratory 

birds, the Department of Agriculture (USDA) Natural 

Resource Conservation Service (NRCS) diverted 

funds for two existing migratory bird habitat initiatives to lease private farmland for fl ooding and fl ood 

appropriate public lands for migratory bird habitat. 

USDA sought FOSC funding to reimburse the programs for the expenses focused on the Gulf Coast. 

Ultimately, the FOSC determined not to provide the 

reimbursement from the OSLTF and the effort was 

later found to be ineffective in keeping migratory 

birds from reaching oiled shorelines. 

Endangered Species. There are 26 endangered or 

threatened species in the Gulf of Mexico, ranging 

from sperm whales to the fi ve species of sea turtles. 

Ensuring compliance with the Endangered Species 

Act for response operations involved bringing experts 

from NOAA, FWS, and other sources to develop 

and disseminate best management practices to adapt 

response operations, whether in situ burns or cleaning tar balls from beaches, to account for potential 

endangered species impacts. The work also involved 

providing trained spotters for skimming and in situ 

burn operations.

Ensuring adequate numbers of appropriately trained 

wildlife responders, supplying wildlife teams with 

necessary logistics support, and communicating 

wildlife related information across such an enormous organization spread across fi ve states, proved 

challenging. 
Executive Summary

xiii

Section 106 Compliance. Approximately 778 

archeological sites, including 113 newly discovered 

sites, were checked during the course of the response. 

There are eleven federally recognized tribes with 

traditional cultural properties and interests in the 

shorelines impacted by the Deepwater Horizon spill. 

There are also state recognized tribes with interests 

in the area. Historic preservation and tribal interests were folded into the response from early May, 

before there were shoreline impacts from the spill. 

Once the well was capped and the focus of response 

operations shifted almost exclusively to shoreline 

cleanup, formal consultations with historic preservation stakeholders took place in August, and the fi rst 

of several government-to-government consultations 

took place in September. 

Chapter 9: Government Personnel

Sustaining the number of people required to direct 

response operations for a spill of this size and long 

duration, proved diffi cult for every government 

agency. Agencies that regularly participate in oil spill 

response have a cadre of highly trained people experienced in spill response work. The response soon 

outgrew the number of those people in almost every 

agency, including the Coast Guard. This posed two 

interrelated challenges. The fi rst was simply staffi ng 

the response itself, given that all the agencies that 

participated had other missions to fulfi ll. Finding 

personnel to support the response effort while still 

maintaining enough staff to enable agencies to carry 

out their other missions proved diffi cult. Second, the 

number of people required exceeded the number with 

signifi cant training and experience in spill response. 

Thus these agencies, including the Coast Guard, had 

to develop just-in-time training methods to bring in 

the numbers of personnel required to oversee operations and provide them with the training necessary 

to perform their functions. 

The Coast Guard mobilized 14 percent of its total 

workforce, active duty and reserve. FWS and NOAA 

deployed approximately 17 percent of their workforce. For contingencies such as the Deepwater Horizon spill, the Coast Guard relies on the Coast Guard 

Reserve. The Reservists can be, and were, ordered 

to active duty under Title 14 of the U.S. Code. While 

this process makes Reservists immediately available, 

they can only be ordered to active duty in this manner 

for 60 days at a time. After that period of service, 

unless the Reservist volunteers for further activation, 

they cannot be recalled for two years. Due to this 

limitation, managing the availability of Reservists 

became a signifi cant challenge; however, the number 

of Reservists who volunteered to continue to work 

on the DWH response under different arrangements 

certainly sustained the effort in a meaningful way. 

Chapter 10: Communications

Common Operating Picture. One of the central 

challenges in communicating about the response 

was developing a common operating picture that 

all stakeholders could access. After initially being 

used to help with oil spill trajectory, on June 5, 

2010, the NIC directed that NOAA’s Environmental Response Management Application (ERMA) 

would be the common operating picture (COP) 

for the Deepwater Horizon response. ERMA provided the ability to use Geographic Information 

System tools to track every aspect of the response, 

ultimately growing to thousands of data layers 

covering a wide array of response operations. It 

also allowed a scaled version of the COP to be 

posted on the Internet as GeoPlatform.gov, where 

the public could view response status information. 

Standard Information Reporting. As the public and 

government offi cials learned of the potential impact 

of the spill, requests for information about response 

activities added a requirement for distilled information for distribution and posting. Daily Incident 

Action Plans, which contained information about 

response operations, quickly became so large that 

they were not useful for conveying information 

to senior offi cials or to the public. A standard set 

of measurements of resources and operations was 

developed, which provided a repeatable set of statistical information reported out from the response 

organization. 

Interaction with Federal and State Offi cials and 

Congressional Affairs. In April through August 

2010, over sixty percent of the Congressional inquiries to the Coast Guard were related to the Deepwater Horizon. Seventeen Congressional hearings as 

well as numerous Congressional Delegation hearings were conducted during the response phase of 

the incident. To ensure the concerns of local elected 

offi cials were accounted for in response operations, 

DHS hosted a daily call-in for local elected offi cials, 

which included a FOSC situation report followed by 

a question and answer session. In addition, the White 

House hosted a daily call that included the NIC, the 

FOSC, and the governors of the fi ve impacted states. 

The states received the same daily summary as the 

White House.
xiv

Executive Summary

To improve information fl ow, Deputy FOSC Representatives (Deputy FOSCRs) were assigned to the 

governors of Alabama, Mississippi, and Florida, 

while the Coast Guard sent a liaison to the staff of 

the Louisiana government and the FOSC, already 

located in Louisiana, met with him frequently. FEMA 

deployed a Governmental Relations Team of 80 

people to assist in communications with local government leaders, interested citizens, and businesses. 

Interaction with Local Government and Affected 

Communities. Interaction between the response and 

government leaders did not stop with the governors. 

An extensive liaison network of approximately 70 

offi cers was established to respond to the needs of 

local offi cials. Liaisons, most particularly with the 

parish presidents of the coastal parishes in Louisiana, 

improved coordination between the response and 

local offi cials. Coast Guard Liaisons were also sent 

to local and state emergency response operations 

to improve communications and understanding of 

response needs. These liaisons fi led daily information reports that were communicated to offi cials in 

Washington. 

The FOSCs and Incident Commanders also reached 

out to the local communities. They found that expo 

type meetings, consisting of booths and tables with 

information and subject matter experts on various 

issues of concern to the public and specifi c aspects 

of response operations, were effective in communicating the status and challenges of the response. 

This was in contrast to town hall style meetings that 

were emotionally charged and did not contribute to 

inspiring public trust. 

Strategic Communications. Strategic Communications for the response began with the Coast Guard and 

RP using the Joint Information Center (JIC) model 

generally used for oil spills. Over time, however, 

this model became more of a hybrid of the National 

Response Framework’s ESF-15 structure that places 

media, governmental, and congressional affairs in 

one federal entity, with a limited JIC embedded. 

By June, the NIC took over primary responsibility 

for addressing the national media on a daily basis 

about actions and items of interest, while the FOSC 

remained responsible for dealing with local media 

and state and local government leaders. The NIC 

focused on addressing the complexities of the relief 

well effort and source control. The FOSC addressed 

oil spill response, removal, and impacts. This large, 

full service communications structure remained in 

place until after the well was capped when media 

interest diminished and allowed reduction in the communications staff, along with scaling back of the rest 

of the response organization. 

As with many other areas of the response organization, it was diffi cult to sustain the number of staff 

required with the appropriate skills to handle both 

traditional public affairs and community and intergovernmental relations. The willingness of other 

agencies to provide public affairs specialists to assist 

was a signifi cant help. 

Conclusion

The Deepwater Horizon oil spill response was ultimately successful, due to the unity of effort and 

perseverance of the more than 1000 organizations 

that contributed to this unprecedented response. The 

NCP was proven sound, and the Incident Command 

System’s scalable organizational structure proved 

critical to multiple agencies working with the RP 

toward common goals under an effective construct. 

The division of responsibilities between the NIC and 

staff working at the National level, and the FOSC 

serving as Unifi ed Area Commander at the regional 

level, was effective in managing national, regional 

and local demands of this fi rst “Spill of National 

Signifi cance.” 

The Deepwater Horizon incident occurred in spite 

of the presence of a blowout preventer. The oil spill 

impacted the marine environment and the lives of 

so many along the Gulf of Mexico. The mitigation 

effort to secure the well source was a three-month 

process (87 days), and the resulting spill response 

effort became extraordinarily large and complex. 

Based on these facts, we conclude that signifi cant 

improvements need to be made in preventative technology and requirements, mitigation technology and 

required capabilities, and oil spill response methods 

and readiness.
Contents

xv

Table of Contents

Organization of the Report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . v

Chapter 1 and the Chronology: Situation as it Developed . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . v

Executive Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . v

Chapter 2: Command and Control . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .vi

Chapter 3: Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .vi

Chapter 4: Health and Safety . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .ix

Chapter 5: Planning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . x

Chapter 6: Logistics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . x

Chapter 7: Finance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .xi

Chapter 8: Natural Resources and Wildlife . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xii

Chapter 9: Government Personnel . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xiii

Chapter 10: Communications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xiii

Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .xiv

Contents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xv

1. Situation as It Developed . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

2. Command and Control . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

2.1 Setting the response structure of the Deepwater Horizon Response . . . . . . . . . . . . . . . . . . . 3

The Role of the Responsible Party under the Oil Pollution Act of 1990 . . . . . . . . . . . . . . . . . 5

2.2 National Incident Command . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

2.3 Unifi ed Area Command . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

Regional Response Team Involvement at the Unifi ed Area Command . . . . . . . . . . . . . . . . . 10

Natural Resource Trustees Involvement at the Unifi ed Area Command . . . . . . . . . . . . . . . . 11

Tribal involvement at the Unifi ed Area Command . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

FOSC Key Points: State Integration into Unifi ed Command . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

2.4 Incident Command Posts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

ICP Houma Command Structure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

ICP Mobile Command Structure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

ICP Houston . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

Federal Agency involvement at the Incident Command Posts . . . . . . . . . . . . . . . . . . . . . . . . . 16

State involvement at the Incident 

Command Posts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

Integration of Local Emergency Entities 

at the Incident Command Posts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

2.5 Branches and Staging Areas . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

ICP Houma Branch Structure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

ICP Mobile Branch Structure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

3. Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

3.1 Source Control . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

Overview of Source Control Activities (Situation) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

Response Organization 

in Houston . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

Source Control Oversight 
Contents

xvi

(Action and Resources) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

Operational Procedure Processing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

Source Control Challenges. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

Oil Trajectory and Amount . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29

Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29

Oil Spill Trajectory in Detail . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29

The Loop Current . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31

Oil Trajectory Challenges Encountered . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31

The Size of the Oil Spill . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31

The Fate of the Oil . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33

3.2 Dispersant Use and Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33

Aerial Application . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36

Sub-sea Dispersant Operations and Sub-Sea Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37

Implementation of Addendum 3 to Reduce Dispersant Application . . . . . . . . . . . . . . . . . . . . 41

Challenges to Dispersant Use . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44

End of Dispersant Use . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44

3.3 In Situ Burn Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45

Overview of Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45

Offshore Vessel Fleet . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46

Simultaneous Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46

Wildlife Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46

Safety and Smoke Plumes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46

Mega Volume Burns . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47

Burn Volume Calculation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47

3.4 Skimming . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48

Offshore . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49

Near-shore Zone . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51

Beach, Bays, and Marshes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52

3.5 Shoreline Protection 

(Boom, Berms, Hesco) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52

Mobile Bay Booming . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54

Louisiana . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57

3.6 Search and Respond Standards and Quick Reaction Forces . . . . . . . . . . . . . . . . . . . . . . . . . 59

Search and Respond Standards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59

Quick Reaction Forces . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59

3.7 National Guard and Department of Defense Support . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60

Command and Control of National Guard and Department of Defense Assets . . . . . . . . . . 60

Demobilization of National Guard Forces . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62

3.8 Shoreline Assessment, Cleanup, Shoreline Cleanup Assessment Technique . . . . . . . . . . 62

U.S. Geological Survey Site Sampling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63

Shoreline Cleanup Assessment Technique . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 64

Shoreline Clean Up Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 68
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Beaches . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 68

Heat and Beach Cleaning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 69

Operational Science Advisory Team II Report on Remaining Oil on Beaches . . . . . . . . . . 69

Marshes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 70

3.9 Alternative Technologies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 72

Federal Agency Response Research and Development Funding . . . . . . . . . . . . . . . . . . . . . . . 72

Coast Guard Oil Spill Research . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 72

Assessment of Alternative Response Technology at the Unifi ed Area Command and 

Incident Command Posts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 72

Interagency Alternative Technology Assessment Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 72

A Whale: An Example . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 72

3.10 Concurrent Emergency Response and Natural Resource Damage Assessment . . . . . 74

3.11 FOSC Key Points . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 78

Response and Restoration, Removal, and Damage Assessment . . . . . . . . . . . . . . . . . . . . . . . . 78

Ineffective Boom Deployment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 78

4. Safety . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 79

4.1 Public Health and Safety. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 79

Fisheries Closures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 80

Seafood Safety Sampling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 80

NOAA, FDA and States’ Reopening Protocol . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 83

Seafood Safety and Sampling Protocols . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 84

Continued Post Reopening Monitoring of Seafood . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 85

4.2 Response Personnel Health and Safety . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 85

Heat and Safety . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 85

Safety Organization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 86

Monitoring Chemical Exposures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 87

Protecting Workers from Exposures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 88

Aviation Safety . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 89

Coast Guard Cutter Safety . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 90

FOSC Key Points: Safety . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 90

5. Planning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 91

5.1 Existing Plans: Area Contingency Plans . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 91

5.2 Existing Plans: The Maritime Transportation System Recovery Plans . . . . . . . . . . . . . . 94

5.3 Organizational Structure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 94

UAC MTSRU . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 94

ICP Houma MTSRU . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 95

ICP Mobile MTSRU . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 95

National Level Support and Outreach . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 95

MTS Recovery Data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 96

5.4 Plans Developed During the Response: Severe Weather Plan and Planning for 

Concurrent Activation of the National Contingency Plans and Stafford Act . . . . . . . . . . . . 96

Concurrent Activation of the National Contingency Plan and the Stafford Act . . . . . . . . . 96
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Development of Severe Weather 

Contingency Plans . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 98

Developing a Severe Weather Planning Capability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 98

Severe Weather Operations Center (SWOC) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 99

Accountability Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 99

Personnel Accountability Unit (PAU) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 100

Accountability for Boom . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 100

Prevention of Confl ict with Local and State Governments Evacuation Plans . . . . . . . . . . 101

Training . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 102

Safety First on Reconstitution of Deepwater Horizon Operations . . . . . . . . . . . . . . . . . . . . . 103

Hurricane Alex, Tropical Depression No. 2, and Tropical Storm Bonnie . . . . . . . . . . . . . . 103

5.5 Plans Developed During the Response: Transition Planning . . . . . . . . . . . . . . . . . . . . . . . . 104

Origins of Strategic Planning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 104

Severe Weather . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 105

Transition Planning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 105

Incident Command Post Consolidation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 106

Monitoring and Maintenance Plan and UAC Transition Plan . . . . . . . . . . . . . . . . . . . . . . . . . 107

5.6 Incident Documentation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 108

5.7 FOSC Key Points . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 109

Area Contingency Plans . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 109

Local Government Involvement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 109

Other State Agency Involvement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 109

6. Logistics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 111

6.1 Operational Logistics: Critical Resources (Boom, Skimmers, Beach Cleaning 

Equipment, Personnel) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 111

6.2 Operational Logistics: International Notifi cation, Cooperation, and the Jones Act . 114

Jones Act, Clarifi ed . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 116

6.3 Operational Logistics: Vessels of Opportunity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 118

6.4 Operational Logistics: Aviation Operations and Airspace Safety . . . . . . . . . . . . . . . . . . . 123

FOSC Key Points: Aviation Coordination Center . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 126

6.5 Operational Logistics: Vessel Decontamination . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 127

Establishment of Decontamination Branch . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 127

Cleaning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 130

Standards and Certifi cation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 130

Resources Committed . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 131

Decontamination Challenges . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 132

Continuity and Training . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 133

Offshore Vessels . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 133

Pre-assessment Surveys . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 133

6.6 Operational Logistics: Waste Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 134

6.7 Operational Logistics: The Severe Weather Contingency Plan . . . . . . . . . . . . . . . . . . . . . 136

6.8 Support Logistics: Command, Control, Communications, Computing and 
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Information Technology (C4IT) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 137

Tactical Communications: Organization and Personnel . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 138

Vessel Communication . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 139

Aviation Communications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 140

Rescue 21 Utilization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 140

Information Management: Network connectivity and infrastructure . . . . . . . . . . . . . . . . . . 140

Electronically Stored Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 141

6.9 Support Logistics: Federal On-Scene Coordinator Logistics Policies . . . . . . . . . . . . . . . 141

6.10 Support Logistics: Area Command Critical Resources Unit . . . . . . . . . . . . . . . . . . . . . . . 142

6.11 Support Logistics: Resource Request Process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 143

6.12 Support Logistics: Requests for Assistance (RFA) from the Department of Defense 

(DOD) and State National Guards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 143

6.13 Support Logistics: Organization and Facilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 144

6.14 Support Logistics: Vehicles and Transportation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 145

6.15 Support Logistics: Lodging and Feeding . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 145

6.17 Support Logistics: Personnel Demobilization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 146

6.18 Support Logistics: Property and Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 146

6.19 FOSC Key Point . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 148

Vessels of Opportunity Protocols . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 148

7. Finance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 149

7.1 Response Funding . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 149

7.2 Responsible Party Liability, Role, and Funding . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 152

7.3 Payment of Claims and Billing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 152

7.4 Finance Section Organization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 153

7.5 Resource Request and Ordering Process. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 154

7.6 Cost Tracking, Resource Tracking, and Financial Reporting . . . . . . . . . . . . . . . . . . . . . . . 156

7.7 Tracking of Personnel and Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 156

7.8 Property Management and Tracking . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 157

7.9 Cost Reconciliation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 158

7.10 Resources Committed . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 160

7.11 FOSC Key Points . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 161

Responsible Party Solvency . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 161

OSLTF Caps . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 161

8. Natural Resources and Wildlife . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 163

8.1 Marine Mammals and Sea Turtles . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 163

Initial Establishment of the Marine Mammal and Sea Turtle Group . . . . . . . . . . . . . . . . . . . 163

Response to Oiled and Stranded Marine Mammal and Sea Turtles . . . . . . . . . . . . . . . . . . . . 164

Sea Turtle Rescue . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 165

Relocation of Sea Turtles’ Nests . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 166

Sea Turtle Rehabilitation Efforts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 167

Dolphins . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 168

Marine Mammal Stranding Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 168
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xx

8.2 Migratory Bird Activities and Volunteer Wildlife Response Assistance . . . . . . . . . . . . . 169

Migratory Bird Habitat Initiative . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 172

8.3 Environmental Compliance with the Endangered Species Act . . . . . . . . . . . . . . . . . . . . . . 172

Endangered Species Act Response Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 174

Natural Resource Trustee Agency Oversight of Endangered Species Act Requirements in 

the Response . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 174

8.4 Wildlife Challenges . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 177

8.5 Section 106 of the National Historic Preservation Act Consultations . . . . . . . . . . . . . . . 178

Situation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 178

First Actions Taken . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 179

Challenges . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 179

Resources Used . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 179

Phase Two Actions Taken . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 179

9. Government Personnel . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 181

9.1 Federal Government Personnel Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 181

9.2 Staffi ng the Response . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 182

9.3 Initial Phase 

(April 20 – May 19, 2010) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 182

9.4 Dynamic Phase 

(May 20 – 15 August 15, 2010) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 183

9.5 Transitional Phase 

(August 16, 2010 – December 17, 2010) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 184

9.6 Project Phase

 (December 18, 2010 – Present) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 184

9.7 Coast Guard Personnel Tracking . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 184

9.8 Other Federal Agency Personnel Efforts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 185

9.9 Training. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 186

10. Communications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 189

10.1 Information Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 189

Application of Advances to Communications to Support Information Management—

Development of a Common Operating Picture . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 189

Organizational Changes to Support Information Management . . . . . . . . . . . . . . . . . . . 192

10.2 Interaction with Federal and State Offi cials, and Congressional Affairs . . . . . . . . . . . 193

10.3 Interaction with Local Government . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 195

10.4 Interaction with Affected Communities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 198

10.5 Strategic Communications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 199

Situation and Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 199

Resources Committed . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 200

Challenges Encountered . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 201

10.6 FOSC Key Points . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 202

The Need for a Common Information Reporting Template . . . . . . . . . . . . . . . . . . . . . . . . . . . 202

Common Operating Picture . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 202

External Affairs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 202

Appendix . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 203
1. Situation as It Developed

1

On April 20, 2010, 126 workers on the 

mobile offshore drilling unit Deepwater 

Horizon were in the process of temporarily closing the exploratory Macondo oil well. That 

evening, an explosion aboard the drilling unit set off 

a chain of events that eventually led to the sinking 

of the Deepwater Horizon. Eleven crewmembers 

lost their lives and others were seriously injured, 

as fi re engulfed and ultimately destroyed the rig.

At 10 p.m. CST on April 20, watch standers at the 

U.S. Coast Guard District Eight command center 

received a report of an explosion and fi re aboard 

the Deepwater Horizon, located approximately 42 

miles Southeast of Venice, La. A search and rescue 

effort began soon after, with Coast Guard District 

Eight as the Search and Rescue Mission Coordinator. Concurrently, Coast Guard Marine Safety 

Unit Morgan City, La., began a pollution response 

case and marine casualty investigation. Aircraft 

involved in the search reported a variably colored 

sheen on the surface of the water, two miles long 

by half-mile wide. 

By April 21, 115 of the 126 workers were accounted 

for. The Coast Guard continued to search for survivors, dispatching 28 air and surface sorties, covering approximately 5,375 square miles. At 5 p.m. 

CST on April 23, the Coast Guard suspended the 

search. Initial debriefs of the surviving crewmembers placed the 11 missing in the vicinity of the 

initial explosions.

The Commanding Offi cer of Marine Safety Unit 

Morgan City, La., became the fi rst Federal OnScene Coordinator (FOSC) to direct the oil spill 

response. As the search and rescue continued, it 

was determined the response had the potential to 

eclipse all others and impact a large portion of the 

Gulf Coast region. Therefore, the Commandant 

of the Coast Guard re-assigned the FOSC role to 

the Commander of Eighth Coast Guard District.

On April 22, dispersants were used for the fi rst 

time.

On April 23, the FOSC established a Unifi ed Area 

Command (UAC) in Robert, La. The UAC served 

as headquarters for the regional response and eventually included representatives from the federal 

government, Alabama, Florida, Louisiana, Mississippi, and the Responsible Party (RP).

The Coast Guard Incident Command Posts (ICPs) 

in Houma, La., and Houston, Texas, were also 

established on April 23. These ICPs, along with 

one in Mobile, Ala. established on April 26, 2010, 

would become the centers of response operations. 

On April 29, the Deepwater Horizon incident was 

declared a Spill of National Signifi cance, the fi rst 

time the federal government used that designation. The declaration permitted a newly designated 

National Incident Commander to assume the lead 

role of communicating with affected parties and 

the public, and coordinating all federal, state, local, 

and international resources at the national level.

Between May 6 and May 8, the RP unsuccessfully 

attempted to place a large containment dome, or 

cofferdam, over the larger of two leaks from the 

broken riser at the sea fl oor.

On May 11, Louisiana applied to the Army Corps 

of Engineers for an emergency permit to construct 

six large, linear sand berms along Louisiana’s barrier islands to guard the coastline from oil. Two 

weeks later, the Corps approved an emergency permit for a portion of the berms. Just over one week 

later, the RP began funding all six Louisiana sand 

berm reaches. The National Incident Commander 

had also authorized one of the six as a prototype 

oil spill response mechanism.

On May 12, the RP released a 30-second video of oil 

and gas streaming from the end of the broken riser.

By mid-May, the Coast Guard evolved the organizational structure for the response and along with 

other response agencies, began to move resources 

into the area from all over the country.

As oil fl ow rate estimates had gone from 1,000 to 

5,000 barrels per day, and the RP was unable to 

ascertain with any certainty the conditions at the 

wellhead inside of the blowout preventer (BOP), 

the federal government became increasingly concerned with fl ow rate estimates. To determine the 

fl ow amount, the National Incident Command created an interagency Flow Rate Technical Group and 

charged it with generating a preliminary fl ow rate.

On May 26, the Environmental Protection Agency 

announced that the government instructed the RP 

to take immediate steps to scale back the use of 

dispersants. Also on May 26, the RP began a top 

kill, a process that involved pumping heavy drilling mud into the top of the well at high pressure. 

After the third unsuccessful attempt, the RP and 

the government agreed to discontinue the strategy.

On May 27, the Flow Rate Technical Group 

estimated the range of oil fl ow from the source 
2

1. Situation as It Developed

between 12,000 to 19,000 barrels per day (fl ow 

rates of up to 25,000 barrels per day were also 

consistent with data). On May 28, the President 

of the United States directed federal manpower 

and resources responding to the spill be tripled.

On May 29, the RP announced that it would attempt 

to cut off the portion of the riser still attached to 

the top of the BOP on the sea fl oor and install a 

collection device—the top hat—that would then 

be connected via a new riser to the Discoverer 

Enterprise.

On June 1, 2010, Rear Admiral James Watson 

assumed the role of FOSC.

On June 3, the top hat was in place and functioning 

at the source. By June 8, the Discoverer Enterprise

was collecting nearly 15,000 barrels of oil per day.

On June 16, the vessel Q4000 became operational, 

and was processing and burning up to 10,000 barrels of oil per day.

On July 9, the National Incident Commander 

authorized the RP to install a capping stack, but 

not to close it. The operation began the next day 

and by July 12, the RP had fi nished installing the 

stack. On July 15, the RP closed the stack and a 

well integrity test commenced.

On July 12, Rear Admiral Paul Zukunft assumed 

the role of FOSC.

On August 3, the RP began a static kill—an operation that involved pumping heavy drilling mud into 

the well to push oil and gas back into the reservoir. 

The static kill succeeded and was followed with 

cement. On August 8, the National Incident Commander reported that the cement had been pressure 

tested and was holding.

In mid-September, the fi rst relief well intercepted 

the Macondo well, allowing the RP to permanently 

seal the reservoir. On September 19, the National 

Incident Commander announced the Macondo 

well was effectively sealed.

On September 20, 2010, the ICPs in Houma, La., 

and Mobile, Ala., were disestablished, and operations were consolidated under the Gulf Coast 

Incident Management Team in New Orleans, La.

On October 1, 2010, the National Incident Command was disestablished.

The response to the Deepwater Horizon spill 

continues. As of July 15, 2010—the day the 

well stopped fl owing—the response involved 

approximately 47,000 responders, more than 6,870 

vessels (including skimmers, tugs, barges, and 

recovery vessels), approximately 4.12 million feet 

of boom, 17,500 National Guard troops from Gulf 

Coast states, fi ve states, multiple corporations, and 

untold hours of work by federal, state, and local 

offi cials, employees or contractors of the RP, and 

private citizens.
2. Command and Control

3

The Deepwater Horizon spill was the fi rst 

Spill of National Signifi cance (SONS) and 

the fi rst to have a National Incident Command (NIC) designated. At its peak, more than 

47,000 people worked on the response in total and 

more than 6,870 vessels were employed in response 

efforts. Oil from the spill directly impacted fi ve 

states. Because of the size and scope of the spill, 

the response organization required to combat it was 

unique in many respects.

2.1 Setting the response structure of 

the Deepwater Horizon Response

• The size and scope of this incident required 

signifi cant coordination of public and private 

resources. The command and control structure 

maximized the Federal On-Scene Coordinator’s (FOSC) work with other federal, state, 

and local stakeholders to address the highest 

operational needs.

• One National Incident Command (NIC) was 

established in Washington, DC, to coordinate 

the ‘whole of government’ response to the 

incident.

• One Unified Area Command (UAC) was 

established to oversee operational activities 

across the entire Gulf Region.

• Five Incident Command Posts (ICPs) were 

established to coordinate operations with local 

and regional elected offi cials. ICPs Houma and 

Mobile were the most robust and active for spill 

response operations.

• Branches and Staging Areas were established 

to coordinate the effi cient and effective distribution and employment of critical resources 

across regional boundaries. Figure 2.1 below 

outlines the location of the UAC, different 

ICPs, and individual Branches. Branches are 

annotated as Staging Areas (S) only for the 

purposes of this graphic.

Figure 2.1: 

Command Locations as of July 16, 2010

After the Deepwater Horizon Mobile Offshore 

Drilling Unit sank on April 22, 2010, the fi rst FOSC 

was the Commanding Offi cer of the Marine Safety 

Unit (MSU) in Morgan City, La. The MSU Commanding Offi cer was assigned FOSC responsibility 

in the Area Contingency Plan, which was developed 

in accordance with the National Contingency Plan 

(NCP). From its outset the spill had the potential 

to impact several states, so the Sector Commander 

for Sector Mobile, whose area of operating responsibility covered Alabama, the Florida panhandle, 

and Mississippi, assumed the responsibilities of the 

FOSC for the Sector Mobile response area.

The process to make the Eighth District Commander 

the FOSC was not as clear-cut as the pre-designation of the Coast Guard Sector Commanders. 

While 40 CFR 300.120(a) clearly gave the district 

commander the authority to designate a FOSC, the 

regulations did not clearly designate that position 

ROBERT, La. – Rear Admiral Mary Landry (center), the Federal 

On-Scene Coordinator for the Deepwater Horizon incident, 

talks with U.S. Coast Guard Commandant Admiral Thad Allen 

(right) before his speech to the members of the Unifi ed Area 

Command. Photo courtesy of U.S. Coast Guard
4

2. Command and Control

as a FOSC, nor was it designated as such within 

the ACP. To remove any possibility for confusion, 

and because of the recognized potential for oil 

to impact several states, the Commandant of the 

Coast Guard designated the Eighth Coast Guard 

District Commander Rear Admiral Mary Landry as 

FOSC on April 23, 2010, without regard to district 

boundaries. On the same day, the newly named 

FOSC established the Unifi ed Area Command 

(UAC) in Robert, La., and became the Unifi ed 

Area Commander. The practice of having the Commandant designate a Deepwater Horizon Response 

FOSC continued until November 2010, when the 

authority to designate the FOSC 

returned to the Eighth District 

Commander. Following the FOSC 

designation, the U.S. Department 

of Homeland Security Secretary 

Napolitano declared the Deepwater Horizon spill a Spill of 

National Signifi cance and named 

Admiral Allen, then Commandant 

of the U.S. Coast Guard, as the 

National Incident Commander on 

May 1, 2010.

The FOSC has authority to direct 

response operations under Section 

311(c) of the Clean Water Act. The 

National Incident Commander did 

as well, at fi rst due to the authority 

of the Commandant of the Coast 

Guard, and after his retirement 

from the Coast Guard, through 

express delegation by the Secretary of DHS. Although the two roles had the potential for overlap, in practice a natural division of labor 

developed between the two. The National Incident 

Commander focused on unifying the government’s 

response, particularly at the inter-departmental level, 

external communications, and technical issues such 

as source control, assessing oil fl ow, and containing 

oil from the well, and issues emanating from the 

response that were outside the NCP. The FOSC 

focused on conducting the response, addressing the 

concerns of state and local leaders, and oil removal 

and mitigation measures across affected areas. In 

addition, the FOSC was responsible for approving 

all response related expenditures from the Oil Spill 

Liability Trust Fund (OSLTF), and also delegated 

some expenditure authority to the Incident Commanders in Houma and Mobile.

The Coast Guard was also sensitive to the NCP 

requirement that there be only one FOSC for the 

spill at any time. This requirement was refl ected in 

the organizational construct depicted in Figure 2.2 

below. The construct placed the FOSC in charge of 

directing response operations within the UAC and 

designated Incident Commands (ICs) at the ICPs 

located in Galveston, Texas, Houma, La., Houston, Texas, Miami, Fla., and Mobile, Ala. Each 

ICP Commander was furthermore designated as 

a FOSC Representative (FOSCR) with authorities 

specifi cally assigned. This designation was consistent with the NCP, and the Coast Guard delegation 

of authority in 33 CFR 1.01-85.

The National Oil and Hazardous Substances Pollution Contingency Plan, or NCP, is the federal government’s blueprint for responding to both oil spills 

and hazardous substance releases. Specifi cally, the 

NCP establishes the National Response System, 

a multi-tiered and coordinated national response 

strategy. Key components of the National Response 

System include the National Response Team (NRT), 

Regional Response Teams (RRTs) located throughout the country based on Environmental Protection 

Agency (EPA) Regions, Area Committees usually 

based on Coast Guard Captain of the Port zones for 

coastal areas, the FOSC, UAC, and the National 

Incident Commander.

Congress fi rst established the NCP in 1968 after the 

37 million gallon Torrey Canyon tanker spill off the 

coast of England. The Federal Water Quality Act of 

1970, which became the Clean Water Act in 1972, 

required the President to publish a NCP. Although 

a version of the NCP was in place at the time of the 

Exxon Valdez spill, Congress responded to that spill 

by passing the Oil Pollution Act of 1990 (OPA 90), 

which directed the President to expand the NCP. The 

authority to expand the NCP was later delegated to 

EPA, which implemented this mandate with amendments to the NCP promulgated in 1994.

The 1994 amendments to the NCP focused on 

expanding federal authority to coordinate effective communication and deployment of equipment. 

Specifi cally, the amendments prescribed additional 

responsibilities for the FOSC and strengthened 

their ability to direct the on-scene response. The 

amendments also called for the creation of Area 

Committees and Area Contingency Plans under the 

leadership of the FOSC. To ensure that contingency 

plans would result in companies and responders 

undertaking more realistic preparation for future 

GULF OF MEXICO – 

Department of Homeland 

Security Secretary 

Janet Napolitano and 

Environmental Protection 

Agency Administrator 

Lisa Jackson receive a 

brief from Rear Admiral 

Mary Landry, Federal 

On-Scene Coordinator for 

the Deepwater Horizon

incident, as they conduct 

an aerial survey of the Gulf 

Coast. Photo courtesy of 

U.S. Coast Guard
2. Command and Control

5

spills than they had for the Exxon Valdez disaster, 

the 1994 amendments required contingency plans 

to consider a worst-case discharge scenario.

The Role of the Responsible Party under the 

Oil Pollution Act of 1990

Under the OPA 90 framework, a responsible party 

(RP) is strictly and jointly liable for removal costs 

and certain damages in connection with a discharge 

of oil, or a substantial threat of a discharge of oil, into 

or upon the navigable waters, adjoining shorelines, 

or the exclusive economic zone of the United States.

The NCP directs that the RP play a role in the 

response. One of the principles of the unifi ed command structure directed by the NCP is that the RP 

must be included in order to “achieve an effective 

and effi cient response.”

The NCP provides that “cleanup responsibility for 

an oil discharge immediately falls on the responsible 

party,” and notes, “in a large percentage of oil discharges, the RP shall conduct the cleanup.” Though 

the NCP directs the FOSC to “monitor or direct all 

federal, state, local, and private removal actions,” 

the FOSC may “allow the responsible party to voluntarily and promptly perform removal actions” if 

the FOSC determines that having the responsible 

party perform such actions will “ensure an effective 

and immediate removal of the discharge.” In this 

situation, the FOSC supervises the RP’s actions. 

The NCP expresses a preference for setting up the 

response in this manner—“[w]here practicable, 

continuing efforts should be made to encourage 

response by responsible parties.” In a spill that 

“results in a substantial threat to the public health 

or welfare of the United States ... the [FOSC] must 

direct all response efforts.”

To accomplish its purpose the NCP gave the FOSC 

and the FOSC’s representatives a number of authorities. The response must be a unifi ed effort, coordinated with other federal agencies, state government, 

local government, any applicable tribal government, 

and private parties such as the RP as well as land 

and facility owners impacted by the spill. The FOSC 

can authorize expenditures from the OSLTF to pay 

for federal and state expenses stemming from the 

response. If there is no RP, or the RP proves unable 

or unwilling to fund cleanup efforts, the FOSC can 

take over the spill and fund all response efforts from 

the OSLTF. The FOSC can issue administrative 

orders to the RP directing specifi c response actions 

be taken. And while required to work within a unifi ed command, the NCP gives the FOSC the fi nal 

say in the response to an oil spill.

For the Deepwater Horizon spill, BP accepted its 

responsibility as an RP under OPA 90 and the NCP 

to respond to the oil spill. Even though the RP participated in the UAC structure at every level of the 

response, the FOSC and the FOSC’s representatives 

directed RP actions. This was done daily in the form 

of Incident Action Plans (IAPs) and also in the form 

of NIC and FOSC directives to the RP.

Figure 2.2: 

Unifi ed Area Command
6

2. Command and Control

2.2 National Incident Command

The Deepwater Horizon oil spill was the fi rst 

incident in U.S. history to be declared a Spill of 

National Signifi cance, and the fi rst to designate a 

National Incident Commander. After being named 

the National Incident Commander by the DHS 

Secretary following the SONS declaration, Admiral Allen established an NIC in Washington, DC, 

to coordinate the entire government response to 

the incident. 

The National Incident Commander issued his own 

report on October 1, 2010. From the perspective of 

the FOSC, the National Incident Commander performed the duties as defi ned in 40 CFR 300.323, 

which states:

The National Incident Commander will assume 

the role of the FOSC in communicating with 

affected parties and the public, and coordinating federal, state, local, and international 

resources at the national level. This strategic 

coordination will involve, as 

appropriate, the NRT, RRT, 

the Governor(s) of affected 

state(s), and the mayor(s) 

or other chief executive(s) of 

local government(s).

The Coast Guard further 

described the National Incident Commander’s responsibilities in a SONS response 

contained in the draft Commandant Instruction: Spills 

of National Significance 

Response Management System. These responsibilities expand on the NCP guidelines to include 

leading national level communications and developing strategic objectives, coordinating interagency issues, coordinating federal, state, local, 

and international resources, and overseeing UAC 

activities for effective response.

As the National Incident Commander, Admiral 

Allen followed the doctrine outlined in the NCP 

and assumed the responsibilities for addressing 

and coordinating national-level issues. At the same 

time, Homeland Security Presidential Directive-5 

(HSPD-5), signed in 2003, establishes the framework for the federal government’s response to 

national disasters requiring interagency coordination. Under this directive, the Secretary of Homeland Security is designated as the Principal Federal 

Offi cial for domestic incident management. Deepwater Horizon, as the fi rst Spill of National Signifi cance, presented the fi rst occasion to consider 

how the NCP structure for addressing a SONS 

would function with the HSPD-5 overarching 

framework for managing a national disaster. Early 

in the response, it was determined that the NCP 

would be executed, and that the National Incident 

Commander would carry out his role under the 

NCP. This would take place within an overarching HSPD-5 framework in which the Secretary, as 

the PFO designated by the President, maintained 

overarching responsibility for coordinating the 

whole-of-government response, particularly at 

the Cabinet level.

Spill of National Signifi cance 

The Spill of National Signifi cance operational 

doctrine was tested in the exercise environment, 

but while it developed over multiple SONS exercises, the doctrine also continued to evolve during 

the course of this response. The NIC’s role was 

strategic and operational, and extended beyond 

traditional spill response actions to include, for 

example, resolution of public health and seafood 

safety concerns, and adjudication of claims. In 

some cases, the National Incident Commander 

engaged in operational decision-making, working 

directly with the FOSC, state and local elected 

offi cials, and the RP. 

Although this was the fi rst declared SONS event 

and use of a National Incident Commander, previous experience was gained through regular SONS 

exercises conducted since the post-Exxon Valdez

rewrite of the NCP. The experience was essential 

ROBERT, La. – U.S. Coast 

Guard Commandant 

Admiral Thad Allen meets 

with Rear Admiral Mary 

Landry and other local, 

state, and federal members 

participating in the Unifi ed 

Area Command. Photo 

Courtesy of U.S. Coast 

Guard

GULF OF MEXICO-Federal 

On Scene Coordinator Rear 

Admiral James Watson 

meets with the owner of a 

collection barge regarding 

oil skimming operations. 

Photo courtesy of U.S. Coast 

Guard
2. Command and Control

7

to the effectiveness of the entire response organization. The Coast Guard and government agencies 

held a SONS exercise in New England in March 

2010. The planning for that exercise did much to 

defi ne the processes to establish a NIC staff and 

implement the entire response organization for 

a SONS event, which included a UAC. Senior 

DHS offi cials participated in the SONS exercise. 

The Assistant Secretary for Intergovernmental 

Affairs led the DHS contingent at the drill, and 

was a key advisor to the NIC in working with state 

and local offi cials during the Deepwater Horizon

response. In addition, many of the key planners and 

participants in the SONS 2010 exercise became 

part of the Deepwater Horizon NIC or UAC staff. 

Thus, while formal doctrine for SONS events was 

still under development, there was extensive, and 

recent, experience with the details of a large scale 

SONS response. 

An exercise environment, however, is not the 

same as a bona fi de Spill of National Signifi cance. 

Actual establishment of a National Incident Commander was unprecedented. The exercise process 

did not take into account that the federal governance structure for oil spill response, the NCP, was 

not familiar to the impacted communities. Because 

of repeated national disasters and emergency declarations, these communities were accustomed to 

a state-centric response organization under the 

Stafford Act.

The SONS designation and the appointment of a 

National Incident Commander still had many benefi cial impacts. The SONS designation assisted with 

the ability to secure equipment, people, and other 

resources from throughout the federal government to participate in the response. The National 

Incident Commander designation emphasized the 

importance of the national and government effort 

to respond to this spill. 

The NCP states that with a SONS declaration, the 

National Incident Commander “will assume the 

role of the On-Scene Coordinator (OSC) in communicating with affected parties and the public, 

and coordinating federal, state, local, and international resources at the national level.” The NCP 

did not address all of the key issues that came 

Figure 2.3: U.S. Government Response
8

2. Command and Control

up in the response. The National Incident Commander, interacting with cabinet level offi cials, had 

to adjudicate some of these issues. An example 

was seafood sampling to ensure the safety of Gulf 

of Mexico seafood. The National Incident Commander role proved very effective in covering the 

considerable public relations duties to include 

explaining the response efforts to the public. As 

the single, named leader of the federal government’s efforts to respond to the spill, the National 

Incident Commander minimized duplication of 

effort by giving external stakeholders, including 

the national media, one individual to address all 

issues associated with the spill. This aspect of the 

National Incident Commander role also helped 

with public concerns regarding who was in charge 

of the response. 

The National Incident Commander directed the 

RP to take a number of actions. In day-to-day 

coordination and decision-making, the FOSC 

issued requirements. The RP complied with direction from both sources. Because the roles of the 

National Incident Commander and FOSC allowed 

for the possibility of overlapping direction, daily 

coordination among the FOSC, the National Incident Commander, and NIC staff occurred through 

conference calls and prior to daily meetings, governor’s calls, press events, and at other times of 

signifi cant decisionmaking.

NIC Interagency Solutions Group

The National Incident Commander developed a 

number of groups that tackled different aspects 

of the response and policy coordination tasks. 

Of these groups, one with signifi cant impact on 

the FOSC was the Interagency Solutions Group 

(IASG) that evolved to fi ll the role of the NRT. 

When the Deepwater Horizon sank on April 22, 

2010, Admiral Allen requested a meeting of the 

NRT as the Commandant. His intent was to employ 

this long-standing interagency coordinating body 

in support of the deepening crises and potential for 

a catastrophic oil release.

The NRT is comprised of 15 federal agencies 

responsible for developing, de-confl icting, and 

reconciling intergovernmental policy issues that 

surface during an oil spill response. During the 

response, the the Secretary of Homeland Security 

exercised oversight over the NRT in accordance 

with guidance developed in the early stages of the 

response effort, and the Deputy Secretary of Homeland Security presided over NRT meetings and conference calls. When a spill involves a substantial 

threat to public health and welfare, the NRT may 

be activated as an emergency response team. The 

primary role of the NRT is to monitor the response 

actions and provide counsel and recommendations 

to the NIC to assist in the response. During activation, the NRT may support RRTs—the regional 

interagency bodies—with recommended actions to 

combat the spill, requests of other Federal, state, 

tribal, and local governments or private agencies 

to provide resources, and coordination of the supply of equipment, personnel, or technical advice. 

During the Deepwater Horizon incident, the NRT 

held nearly 50 separate meetings and briefi ngs to 

coordinate national efforts for the incident.

The primary challenge to the role of the NRT was 

that, in order to carry out its roles, interagency 

coordination needed to occur at the Departmental level. This was signifi cantly above the level at 

which the NRT typically operated and was not the 

level articulated in the NCP. Direct engagement 

by Cabinet-level offi cials from the outset of this 

response redirected the NRT to the role of support 

to intra-Cabinet communications and briefi ngs.

To provide the originally intended functions of the 

NRT, the Coast Guard created a new organization 

named the Interagency Solutions Group (IASG) 

within the NIC. The IASG essentially assumed the 

doctrinal responsibilities of the NRT, and proved 

adept in promoting interagency unity of effort.

The IASG became a self-contained interagency 

body, with decision-making authority, capable of 

resolving time-sensitive policy issues. The group 

ROBERT, La. – U.S. Coast 

Guard Commandant 

Admiral Thad Allen speaks 

with local, state, and 

federal members at the 

Unifi ed Area Command 

during an all-hands 

meeting. Photo courtesy of 

U.S. Coast Guard
2. Command and Control

9

had representatives from 20 federal agencies and 

Departments. At the height of the response, there 

were 25 to 35 experts present each day in the IASG 

spaces. The rest of the 122 IASG members worked 

remotely from their own agency locations or on the 

Gulf Coast at the various command posts or other 

facilities. Nearly all recommendations that emerged 

from the IASG were the result of group consensus.

During the course of the response, the IASG teams:

• Finalized fl ow rate calculations for the 

Macondo well,

• Published an oil budget model to address 

the fate of the oil,

• Reviewed physical countermeasure proposals for consideration by the FOSC,

• Reviewed 24 proposals, valued at $500 

million, in proposed emergency restoration initiatives; these were of concern to 

the NIC and other agencies but fell outside 

the scope of FOSC responsibilities,

• Reviewed more than 3,900 proposals to 

leverage innovative oil spill response 

technologies,

• Provided weekly outreach to over 600 

environmentally focused non-governmental organizations to explain ongoing response activities and address caller 

concerns.

• Integrated the federal government 

response to local and regional government and non-government entities in 21 of 

the most impacted counties and parishes 

along the Gulf of Mexico,

• Developed seafood safety protocols 

regarding closed fi sheries, and

• Reviewed an extensive subsurface oil 

detection program to identify recoverable oil.

In an effort to manage the constantly changing 

scope of work, the IASG formed teams into the 

following seven areas of emphasis:

1. Countermeasures and Alternative Technologies;

2. Community Engagement; 

3. Flow Rate and Sub-sea Analysis; 

4. Economic Solutions; 

5. Environmental, Archeological, and Cultural 

Protection Strategies; 

6. Integrated Services; and

7. Public Health and Worker Safety.

2.3 Unifi ed Area Command

On April 23, 2010, the UAC was established in 

Robert, La., with the FOSC assigned as the Unifi ed 

Area Commander. The UAC’s principal focus was 

directing, supporting, and assisting the ICPs, and 

coordinating with the RP and each affected state. 

The FOSC, RP, and state representatives worked 

together to fi ll operational resource requests and 

address state-by-state concerns with the ongoing operation. The FOSC met regularly with key 

stakeholders, including the governors of each Gulf 

Coast state, and established critical lines of communication to remove obstacles. Daily conference 

calls with the impacted states’ governors facilitated 

open and continuous dialogue.

The key role of the UAC was to standardize practices across the response and broker resources, 

particularly boom, skimmers, and personnel. There 

was some early confusion outside the UAC and 

the Coast Guard as to who from the Coast Guard 

was actually in charge of the response, and who 

had operational and tactical control of assets in the 

response. Within the Coast Guard, the question 

of who was in charge was less ambiguous: the 

Staging Areas worked for the Branches and the 

Branches worked for the FOSCR assigned to the 

ICP, who then worked for the FOSC and UAC. 

The scope of the FOSCR role and the connection 

with the FOSC evolved to refl ect the growing size 

and complexity of the response.

The FOSC established a daily battle rhythm for 

interaction with the response organization and 

stakeholders early on and these practices continued 

throughout the response. A snapshot of the daily 

battle rhythm from key points during the response 

is included in Figure 2.4 below. The Unifi ed Area 

Commander and Incident Commands held daily 

conference calls at 7:00 a.m. and 5:30 p.m. Participating in these discussions were the FOSC, FOSCRs, RP, State On-Scene Coordinators’ (SOSC) 

Representatives or other state representatives, and 

other senior federal representatives at the UAC and 

ICPs. The NIC staff was invited to listen to obtain 

a current operational picture. Safety was the fi rst 

issue discussed every meeting. Forecasted weather 

and critical situations on the sea fl oor that could 

impact source control were also discussed.

Meetings included a review of strategic objectives 

and critical spill response resources. Resources 

were reviewed to evolve business metrics for 
10

2. Command and Control

tracking the effectiveness of the response. Metrics 

were a way of measuring accomplishments and 

progress, and were designed to motivate responders who were putting forth an extraordinary effort 

in the response. The ultimate goal was to follow 

the Best Response Model doctrine outlined in the 

OSC Crisis Management Course, which was comprehensive in its approach to spill response.

In order to inform, communicate, and establish 

strategies to improve the response effort, the UAC 

began regular deep-dives into numerous topics 

including safety, shoreline cleanup, decontamination, and waste management. These meetings were 

conducted in conjunction with the daily ICP brief 

and kept UAC decision makers on current operations, enabling them to direct the response and 

adjust priorities more effectively. The deep-dives 

were also utilized in strategic planning.

Regional Response Team Involvement at the 

Unifi ed Area Command

The Deepwater Horizon spill affected the RRTs 

for Region IV and Region VI—RRT IV includes 

the states of Alabama, Florida, and Mississippi, 

and RRT VI, the states of Louisiana and Texas.

Under 40 CFR 300.115, RRTs are responsible for 

Table 2.1: Battle Rhythm

Deepwater Horizon/Mississippi Canyon 252/BP (UAC) —all times are Central Standard Time

Battle Rhythm: 

Monday. May 24, 2010 

Battle Rhythm: 

Tuesday, June 15, 2010 

Battle Rhythm: 

Thursday, July 8, 2010

Battle Rhythm: 

Thursday, September 9, 2010

Time Meeting Meeting Meeting Meeting

6:00 AM Operations Brief Shift Change

6:30 AM NIC Senior Leader Call

7:00 AM Area Command/Incident Command 

Brief

NIC Senior Leader Call

7:30 AM Area Command/Unifi ed Command Brief Area Command/Unifi ed 

Command Brief (Tuesday)

7:45 AM Incident Command/Unifi ed Command 

Objectives

8:00 AM DHS Secretary call DHS Secretary call (M-W-F)

8:00 AM DOI and DOE call

8:05 AM Daily Coordination Call Governor’s/NIC Conference Call 

(Thursday)

8:15 AM Daily Governor’s/NIC Conference Call

9:00 AM Command and General Staff Meeting Command and General Staff Meeting

9:45 AM ICP Briefi ng ICP Briefi ng

10:00 AM Boom Task Force Boom Task Force NRT Conference Call (Tuesday & Friday)

11:00 AM Pre Tactics - How to meet next periods 

objectives

Pre Tactics - How to meet next periods 

objectives

12:00 PM Joint Operations Brief

01:00 PM Tactics Meeting - Finalize strategy to 

meet objectives

01:45 PM Planning Section Alignment

02:00 PM Tactics Meeting - Finalize strategy to 

meet objectives

03:00 PM Planning Section Alignment - Strategic

03:30 PM Branch Planners Meeting

04:30 PM Planning Meeting Planning Meeting

05:30 PM Shift Change Area Command/Incident Command 

Brief

06:00 PM Operations Brief Shift Change & Shift Change Brief PPLO Call

08:00 PM Data Integration Meeting

09:30 PM Planning Section Alignment - Strategic

010:20 PM Data Integration Meeting

011:00 PM Situation Status

3:30 AM Command and General Staff Meeting Command and General Staff Meeting

5:30 AM Shift Change
2. Command and Control

11

regional planning and coordination of preparedness and response action. The RRT membership 

includes representatives from each of the 15 NRT 

agencies, as well as regional representatives from 

the affected states and tribal governments where 

appropriate. The EPA and Coast Guard co-chair 

the RRTs, among other responder stakeholders. 

There are ten RRTs in the United States. The EPA, 

affected states, and natural resource trustees on 

the RRT have specifi c dispersant and chemical 

countermeasures decision authority for both preauthorization plans and incident-specifi c decisions 

per 40 CFR 300.910.

During the Deepwater Horizon response, RRT 

VI was closely involved with the FOSC and Unifi ed Area Commander. The RRT advised the UAC 

regarding in situ burning, chemical dispersants, 

response techniques, and agency participation.

There were 26 incident-specifi c RRT VI meetings 

via teleconference between the start of the incident 

on April 20, and December. During the early weeks 

of the spill, RRT VI held incident-specifi c calls 

regularly. Topics of discussion included agency 

participation, use of in situ burns, use of dispersants and surface washing agents and solidifi ers, 

and bioremediation techniques, such as those suggested in the Louisiana marshes and discussed 

below. RRT IV teleconferences were less frequent, 

largely because there were no plans to use dispersants or in situ burning in RRT IV areas. RRT IV 

engagement generally involved coordination, situational awareness, and the potential for alternate 

spill response technologies.

Once the sub-sea well was closed, the frequency 

of RRT calls diminished. With offshore response 

techniques no longer an issue, the remaining calls 

focused on dispersants and surface washing agents 

to issues associated with beach cleanup and bioremediation techniques.

Although both RRTs worked to carry out their 

assigned role, there were several notable challenges to their efforts. At times, senior offi cials 

engaged directly with the FOSC on tactical topics 

without working through the NIC or RRT. Another 

RRT challenge involved the states and waste 

removal. The states—Alabama, Florida, Louisiana, and Mississippi—were already delegated the 

authority to enforce the Resource Conservation 

and Recovery Act and coordinate waste management and activities. These responsibilities were 

clearly outlined in the Area Contingency Plans, 

and had been approved by FOSCs and District 

Commanders each year for the previous ten years. 

The Mobile and Houma ICPs had approved those 

plans in conjunction with the affected states and 

EPA personnel on-scene. Separately, however, 

EPA drafted a waste management directive and 

requested that the FOSC issue it to the RP.

Natural Resource Trustees Involvement at 

the Unifi ed Area Command

Designated Natural Resource Trustees include federal, state, Indian Tribes, or foreign offi cials who 

act on behalf of their jurisdiction in the interests 

of the natural resources, per the NCP, 40 CFR 

300.600, and other statutory authorities such as 

OPA 90, FWPCA, National Marine Sanctuaries Act 

(16 U.S.C. 1431 et seq.), Park System Resource 

Protection Act (16 U.S.C. 19 JJ), and applicable 

state laws. During spill response, natural resource 

trustees advise the FOSC on means to minimize 

natural resource injuries; assess natural resource 

damages that do occur and the public’s lost use 

of damaged natural resources; and to obtain compensation from the RP to (i) restore injured natural 

resources to baseline conditions and (ii) to account 

for interim losses of natural resources and services 

that occur from the date of the incident until recovery. Such advisors worked in the UAC and ICPs 

throughout the response. The Natural Resource 

Figure 2.4: Regional Response Team (RRT)
12

2. Command and Control

Damage Assessment (NRDA) process, overseen 

by the Trustees, began shortly after the spill with 

separately focused teams from trustee agencies. 

NRDA members were independent of the FOSC 

response activities, and had segregated spaces provided in the UAC.

Tribal involvement at the Unifi ed Area 

Command

Executive Order 13175, Consultation and Coordination with Indian Tribes, requires an accountable 

process to ensure meaningful and timely input by 

tribal offi cials in the development of regulatory 

policies that have tribal implications. The U.S. 

Government has additional unique legal relationships with Indian Tribes as set forth in the Constitution, executive orders, treaties, statutes, and 

court decisions. Government-to-government relations with recognized Indian Tribes (as defi ned in 

40 CFR 300.5) were guided not only by 40 CFR 

300.180, but also by the Programmatic Agreement for the Protection of Historic Properties 

During Federal Emergency Response. The FOSC 

coordinated tribal input into response activities, 

as outlined in Chapter 8, early in the response, 

and initiated regular government-to-government 

consultations with the eleven federally recognized tribes with traditional cultural properties in 

impacted areas over the course of the response.

FOSC Key Points: State Integration into 

Unifi ed Command

The NCP contemplates a robust role for states in 

the unifi ed command structure. In the Deepwater 

Horizon response some states essentially did not 

embrace their role, by either not participating in 

the unifi ed command, or by not empowering their 

representatives to make decisions. Because of the 

high visibility and broad impact of any major spill, 

it is to be expected that more of state government 

than the oil spill response specialists will have to 

be involved. The NCP needs to anticipate such 

needs and fi nd a way to still integrate state participation in the unifi ed command construct.

NEW ORLEANS – Rear 

Admiral Paul Zukunft, 

the Federal On-Scene 

Coordinator for the 

Deepwater Horizon 

response, speaks to 

governmental members 

of federally recognized 

Native American tribes 

during a government-togovernment consultation. 

Photo courtesy of U.S. Coast 

Guard 
2. Command and Control

13

2.4 Incident Command Posts

The command staff at both ICP Mobile and Houma 

did not know the exact size or potential for the 

spill, but assumed an uncontrolled major ongoing 

release. Therefore, the UAC planned for a 24-hour, 

seven-day-a-week, fully staffed ICS organization 

for an unknown duration. The Coast Guard and 

the RP began to mobilize personnel immediately. 

Coast Guard personnel from MSU Morgan City, 

MSU Houma, Sector Mobile, and a core of RP 

employees staffed the initial ICS Section Chief 

and Deputy Section Chief positions as the ICS 

organizations grew.

Due to proximity to the incident, the operational 

tempo, the complexity of response and communications challenges, the FOSCRs on occasion 

had to make decisions and exercise initiatives and 

authorities traditionally outside those typical of a 

FOSCR. While normally unnecessary for lesser 

spills, the ability of the FOSCRs to make these 

decisions refl ected both the trust the UAC had in 

them and the span of control issues engendered 

by the size of the response operation.

ICP Houma Command Structure

The ICP Houma command staff included the 

FOSCR and fi ve Deputies. The assignment of 

Deputies became useful in dividing the substantial tasking originating from the spill, stakeholders, the media, and the chain of command. The 

Coast Guard assumed responsibilities for external 

activities such as distinguished visitors, media 

interviews, consultations with parish presidents, 

and visiting the fi eld to ensure operations occurred 

in accordance with the Incident Action Plan (IAP). 

Senior ranking Coast Guard Deputies assumed 

responsibilities for ensuring internal operations. 

One deputy oversaw the Incident Management 

Team processes for the FOSCR and was designated as a FOSCR by the FOSC. The Deputy 

was responsible for attending all ICP regularly 

occurring meetings including the planning process meetings, making decisions based on the 

UAC objectives, and helping ensure that the ICP 

activities would not be negatively impacted by 

the physical absence of the FOSCR. In addition, 

a Coast Guard Deputy for External Affairs—and 

initially a Coast Guard Deputy for Coast Guard 

Resources—was designated. This latter position 

was only temporary until the Coast Guard forces 

began to fl ow predictably into the fi eld. Later in 

the response, the Coast Guard appointed a Coast 

Guard Deputy for Operations to assume the operational quality control check duties of the FOSCR. 

The RP provided representatives to ICP Houma, 

who were actively involved in day-to-day ICP 

operations and planning.

ICP Mobile Command Structure

Approximately one week into the spill response, it 

became clear the response organization would have 

to grow to include ICPs in other geographic locations along the Gulf Coast. The span of control, 

state and local jurisdictional lines, and response 

demands did not allow for a single organization 

out of ICP Houma to manage all aspects of the 

response.

ICP Mobile was established on April 26, 2010, and 

was initially staffed with Sector Mobile personnel. 

ICP Mobile grew exponentially in the following 

days as the UAC dispatched a number of key RP 

and contractor personnel from Houma to Mobile. 

The increase in personnel served to reinforce ICP 

HOUMA, La. – U.S. Coast Guard Captain Roger 

Laferriere, the Incident Command Post Houma 

Incident Commander, speaks to the public at an open 

house event. Photo courtesy of U.S. Coast Guard
14

2. Command and Control

Mobile as oil trajectories projected an increasing 

threat to the coastlines of Alabama, the Florida 

panhandle, and Mississippi.

The Coast Guard Sector Commander for Mobile 

was named the FOSCR of ICP Mobile. The FOSCR 

expended considerable effort, signifi cantly assisted 

by existing relationships with the three states in his 

area of responsibility, to encourage Alabama, Florida, and Mississippi to join a single command post 

for their region centralized in Mobile rather than a 

command post in each state. Preserving the unity 

of command for the three states was essential. The 

unity helped ensure response agility in the interconnected and integrated waterways in the area, 

allowed for the shifting of resources throughout 

a single Coast Guard Sector boundary (especially 

offshore and near-shore skimmers), and avoided 

trifurcating Captain of the Port responsibilities. 

With some signifi cant organizational adjustments 

that improved local ownership and involvement in 

tactical planning, ICP Mobile retained responsibility for the directing response in the three-state 

area until efforts were consolidated into the Gulf 

Coast Incident Management Team (GC–IMT) on 

September 20, 2011.

The ICP Mobile FOSCR created Deputy Federal 

On-Scene Coordinator (Deputy FOSCR) positions to respond to the large operational response 

area. One Coast Guard Deputy remained at ICP 

Mobile to direct overall response operations. Other 

Deputies were designated as available to assist 

with daily ICP functioning. A senior Coast Guard 

offi cer, designated as the Chief of Staff for ICP 

Mobile, managed Coast Guard personnel and 

overall information fl ow. Three additional Coast 

Guard deputies, along with RP deputy counterparts, forward deployed to Alabama, Florida, and 

Mississippi, in June 2010. Each was deployed with 

a small Incident Management Team to direct tactical planning and tactical operations. The Deputies 

worked directly with the staffs of the Alabama, 

Florida, and Mississippi governors, and provided a 

direct link to the FOSCR. These Deputies worked 

for the ICP Mobile FOSCR. As such, ICP Mobile 

set the daily response priorities and objectives and 

developed the Incident Action Plan with input from 

the Branches. Deputies managed resources and 

logistics, and coordinated overall response operations and outreach, including strategic and public 

communications. The state deputies were authorized to conduct tactical planning and direct tactical operations through the Branches. The Deputies 

also performed local outreach to execute the IAP 

with respect to inshore skimming, booming, beach 

cleanup, and Vessels of Opportunity (VOO). ICP 

Mobile retained operational and tactical control 

of offshore and near-shore skimming because the 

task forces routinely worked across state boundaries and skimmers were mixed to provide optimum 

results.

THEODORE, Ala. – U.S. 

Coast Guard Captain 

Steven Poulin, the Incident 

Command Post Mobile, 

Incident Commander, 

conducts a media 

interview at the Theodore 

Staging Area. Photo 

courtesy of U.S. Coast 

Guard

PENSACOLA, Fla. – Vice Adm. Robert C. Parker (center), 

Atlantic Area Commander, Rear Adm. Mary Landry (right), 

and the Coast Guard Atlantic and Pacifi c Area Command 

Master Chiefs (left) listen to a briefi ng at the Bayou Chico 

Staging Area, Fla. Photo courtesy of U.S. Coast Guard
2. Command and Control

15

ICP Houston

While the ICPs in Mobile and Houma took shape, 

the FOSC and FOSCR determined that a technical group currently working in Houston would be 

organized into an ICP under ICP Houma. At the 

beginning of the response, Coast Guard members 

deployed to Houston. ICP Houma implemented a 

virtual UAC by establishing a video teleconference 

link with the ICP in Houston. The two ICPs developed separate response plans (known as Incident 

Action Plans) because of their geographic separation and the differences in the nature of the work 

conducted at the two ICPs. Over the next several 

days, the ICS organization in both Houma and 

Houston fi lled out and these commands established 

regular meeting schedules and mechanisms for 

information and document exchange. Under the 

new design, ICP Houston would focus on well 

intervention and source control, while the ICPs 

in Houma and Mobile would focus on response.

Five ICPs were eventually created. ICPs coordinated operations with local and regional elected 

offi cials. ICP Houston coordinated source control 

activities at the wellhead, engineering discussions, 

and the potential courses of action to secure the 

source. Houston, Texas, also led source control 

planning and operations, including sub-surface 

dispersant operations, and reported directly to the 

UAC. ICP Houma managed offshore response 

operations surrounding the wellhead, near-shore, 

and shoreline Louisiana response operations. The 

ICP in Mobile, Ala., managed offshore, near-shore, 

and shoreline response operations for Alabama, 

the Florida panhandle, and Mississippi. The ICP 

in Miami, Fla., managed near-shore and shoreline 

response operations the West Coast of Florida, 

although no oil reached the ICP Miami area. The 

ICP in Galveston, Texas, managed similar operations for the State of Texas, although a minimal 

number of tar balls reached the state.

PENSACOLA, Fla. – Vice 

Admiral Robert C. Parker, 

Atlantic Area Commander, 

and Rear Admiral Mary 

Landry are briefed at 

the Florida Emergency 

Management Mobile 

Command Post at the 

Bayou Chico Staging Area. 

Photo courtesy of U.S. Coast 

Guard

GALVESTON, Texas – Coast 

Guard Captain Marcus 

Woodring, Federal On-Scene 

Coordinator Representative 

for the Texas portion of the 

Deepwater Horizon oil spill 

response, and Rob Hadley, a 

response offi cer for the Texas 

General Land Offi ce, review 

maps of potential oil slicks 

off the Texas coast. Photo 

courtesy of U.S. Coast Guard
16

2. Command and Control

The size and complexity of the spill response presented many organizational challenges. As individual fi eld elements of the response organization 

were working intensely, it was very diffi cult to 

maintain situational awareness across the entire 

response. Maintaining unity of effort across such a 

large organization spread and geographic area was 

diffi cult. The ICPs held daily all hands meetings. 

At these meetings there was continuous focus on 

safety, unity of effort, and discussion about the 

importance of each aspect of the response organization to the success of the overall response effort.

Federal Agency involvement at the Incident 

Command Posts

Federal agency representatives held positions at 

the ICPs and were actively involved in planning 

and executing the ICS planning process. A few 

supporting agencies developed their own ICS 

organizations outside the UAC. An example is 

the tactics meeting and incident action plan (IAP) 

preparation. The tactics meeting for developing the 

IAP for the Deepwater Horizon response required 

signifi cant investment in time and energy. Some 

of the supporting agencies found the process too 

burdensome and time consuming, and decided to 

conduct their own tactics meetings and develop 

their own IAPs. Because their plans were more 

limited, involved fewer stakeholders, and could 

be completed more quickly, they decided to go 

outside the UAC process. Initially they did so 

without consulting the ICP.

By creating their own IAPs, the agencies had to 

have their own planning and operations sections. 

Agencies were also bringing in or purchasing their 

own resources while existing resources were available; this led to duplication of effort. Eventually, 

the Coast Guard brought these agencies into a 

single unifi ed command under the single IAP, in 

part because this was a condition of funding via 

Pollution Removal Funding Authorizations.

At ICP Mobile, the EPA and National Park Service 

(NPS) participated as On-Scene Coordinators. This 

varied from the traditional ICS structure, but was 

based on existing relationships with regional EPA 

and NPS staffs. The FOSCR recognized NPS as a 

signifi cant landholder in the Sector Mobile AOR, 

thus it was important to have them participate in 

the incident command.

State involvement at the Incident 

Command Posts

The NCP provided that response operations at the 

state and local levels would require active state 

involvement at all levels of the organization. The 

SOSC represented the state’s interests in response 

operations. This is especially the case regarding 

specifi c state and local government interests, strategic communications, and community outreach 

activities. During the Deepwater Horizon response, 

each state governor designated a state offi ce and 

representative to represent the state at the ICP and 

UAC levels. This lead state response offi cial was 

responsible for coordinating and communicating 

with all other state agencies. State agency representatives did not have decision-making authority for all response-related matters as required by 

the NCP. When necessary, those representatives 

would defer to an authority outside the ICPs and 

UAC. This caused delays in obtaining state concurrence. This also supported public perception that 

the Coast Guard and the RP were too close and 

were leaving out the states.

Some problems arose because state and local government offi cials outside the NCP structure were 

unfamiliar with the OPA 90 and applying the NCP 

doctrine to a major oil spill. This was not necessarily true of state agencies regularly involved in 

spill planning, exercises, and response. However, 

because of the scope of the spill, agencies that did 

not regularly work on spill responses and were 

generally unfamiliar with NCP response guidelines, participated signifi cantly.

Integration of Local Emergency Entities 

at the Incident Command Posts

Continuous engagement of 

parish president’s and the 

Louisiana Governor’s Offi ce 

of Homeland Security and 

Emergency Preparedness 

(GOHSEP) into the ICP 

Houma unifi ed command 

structure was necessary to 

ensure local cooperation 

and coordination.

NEW ORLEANS, La. – Rear Admiral 

Zukunft briefs a few parish 

presidents on the fl ight plan for a 

trip to the Deepwater Horizon spill 

site on a HC-144 Ocean Sentry. Photo 

courtesy of U.S. Coast Guard
2. Command and Control

17

As more oil impacted the shoreline, the people 

and government of Louisiana became frustrated. 

This became evident in the fi rst meetings with 

GOHSEP representatives and parish presidents. 

The response organization, from the NIC level to 

the Branch level, took actions to integrate parish 

leadership and local emergency response organizations into the response effort. The more closely 

local government was integrated into the rest of the 

unifi ed response organization, the more effective 

and effi cient local participation became.

The National Incident Commander implemented 

the Parish President Liaison Offi cer (PPLO) Program, which assigned Coast Guard Liaison Offi -

cers (LNOs) to parish presidents, governors, and 

some mayors whose jurisdictions were the most 

impacted. A Coast Guard member, who was designated as a FOSC Deputy for External Affairs, 

supervised the LNOs and worked directly for ICP 

Houma. This member had direct access to the UAC 

and the authority to make decisions in the fi eld to 

address a major crisis within each jurisdiction.

ICP Houma installed WEB Emergency Operations Center (WEB EOC), an emergency communications program used by GOHSEP, to ensure 

connectivity with all Louisiana EOCs. A portable 

GOHSEP Command Post stationed in Houma 

facilitated the program. This improved communications between the Houma ICP and the parish presidents. Reports of new oil sightings were 

communicated via WEB EOC and allowed the 

Houma ICP to react quickly and work in unison 

with parish emergency response forces. The FOSC 

held weekly meetings with parish presidents and 

GOHSEP representatives. LNOs were also placed 

within the GOHSEP EOCs to ensure ICP Houma 

addressed local needs.

As ICP Mobile was established, the Coast Guard 

assigned LNOs to the EOCs for the states and 

some of the larger counties in Alabama, Florida, 

and Mississippi. Alabama also established a forward EOC in Mobile. Synergy among the state, 

EOC, and county LNOs improved the span of control. The LNOs provided situational awareness 

to county emergency managers and responded to 

queries from local elected offi cials. As Branches 

expanded to accommodate local involvement, and 

the Deputy FOSCRs directed the tactical response 

through the Branches, the integration of the LNOs 

within the Branches correspondingly improved.

2.5 Branches and Staging Areas

The decision to have one UAC and one FOSC 

rather than multiple area commands for the Gulf 

Coast area had down-stream effects. One signifi cant 

impact was Branch level organization and tasking.

Typically, Branches at the ICS organizational level 

have functional responsibility for major segments 

of incident operation. The Branch level is situated 

organizationally between sections and groups in 

the Operations Section, and between sections and 

units in the Logistics Section. For examples, the Air 

Operations Branch under the Operations Section 

and the Supply Branch under the Logistics Section 

are types of functional–oriented Branches designed 

under ICS. Early in May 2010, the Coast Guard 

recognized that the ICS organizations operating 

at the parish level in Louisiana were operating as 

Incident Management Teams (IMTs). IMTs are part 

of the incident command system and manage the 

logistical, fi scal, planning, operational, safety, and 

community issues related to the incident. As the 

response organization under ICP Mobile grew, the 

same issue arose in the individual states.

Figure 2.5: Unifi ed Incident 

Command Structure
18

2. Command and Control

The Coast Guard designated parish and county operations as Branches (or forward operating bases) in 

Alabama, Florida, Louisiana, and Mississippi. This 

brought the Coast Guard closer to the front lines of 

the response without sacrifi cing operational unity 

and control or creating demands beyond available 

personnel resources. It also provided more interaction at the local level. The ICS system is designed 

to expand and contract as required to manage a 

response. The use of a large, IMT style Branch 

structure represented a new level of organizational 

expansion for the ICS system, which had not been 

applied in previous responses. Over time, the 

Coast Guard staffed the Branches to accomplish 

all ICS functions including planning, operations, 

and logistics.

ICP Houma Branch Structure

There was debate as to whether to establish ICPs 

in each of the likely-affected parishes, complete 

with a FOSCR and Deputy FOSCRs with a full 

ICS organization. Due to the demands for a consistent and accurate information fl ow and the 

established ICS organization and supply chain, 

ICP Houma determined that Branches would 

report to the Operations Section of ICP Houma. 

Another consideration was that the federal agencies, the RP, and state did not have enough people 

with requisite ICS training to be able to staff nine 

ICPs, particularly in logistics and fi nance. Retaining the Incident Commander position in Houma 

also insulated the Branch Directors from some of 

the political pressures involved with dealing with 

local government offi cials.

When establishing the Branch structure, the Coast 

Guard and the RP invited county and parish offi -

cials to participate in the process. The level of 

county or parish involvement was unique to each 

Branch and this early involvement was essential 

to the overall operational success. For example, 

before the Branch in Grand Isle, La. (Jefferson 

Parish) was established, the local and regional governmental offi cials operated from a command post 

vehicle separate from the command post established by the Coast Guard and RP. This made 

the integration of activities diffi cult. To improve 

coordination, a larger command post space was 

established and all groups were integrated to create 

one response organization. Similarly, the Branch in 

Port Fourchon (Lafourche Parish) was well integrated with the Unifi ed Command Branch organization. These integrated Branches proved highly 

effective, and local offi cials’ satisfaction with their 

input and knowledge of response operations was 

highest in those locations.

Oil began to affect the Louisiana shoreline fi rst; 

resources soon fl owed into staging areas along 

the Louisiana coast. It became apparent that ICP 

Houma would not be able to maintain effective 

command and operational control of all deployed 

personnel and resources from its location. The 

Coast Guard soon established Branches within 

each of the state parishes to maintain effective 

command and control and ensure the adequacy of 

response and information fl ow into ICP Houma. 

Very early the FOSCR authorized these Branches 

to engage in tactical planning, which greatly 

GRAND ISLE, La. – The Coast Guard Branch Director in Grand Isle gives 

an operational brief to a group of international observers. Photo 

courtesy of the U.S. Coast Guard

SOUTHPORT, Fla. – The 

Supervisor of Coast Guard 

Marine Safety Detachment 

Panama City and the Chief 

of Emergency Services 

in Bay County, Fla., 

answer questions during 

a press conference at the 

Bay County Emergency 

Operations Center. Photo 

courtesy of the U.S. 

Coast Guard
2. Command and Control

19

increased the effectiveness of the individual 

Branches and alleviated span of control problems 

for the FOSCR charged with leading such large 

organizations remotely.

The Branches in Louisiana reported to the Deputy 

Operations Section Chief for ICP Houma. Each 

Branch under ICP Houma was assigned a Branch 

Director. Branch Directors had their own deputy 

and support staff required to meet the objectives 

established by the ICP and UAC. The Branch 

Director’s primary focus included managing the 

onshore, inland, and VOO operations.

ICP Mobile Branch Structure

As it became clear that oil would impact ICP 

Mobile’s response area, planning and establishment of similar county-based Branches began. 

Mobile Branches worked through the planning, 

operational direction, and resource processes 

of ICP Mobile. The designation and location of 

Branches was driven by geography and potential 

for oil impacts. Branches were centrally coordinated through ICP Mobile—although as the size 

of the response organization grew, the branches 

gained responsibility for tactical planning and 

direction, consistent with the IAP developed by 

ICP Mobile. Logistics and resourcing at the Mobile 

Branches was largely coordinated through ICP 

Mobile. In some instances, ICP Mobile consolidated several counties under a single Branch that 

reported to a Deputy FOSCR for each respective 

state at the ICP. Larger counties had a Branch to 

themselves. 

Because of the remoteness of the barrier islands 

and the challenges of VOO coordination within 

Mississippi, the Coast Guard established a separate 

Branch for VOO command and control in Mississippi with the Mississippi National Guard. 

At both ICP Houma and Mobile, the coordination 

between the geographically separated Branches, 

staging areas, and ICP was less than optimal. The 

solution was to physically co-locate the federal, 

state, and RP commands assigned to a specifi c 

Branch. The co-location consisted of a single 

Branch command post that could accommodate 

all command personnel and associated functions. 

Co-location allowed relationships to develop 

among key individuals, developing a credible 

team dynamic while building trust through direct 

interaction. Open and transparent communication 

was essential to integration and the success of the 

response.

As an example, the Plaquemines Parish Branch 

followed the unifi ed command structure, with the 

Coast Guard as the Branch Director and the RP as 

the Deputy Branch Director. This proved highly 

effective in the management of a response structure 

that ultimately grew to 2,800 people in July. The 

state was represented at ICP Houma, and periodically provided a Louisiana Department of Environment (LADEP) representative to Plaquemines 

Parish during which time they would attend the 

Branch operational planning meetings. The Branch 

had steady representation from Louisiana Fish and 

Wildlife representatives, who represented the interests of the State Wildlife Refuge. An Emergency 

LAFOURCHE PARISH, La. – Capt. Roger Laferriere (second from 

right), the Incident Command Post Houma Incident Commander, 

discusses an oil trajectory chart with two Coast Guard parish 

president liaison offi cers and a Coast Guard Branch chief. Photo 

courtesy of U.S. Coast Guard

MOBILE, Ala. – Capt 

Steve Poulin, Incident 

Command Post Mobile 

Incident Commander, 

briefs Secretary Napolitano 

on clean up operations 

during an overfl ight. Photo 

courtesy of U.S. Coast Guard
20

2. Command and Control

Operations Center Manager traveled from Belle 

Chase and attended meetings at least once a week, 

participated in the Tactics and Planning Meetings, 

and signed the IAP in person or by facsimile for 

each operational period. The UAC also held a 

weekly briefi ng for the parish president, during 

which they provided detailed updates and offered 

fi eld tours by air and boat of spill cleanup activities, progress, and long-term strategy. These efforts 

enabled closer coordination with the parish. The 

Branch also had several members of the Louisiana 

VENICE, La. – U.S. Coast 

Guard Commandant 

Admiral Thad Allen (left) 

listens in on a conference 

along with Plaquemines 

Parish, La., offi cials. Photo 

courtesy of U.S. Coast 

Guard

THEODORE, Ala. – A Coast 

Guard Gulf Strike Team 

member explains skimming 

and booming operations 

to a reporter during a press 

briefi ng at the Theodore 

Staging Area. Photo 

courtesy of U.S. Coast Guard

Army National Guard serving in the Branch. These 

members successfully kept lines open between 

the Branch and the governor’s offi ce and greatly 

enhanced information sharing.

Two Area Command Staging Areas in Gonzalez, 

La., and Theodore, Ala., were established to coordinate the effi cient and effective distribution of 

critical resources across regional boundaries. Protective boom and skimmers were delivered to these 

areas and then redistributed to those areas most 

affected by the oil. This arrangement allowed onscene responders to focus on removing oil. Establishment of additional local staging areas allowed 

for timely reallocation of regional resources based 

on the oil spill’s trajectory. Additional details are 

provided in Chapter 6 of this report.

ICP Houma and Mobile also established temporary staging areas where personnel and equipment waited for tactical assignment. This proved 

effective in ensuring balanced resource distribution across the parishes and counties, as well as 

between states. These temporary, initial staging 

areas were established within each impacted parish 

and at suitable locations at the county level, close 

to impacted shoreline throughout the coastline.
3. Operations

21

Thirteen individual sections under the operations heading focused on the most distinct, and challenging operational issues for this 

response. Unlike most oil spills, which are usually 

nearly instantaneous events at or near the water’s 

surface, the source of the oil for the Deepwater 

Horizon spill was the Mississippi Canyon 252

Macondo well, at a depth of 5,000 feet, that spilled 

continuously for 87 days.

Because of the depth and duration of the spill and 

size of the area impacted, operations were constrained by certain critical resources: deep water 

operating equipment, skimmers, boom, trained 

personnel, and beach cleaning equipment. These 

resources were essential in responding to the 

spill, but the duration and size of the event magnifi ed concerns and competing demands for these 

resources across multiple states. The scope of the 

impacted area also created the need for an expansive response organization that included branches, 

forward operating bases, and staging areas, with 

some branches becoming response organizations 

larger than the entire organization used for other 

sizable spills.

Response operations took place in four zones: at 

the source of the spill, offshore, near shore, and in 

shore. At the source the drilling rigs and remotely 

operated vehicles necessary for deep water drilling were the only means of accessing the well. 

Offshore, the response focused on removal of the 

oil. Key to these operations were large skimmers 

and in situ burn task forces. The skimmers, storage for the oil recovered by the skimmers, and fi re 

boom were critical resources. When oil could not 

be removed through these means, aerial application 

of dispersants was used. Near shore operations 

focused on skimming and the use of boom to protect sensitive areas; later, they focused on cleaning 

as much of the shoreline as possible. Obtaining 

enough boom was a central concern of near shore 

operations. In shore operations used barriers such 

as Hesco Baskets to minimize shoreline impact. 

Once oil reached the shore, the long, arduous, labor 

intensive process of shoreline cleanup began. After 

the well was capped shoreline cleanup became the 

focus of continued response operations.

3.1 Source Control

Securing the source of the oil for the Deepwater 

Horizon spill was challenging and complex. As 

sub-sea drilling systems are not an area of Coast 

Guard cognizance and expertise, the Federal OnScene Coordinator (FOSC) was unfamiliar with 

the technology and capabilities of the deepwater 

PORT FOURCHON, La. – 

A team of welders 

fabricates a portion of the 

subsea oil recovery system 

chamber. The chamber will 

be one of the largest ever 

built and will be used in 

an attempt to contain the 

subsea fl ow of oil. Photo 

courtesy of U.S. Coast 

Guard 
22

3. Operations

drilling industry. Neither the Coast Guard 

nor any other federal agency had experience with a massive deep water spill. 

Ultimately, source control had to be 

achieved through the Responsible Party 

(RP), whose employees were not accustomed to extensive government input to 

their deepwater operations, nor the federal oversight of multiple agencies unfamiliar with working together in a large 

response organization. The source control 

effort was a whole of government and 

whole of industry response. The Department of Energy, Department of Interior, 

U.S. Geological Survey, and Coast Guard 

participated extensively in these efforts. 

Other oil companies, including Shell and 

Exxon-Mobil, assisted with source control strategy.

Overview of Source Control Activities 

(Situation)

Source control was a multifaceted effort that started 

immediately after the spill and continued until the 

relief well from the Development Driller III intersected the Macondo well on September 19, 2010. 

Initial activities focused on activation of the seven 

separate closing devices on the blowout preventer 

stack, or BOP stack, which includes the Lower 

Marine Riser Package (LMRP). As it became clear 

that the initial efforts to activate the BOP stack had 

been unsuccessful and that there were two separate 

leaks from the riser, the FOSC and RP began to 

consider other source control options.

Multiple courses of action were simultaneously considered and acted upon. Relief 

wells are a commonly used method for 

stopping a blowout and the after consultation with the FOSC the RP mobilized 

two rigs to drill separate relief wells within 

days of the explosion. The RP recognized 

that it would take at least 100 days to drill 

a relief well, so began working with Coast 

Guard and BOEMRE personnel on containment options. These options included 

adapting shallow-water technology to 

the deep-water environment or designing 

entirely new devices. Multiple teams with 

government and industry personnel were 

established at the RP’s Houston headquarters to develop concurrently different ways 

to either stop the fl ow of oil or collect it at its source. 

Each team focused on a discrete effort, such as collecting oil from the riser or stopping fl ow through a 

top-kill procedure.

Although early attempts failed—in part because of 

lack of knowledge of the accurate pressure levels at 

the wellhead—it was recognized that actuating the 

BOP stack remained the best chance to shut the well 

quickly or at least slow the fl ow of oil. A number 

of organizational and engineering challenges complicated efforts to actuate the BOP stack. Problems 

arose from the differences between the piping and 

wiring diagrams for the BOP and the actual installation, as well as from the need to make special tools 

so the Remotely Operated Vehicles (ROVs) could 

deliver hydraulic pressure. The RP ceased trying to 

use the BOP stack rams and shears to stop the fl ow 

of oil on May 5.

Three early containment options were developed 

and deployed during the month of May with limited 

success. The RP unsuccessfully tried to install a large 

containment dome, or cofferdam, over the larger of 

the two leaks in the broken riser on May 7, 2010. 

This effort was unsuccessful primarily due to the 

formation of hydrates while moving the device into 

position. A smaller device, called the Riser Insertion 

Tube Tool (RITT), was successfully inserted into 

the end of the broken riser on May 16, 2010, and 

carried oil and gas up to the Discoverer Enterprise

on the surface. The RITT remained in place until 

May 25, 2010, and collected approximately 22,000 

barrels of oil.

GULF OF MEXICO –The 

damaged blowout 

preventer and the lower 

marine riser package 

were removed and placed 

aboard the Q4000. Photo 

courtesy of U.S. Coast 

Guard

GULF OF MEXICO – A small 

pollution containment 

chamber, known as a 

“top hat” was used in 

an attempt to contain 

an oil spill caused by 

the Deepwater Horizon 

explosion. Photo courtesy 

of U.S. Coast Guard

GULF OF MEXICO – The mobile off shore drilling unit Development 

Driller III (near) prepared to drill a relief well at the Deepwater 

Horizon site, as the MODU Q4000 held position directly over the 

damaged blowout preventer while making preparations for a 

“junk shot” or a “top kill. “ The drillship Discover Enterprise (far) 

continued to capture oil from the ruptured riser. Photo courtesy of 

U.S. Coast Guard
3. Operations

23

On May 26, 2010, after the National Incident Commander and FOSC had reviewed plans, the RP 

removed the RITT and attempted a top kill operation. 

A top kill, also known as momentum or dynamic 

kill, involves pumping heavy drilling mud at high 

pressure and volumetric fl ow rates into the top of the 

well through the kill and choke lines in an attempt 

to push the hydrocarbons back into the reservoir. In 

conjunction with top kill, after realizing its limited 

potential for success, the RP attempted to reduce 

outfl ow and build back pressure through a junk shot. 

The term junk shot refers to bridging material, such 

as pieces of tire rubber and golf balls, which ideally 

block the fl ow path for the hydrocarbons and further 

impede the fl ow. After three unsuccessful attempts 

on consecutive days, the RP ended top kill attempts 

on May 29, 2010.

The next phase of source control involved collection of oil from the well near the seafl oor. On June 

1, 2010, the RP began cutting the riser from the top 

of the BOP stack, and by June 3, the top hat was in 

place and siphoning hydrocarbons to the surface. 

By June 8, the Discoverer Enterprise was collecting 

nearly 15,000 barrels per day (BPD) of oil through 

this device. A second connection was made between 

the Helix Q4000 and the choke line on June 16. 

Rather than collecting oil, the Q4000 used special 

equipment to process and burn up to 10,000 BPD of 

oil. The fi nal collection device connected the kill line 

on the BOP stack to the Helix Producer through a 

freestanding riser. The system became operational on 

July 12, 2010, and collected oil for two days before 

the well was capped. These efforts, and several others that were planned but not executed, were continuously being refi ned to increase redundancy and 

reduce disconnection time in the event of a hurricane.

On July 10, 2010, the RP started work to install 

a capping stack, which was essentially a smaller 

version of a BOP designed to connect to the top of 

the BOP stack with a tight fi tting seal. After two 

days of complicated activity, the capping stack was 

installed without incident. With the approval of the 

National Incident Commander, the RP shut the stack 

on July 15, 2010, and began a well integrity test 

(designed for a maximum of 48 hours), marking 

the fi rst time in 87 days that no oil fl owed into the 

Gulf of Mexico. Government scientists expressed 

some initial concern that keeping the stack shut 

could cause subterranean leakage resulting in the 

broach of the seabed. Despite these concerns, the 

test continued for 24 hours, and extended in 24-hour 

increments with constant monitoring, using a variety of sensors 

and other means. By July 24, 

2010, though the response had 

confi dence in the integrity of the 

well, it continued monitoring. 

With the capping stack in place, 

the RP raised the possibility of 

killing the well before completing the additional relief wells 

through a procedure called a 

static kill or bullhead kill. Like 

the top kill, the static kill involved 

pumping heavy drilling mud into 

the well in an effort to push the 

hydrocarbons back into the reservoir and establish a column of 

drilling mud. After successfully 

completing the preliminary tests 

on August 3, 2010, and with the approval of the 

National Incident Commander and the FOSC who 

approved operational procedures, the RP began the 

operation and achieved hydrostatic control of the 

well. The following day, the RP cemented the well 

and successfully pressure-tested the cement.

While the relief well neared completion, the RP 

opted to remove the damaged Deepwater Horizon

BOP stack and replace it with a fully functioning 

and recently tested BOP stack from the Development Driller II to facilitate well abandonment procedures after relief well intersection. Finally, on 

September 19, the relief well drilled by the Development Driller III intersected the Macondo well 

at 18,000 feet below the surface, plugging the hole 

with cement, and marking the offi cial sealing, closing, well kill, plug and abandonment of the well. 

Response Organization 

in Houston

After notifi cation of the Deepwater Horizon incident, the Coast 

Guard activated an Incident 

Command Post (ICP) in Houston, Texas, to deal with source 

control. This ICP was separate 

but integral to the ICPs in Houma 

and Mobile set up to deal with 

the response. An Incident Management Team (IMT), following 

the Incident Command System 

(ICS) set up the ICP in Houston. 

GULF OF MEXICO – The crew 

of Blue Dolphin and the 

HOS Centerline pump mud 

through lines to the Q4000 

and down to the temporary 

cap and into the well for a 

static kill, as the DD II crew 

continues to drill a relief well 

in the background. Photo 

courtesy of the U.S. Coast 

Guard

GULF OF MEXICO – 

Roughnecks maneuver a 

section of drill collar into 

position on the drilling fl oor 

of Development Driller III, 

which drilled the relief well 

and pumped the cement to 

seal the Macondo well. Photo 

courtesy of the U.S. Coast 

Guard
24

3. Operations

CDP 

Task Force

Relief Wells 

Task Force 

Engineering 

Task Force

SIMOPS 

Task Force

Top Kill 

Task Force

BOP 

Interventions 

Task Force

Source Control 

Branch

Containment

BOP Capping 

Task Force 

Q4000 

Task Force

Enterprise 

Task Force

Clear 

Leader 

Task Force

BOP 

Connections 

Task Force 

Procedures 

Branch

Dispersant 

Branch

Safety, Human 

Resources, 

Information, 

Legal, Security 

Branch

Logistics Operations Planning Finance

Incident Command Post Houston

Figure 3.1: Organizational Chart Task Forces
3. Operations

25

At fi rst, the Operations Section included containment activities such as relief wells, BOP intervention, capping, etc. Later, an Operations Section was 

created specifi cally for Source Control and assumed 

operation of containment activities. Containment 

activities were then further subdivided into logical 

work-specifi c activities in the form of Task Forces, 

as described in the NIMS ICS. Initially, individual 

Task Forces were set up for relief wells, BOP intervention and sub-sea containment, ROV operations, 

and survey operations. Marine operations were originally within the Logistics Section, but later moved 

to the Source Control Branch, which coordinated 

overall simultaneous source control operations.

Task Forces formed, delivered, and deactivated as 

needed. For example, the BOP Intervention team 

formed with the goal of actuating the BOP to shut 

in the well. This team later changed its focus to 

providing access to the BOP and repairing the control pods. Upon achieving those goals, the team 

assumed a monitoring role. Similarly, teams formed 

to address the several containment options, including top hats, hot taps, capping stacks, and collection 

or processing. By early June, the organization chart 

was as as shown in Figure 3.1.

The work process generally followed the planning 

as described in the NIMS ICS. Task Forces would 

provide regular and frequent status reports and plans 

to the Incident Management Team for Source Control and Operations. These plans were also included 

in the Incident Action Plan (IAP) process. Task 

Forces were operational 24 hours a day, with most 

of the operational procedures development occurring during the evening.

Containment Task Forces conducted their work 

applying the following principles:

1. To avoid solutions that might result in a 

worse situation,

2. That time was of essence,

3. That reaching a solution would require 

redundancy and contingency, and

4. That resources would be provided as 

needed to staff the teams and to develop 

solutions.

As a result, teams worked simultaneously on shortterm (e.g., top hats) and longer-term (e.g., Containment and Disposal Projects) solutions. As the Task 

Forces developed options, both the Incident Command and the RP Senior Management reviewed 

and selected options, and made priority determinations for review and approval by the National 

Incident Commander and FOSC. Task Forces 

then engineered and fabricated selected options as 

required, while concurrently developing operational 

procedures and identifying and managing hazards. 

Once completed, ICP Houston and the Unifi ed Area 

Command (UAC) approved the operational procedures. Task Forces interfaced with Coast Guard, the 

Bureau of Ocean Energy Management, Regulation 

and Enforcement (BOEMRE, formerly Minerals 

Management Service), and Science Team personnel 

during solution development, hazard identifi cation, 

and management sessions. Incident Command also 

interfaced frequently with Coast Guard, BOEMRE, 

and Science Team to focus on activity prioritization 

and procedure approvals.

Of note, engineering review incorporated lessons 

learned during this process. For example, the cofferdam execution provided the lessons used to develop 

the top hat and Riser Insertion Tube Tool. Before 

deploying the fi rst top hat, the engineering phase 

of subsequent top hats incorporated lessons from 

the initial fabrication. Examples of contingency 

and redundancy included top hats constructed as a 

contingency to RITTs, as several were designed and 

built specifi cally for contingency and redundancy. 

Similarly, the latch cap and valve manifold for the 

capping stack were developed as a contingency for 

the transition spool and 3-ram stack, and two latch 

caps were developed for redundancy purposes.

Source Control Oversight 

(Action and Resources)

Multiple federal entities conducted oversight of 

decisions and operational procedures to stop the 

fl ow of oil from the stricken Macondo well. Entities 

accomplished this through informal coordination 

both within and outside of the Incident Command 

System. The primary participants at ICP Houston 

included the Coast Guard, BOEMRE, the Science 

Team, and the National Incident Commander’s 

representative. Other agencies had a more limited 

presence at the ICP, including U.S. Navy Supervisor 

of Salvage and Diving (SUPSALV), and National 

Oceanic and Atmospheric Administration (NOAA).

Coast Guard oversight in Houston began immediately, with Outer Continental Shelf (OCS) inspectors from MSU Morgan City arriving on April 21, 

2010, to act as liaisons while the Deepwater Horizon was on fi re. As the situation evolved, staffi ng 

expanded slightly to include incident management 

expertise from the Gulf Strike Team, engineering 
26

3. Operations

expertise from the Marine Safety Center, and OCS 

inspectors. This enabled Coast Guard personnel to 

provide oversight of both incident management and 

source control development (i.e., design and vessel issues). The Coast Guard solidifi ed the staffi ng 

model in mid-May 2010, and it generally remained 

consistent throughout the response, with the numbers decreasing toward the end.

This Coast Guard contingent served several primary functions. It was responsible for providing 

situational awareness and updates to the NIC and 

UAC, and participated in daily teleconference Cabinet Secretary Briefi ngs with the Department of the 

Interior (DOI) and the Department of Energy. It also 

served as the senior federal representative at ICP 

Houston, while providing expertise and oversight 

to the RP’s engineering work groups during their 

development of concepts, procedures, and equipment to contain the source. The contingent also 

conducted initial review of source control procedures and plans, coordinated inspection schedules, 

and lent expertise at meetings to identify hazards, 

regulatory issues, and scheduling confl icts with 

planned procedures.

Initially, the Coast Guard personnel at ICP Houston 

were under the supervision of ICP Houma, but still 

participated in twice daily UAC briefi ngs with their 

RP counterparts. In early May 2010, ICP Houston’s 

reporting chain changed to the UAC. By mid-June, 

the Houston ICP reported to both the NIC and the 

UAC for source control issues but continued to participate in the twice-daily UAC briefi ngs. Additionally, a daily report describing source control 

developments and technical oversight activities was 

provided to the UAC, the Marine Safety Center, and 

a number of other entities in Coast Guard Headquarters and LANTAREA.

On May 22, 2010, the National Incident Commander dispatched a senior offi cer to serve as 

his direct representative in Houston and provide 

high-level liaison with senior RP management, the 

Science Team, and high-level offi cials from the 

DOI and the Department of Energy. This position 

was instrumental throughout (i.e., until relief well 

intersection). Although overseen by a Coast Guard 

captain at all times, both the fl ag offi cer and captain had signifi cant technical engineering expertise 

and they worked together to provide a continuous 

presence in Houston, Texas. On July 25, 2010, 

another Coast Guard senior offi cer served as the 

National Incident Commander’s representative 

and provided relief to the originally assigned fl ag 

offi cer. For the remainder of the incident, they 

worked together to provide a continuous presence 

in Houston. However, both remained engaged with 

source control oversight even when not in Houston, in order to ensure continuity.

BOEMRE served as the primary source of government oversight and expertise on sub-sea source 

control operations. As with Coast Guard personnel, 

BOEMRE participated on a number of the RP’s 

work groups to develop source control options and 

mitigate risks. BOEMRE also conducted a detailed 

review of source control plans before sending them 

to UAC for review and approval. BOEMRE had 

four to fi ve employees in Houston overseeing the 

RP. BOEMRE did not participate in the ICS structure at ICP Houston, but was fully integrated with 

the UAC in New Orleans.

Under the direction of the Energy Secretary, the 

Department of Energy assembled a scientifi c oversight team to monitor the progress and critically 

review the RP’s efforts to contain and secure the 

source of the leak from the Macondo well. The 

team consisted of more than 200 scientists, engineers, and other experts from the National Laboratories, U.S. Geological Service (USGS), other 

government agencies, and major oil companies. 

Additionally, the team included a small group of 

the nation’s top scientists who served as advisors 

to the National Incident Commander.

The team, established during the week of April 26, 

2010, remained engaged throughout the response. 

A core group of up to 20 personnel stationed on the 

ground in Houston provided the needed interaction and coordination with the RP. This core group 

actively maintained connectivity to the remainder 

of the team, as well as select industry experts, to 

bring the appropriate disciplines to bear on individual issues.

On July 14, 2010, the NIC asked NOAA to assist 

with monitoring the wellhead. The NOAA ship 

Pisces sailed from Pascagoula, Miss., to be on scene 

with some of NOAA’s top acousticians. The vessel 

was equipped for acoustic monitoring at several 

kilohertz (18, 36, 48, 96, and 128). These vessels 

were imaging for sound associated with gas or oil 

leaks in the ocean fl oor, which would indicate a 

potential formation leak. A request came a few days 

later for an additional support vessel, and NOAA 

provided the ship Gordon Gunter. Gordon Gunter

had a similar range of acoustics, but did not have 
3. Operations

27

a dynamic positioning 

system. Therefore, the 

Pisces worked near the 

wellhead, and the Gordon Gunter farther out, 

near faults that USGS 

identifi ed as possible vent 

locations. After about a 

week, the Secretary of 

Energy’s team decided 

one acoustic vessel was 

suffi cient for acoustics 

monitoring, and the 

Gordon Gunter went off 

scene. The Henry Bigelow relieved the Pisces 

in early August. When not specifi cally conducting 

acoustic sampling, both the Pisces and Henry Bigelow conducted water sampling near the wellhead. 

These ships spent 81 sea days on scene. NOAA 

streamed data collected in real time to University 

of New Hampshire (UNH), where the UNH team 

processed the data 24 hours a day, 7 days a week. 

The Secretary of Energy and senior agency representatives on the team personally participated in 

daily briefi ngs with the RP’s executives and provided real time recommendations on the effi cacy of 

the proposed mitigation measures to the National 

Incident Commander.

Operational Procedure Processing

All sub-sea activities conducted by the RP were 

agreed to in writing through detailed procedures 

describing the operation to be performed around the 

wellhead. BOEMRE and Coast Guard personnel in 

Houston participated in the development and drafting process to help identify and mitigate hazards. 

Once they fi nalized the procedures, senior engineers in Houston signed off and forwarded them 

to the UAC in Louisiana. The senior BOEMRE 

representative in the UAC would again review and 

approve the procedures before the Unifi ed Area 

Commander gave the fi nal permission to proceed. 

This sign-off process remained in place throughout the containment effort until permanent well 

kill. After that point, the RP still had to work with 

BOEMRE to approve procedures related to plug 

and abandon the well, a typical oil fi eld activity 

covered by BOEMRE regulations. As the well was 

no longer a threat for further release of oil, FOSC 

participation in those operational procedures was 

not required.

Source Control Challenges

The Incident Management Team in Houston followed ICS processes, but the overall coordination 

with the NIC representative, BOEMRE, the Science Team, and other federal agencies present in 

Houston was informal and outside the ICS planning cycle. The skill sets and perspectives of all 

the federal entities were essential to successful 

oversight.

Particularly early in the response, there was a lack 

of transparency by the RP on source control. Initially, senior RP management in Houston made 

major decisions outside the ICS. Early on, the 

Coast Guard Incident Commanders raised this concern with the RP and were subsequently included 

in the daily meetings with the senior managers. 

However, it remained apparent that key strategic 

and tactical planning occurred behind closed doors 

by RP personnel without government participation 

in the formulation of those plans. This changed 

in late May 2010 when the NIC representative 

vigorously insisted on participating in an internal 

RP meeting to assess the failed top kill, establishing a new paradigm. From that point forward, 

the government played a signifi cant role in overarching source control planning and assessment. 

Ultimately, the NIC asserted authority and ordered 

specifi c source control actions through issuance 

of NIC directives.

Although Coast Guard inspectors and engineers 

were not well versed in the nuances of sub-sea 

engineering, they did offer critical thinking, operations and 

engineering skills to the review 

process. The RP and industry 

personnel valued their participation on design and in the hazard 

operations and hazard identifi -

cation teams. Even with these 

contributions, there was a large 

amount of work. As the operation 

progressed, it was clear that the 

pool of Coast Guard personnel 

with the requisite skill sets was small. Equally 

clear was the necessity to establish a rotation 

scheme to sustain the participation of those with 

the technical background to assess RP proposals 

at ICP Houston. 

This was the fi rst major spill in the United States 

in deep water that required securing a well blowout 

in order to stop the fl ow of oil. Securing the well 

GRAND ISLE, La. – NOAA personnel on a 

commercial vessel receive a briefi ng on 

the Conductivity-Temperature-Depth 

(CTD) equipment via radio from scientists 

onboard the NOAA vessel PISCES. Photo 

courtesy of the U.S. Coast Guard

GULF OF MEXICO – 

Transocean’s 

Development Driller II

continues to dig a relief 

well in an eff ort to stop 

the fl ow of oil into the 

water from the Deepwater 

Horizon incident. Photo 

courtesy of U.S. Coast 

Guard
28

3. Operations
3. Operations

29

was a major technical challenge. The RP initially 

had the technical expertise to identify the means of 

controlling the source and developed plans, with 

the oversight of BOEMRE and the Coast Guard. 

This resulted in an evolving series of attempts to 

stop the oil fl ow, culminating with the successful fi nal capping stack, static kill, and bottom kill 

through a relief well. From beyond Houston, the 

perception of the attempts may have appeared as 

if each was thought of after the previous effort 

failed. In reality, multiple options were constantly 

under development and revision.

Oil Trajectory and Amount

Beginning April 21, 2010, the modeling team at 

NOAA’s Offi ce of Response and Restoration began 

generating daily trajectories for the Deepwater Horizon oil spill and continued for 107 days.

Background

Cumulative trajectory maps were produced early 

in the Deepwater Horizon spill response. One map 

displayed the surface location of spilled oil for 

several consecutive days, as well as a forecast for 

the following day. As the area of water affected by 

the spill grew larger, the forecast aspect of these 

maps became more important than the day-to-day 

changes in surface oil. Consequently subsequent 

trajectory products only included forecasts.

Forecasts for 24, 48, and 72 hours were produced 

for surface oil in the near-shore area to support daily 

response planning. The production of the forecasts 

continued until no recoverable oil was seen in overfl ights of the area for three weeks.

In mid-May, when a tail of oil entered the northern 

part of the Loop Current, it created a potential pathway for oil to be transported to the Florida Keys, 

Cuba, or the Bahamas. With this change in the scale 

of the trajectory forecasts, the Offi ce of Response 

and Restoration began to produce forecasts for two 

regions, near-shore and offshore. The offshore forecasts also supported daily response planning, and 

predicted surface oil impact by the Loop Current 

system for the next 24, 48, and 72 hours. 

In mid-July, Offi ce of Response and Restoration 

began to produce maps to provide daily updates 

of the location of the Loop Current and its major 

eddies, and the location of fl oating oil relative 

to the Loop Current system. After more than a 

month of daily mapping, over-fl ights and satellite 

analyses eventually showed no recoverable oil in 

this area; these fi ndings indicated a diminished 

Loop Current threat. Weeks later, when recoverable oil was no longer observed in over-fl ights 

or satellite analyses, the offshore forecasts were 

phased out.

In addition to surface oil trajectory forecasts, 

NOAA provided guidance on expected movement 

of subsurface oil from mid-May through mid-September. The UAC Subsurface Monitoring Unit 

(SMU) used subsurface forecasts as a tool to direct 

vessels in sampling. The daily sampling information, including fl uorometry, dissolved oxygen, and 

analytical chemistry, provided usable data on the 

subsurface oil during the incident.

Oil Spill Trajectory in Detail

The Deepwater Horizon oil spill posed multiple 

challenges for trajectory modeling and stretched 

NOAA’s capacity to generate timely, accurate, and 

useful products to the response. Over the course 

of the spill, NOAA prepared more than 400 trajectory products. They developed multiple new 

products to address the need for subsurface and 

long-term forecasts, and to help improve user and 

public understanding.

NOAA provided the fi rst trajectory forecast to the 

FOSC on the morning of April 21, 2010. This trajectory focused solely on the 700,000 gallons of 

diesel aboard the burning Deepwater Horizon rig. 

The fi rst trajectory assumed a continuous release 

starting at 10:00 a.m. Central daylight time on April 

20. NOAA later prepared additional trajectory products with different oil release scenarios. Scenarios 

included diesel oil spilling from the rig at different times over several days, and a trajectory for a 

potential continuous release of crude oil from the 

well. Based on observations from over-fl ights, the 

trajectories produced on April 22 and the morning of 

April 23 assumed no further release from the well or 

rig. However, on the afternoon of April 23, a Coast 

Guard and NOAA over-fl ight confi rmed signifi cant 

amounts of oil near the well and observed surfacing 

oil. All subsequent trajectory forecasts assumed a 

continuous release from the well.

NOAA developed four different types of trajectory forecasts used in operations throughout the 

response effort. They produced a daily Loop Current analysis to address the potential threat of oil 

transport toward the Florida Straits. A fi fth type 
30

3. Operations

of trajectory forecast was also investigated. The 

fi fth trajectory was a 45-day outlook based on 

NOAA Climate Center wind forecasts and NOAA 

generated ocean forecasts. This trajectory yielded 

results inconsistent with observed oil movement 

and thus was not introduced to the response. Table 

3.1 summarizes the types of trajectory analyses 

used, the periods required to generate products, 

and the distribution of the results.

The surface oil forecasts occurred twice a day 

from April 23 to May 19, 2010, once daily after 

then until August 13, then every few days until 

the fi nal forecast on August 23. From May 18 to 

June 17, the surface forecast split into a near-shore 

and offshore forecast. Lack of observable sheens 

in the offshore area and the clear separation of the 

Loop Current resulted in discontinuation of the 

offshore forecasts on June 18. This indicated a 

reduced likelihood of oil transported to the Florida 

Straits. Trajectory forecasts from August 3 through 

the fi nal forecast produced August 23 indicated no 

recoverable surface oil.

The Comprehensive Deepwater Oil and Gas 

model (CDOG) and the SINTEF (a Norwegian 

research organization) Deepblow model produced 

the initial subsurface plume forecasts. The subsequent daily subsurface plume forecast identifi ed 

potential locations of oxygen depression at depth. 

NOAA contacted a third party for additional subsurface plume modeling, but that modeling was 

unsuccessful.

Producing reliable surface trajectory forecasts 

required a signifi cant number of supporting data 

sources. In particular, observations of oil distribution and forecasts of winds and currents were 

critical. Oceanographers in NOAA’s Offi ce of 

Response and Restoration compiled all available 

observational data, evaluated six hydrodynamic 

forecast models, and loaded relevant information 

into the General NOAA Operational Model Environment to carry out the daily trajectory forecasting. Not all data were of the same quality, nor were 

all data sources prepared to provide operational 

support at the beginning of the spill. However, 

over time the quality and availability of data and 

information became more robust and reliable.

In addition, Bureau of Ocean Energy Management, Regulation, and Enforcement (BOEMRE) 

oceanographers provided NOAA with data used 

for oil trajectory and shoreline threat probability 

modeling. They collected urgently needed information and modifi ed and extended research studies already underway at the time of the spill. The 

Lophelia II expedition, Loop Current monitoring, 

socioeconomic studies, and other studies provided 

data to help evaluate the impacts of the spill.

Type Frequency Dates Distribution

Surface Oil Forecast Daily April 21 – August 23 Within commands, then 

public after 26 April, 2010

Shoreline Oiling 

Outlook Daily April 27 – August 23 Within commands only

Statistical Long Term 

Outlook Irregular

First results: May 2

First IC presentation: May 10

Press Release: July 2

Initially within commands, 

public on July 2

Subsurface Plume 

Forecast Irregular, then daily

First forecast: May 15 Forecast based 

on climatology: May 30

Daily: September 7 – September 24

Used for guidance of vessels 

as part of SMU

Loop Current Analysis Irregular, then daily First analysis: May 5

Daily: May 17– July 22

Generally within commands 

only

Table 3.1: Trajectory Analyses
3. Operations

31

The Loop Current

Early in the response, NOAA recognized the threat 

of oil entering the Loop Current and potentially 

affecting shorelines beyond the northern Gulf of 

Mexico. There was particularly strong concern this 

transport pathway could rapidly bring oil to southern Florida. Therefore, when scientists observed 

oil entering the northern edge of the Loop Current, 

a separate offshore trajectory tracked this oil. The 

oil in the offshore area consisted of very widely 

scattered light sheens with vessel-observed tar 

balls in the northern section on June 8 and again on 

June 15. The modeling team attempted to convey 

this was signifi cantly less oil than was present in 

the northern Gulf by changing the pattern of the 

oil distribution, and by using labeling to associate 

this with widely scattered sheens. However, when 

users separated the assumptions and labeling from 

the trajectory shape fi les, this information was lost.

By late May, it became clear the northern extent of 

the Loop Current was unstable. After several conversations with scientists who had spent decades 

observing the Loop Current, there was no consensus on whether the northern intrusion would 

permanently detach. However, by mid-June it 

appeared to have formed a permanent separation. 

The statistical analyses conducted in early May 

considered all scenarios, most of which estimated 

the Loop Current would extend into the central or 

northern Gulf. NOAA SSCs briefed the results of 

these statistical analyses to the NIC, FOSC and 

FOSCRs. However due to a protracted OMB clearance process, the public release of the document 

did not occur until early July; after the Loop Current no longer provided an oil transport pathway 

to the Florida Straits. This delayed public release 

caused confusion for the public.

Oil Trajectory Challenges Encountered

Trajectory forecasting development and execution 

encountered several challenges. Communicating 

forecasting results was the fi rst. The broad public 

distribution of trajectory forecast products generated for the Deepwater Horizon oil spill was 

unprecedented. In general, the UAC used trajectory forecast products as one piece of information 

to determine resource allocation. During the Deepwater Horizon response, signifi cant public interest 

resulted in the availability of surface trajectories to 

a very wide and diverse audience. Until oil began 

stranding on the shorelines, 

the trajectory product was 

one of the few visuals 

available to media. The 

trajectory modeling team 

was unprepared for this 

widespread use. Details on 

the assumptions and uncertainties were often diffi cult 

to explain to the public and 

media, and occasionally 

resulted in confusion. The 

forecasts showed areas of 

varying probability that oil would be found, not 

an actual depiction of the location of oil, and even 

within the areas shown by the forecast, the maps 

were never intended to imply that the entire surface area of the water would be covered by oil. In 

particular, the FOSC had to explain jumps in the 

heavy, medium, and light contours on the surface 

trajectories, which required describing the complex modeling processes that could lead to such a 

jump. This potentially eroded public confi dence 

in the forecasts. Because of uncertainties in the 

release rate and weathering processes, associating concentrations or volumes with the shoreline 

impacts was generally not possible, but at times the 

lack of volume estimates caused others to question 

the forecasts. The modeling team was not prepared 

to manage the expectations arising from such a 

diverse audience. 

Signifi cant observational efforts determined the 

surface and subsurface extent of the oil. During the 

early stages of the spill, determining who collected 

what data in what formats, and how to access it, 

was challenging. As the spill progressed, the access 

and quality of data improved signifi cantly.

The Size of the Oil Spill

Estimating the size of oil spills has historically been 

a contentious, uncertain, and politically charged 

process. The Deepwater Horizon spill was no 

exception. Determining fl ow rates and overall mass 

balance was especially diffi cult in the Deepwater 

Horizon spill as there were no proven techniques for 

estimating fl ow under conditions found at the wellhead. Over time, the RP developed peer-reviewed 

estimates of the spill release, but the substantial 

discrepancies between the preliminary estimates 

created a great deal of public distrust. Several other 

challenges complicated these efforts.

ST. PETERSBURG, Fla. – 

Captain Tim Close, 

Commander of U.S. Coast 

Guard Sector St. Petersburg, 

discusses a NOAA oil spill 

trajectory with the media. 

Photo courtesy of U.S. Coast 

Guard
32

3. Operations

The response was regarded 

as a worst-case spill, despite 

quantifi cation diffi culties. The 

protracted campaign necessary to deal with the 87-day 

spill required significant and 

sustained levels of resources, 

including skimmers, fi re boom, 

dispersants, boats, and personnel. The estimates as to spill 

size did not drive the amount of 

resources brought to the spill. The oil spill response 

plan for the well included a worst-case discharge of 

approximately 250,000 barrels per day. The RP’s 

initial estimates were far below that, but the spill 

was always handled by the FOSC as a worst-case 

discharge.

Researchers had not experienced an unbounded 

source and timeline of this extent before. Typically, ship or tank-based spills have a clear upper 

bound in the form of the total capacity of the ship 

or tank, and releases are generally over in a matter of hours. The depth of the Deepwater Horizon

leak source and its multiple leak points, without 

geometrically simple openings, also contributed 

to diffi culty in understanding the extent of damage 

to the well and riser pipe. Additionally, the poorly 

known gas-liquid mixture coming from what was 

an exploratory well fl uctuated over time. The available information on the leaks was of poor quality 

and not readily available to experts working in spill 

volume estimation. Visual estimation was diffi cult 

because of uncertainties in the fate and behavior of 

the oil and gas mixture as it travelled to the surface. 

As the well was not yet producing, there was also 

uncertainty over reservoir conditions and a lack of 

prior production rates to bound the problem. 

The initial response efforts focused on fi re fi ghting, search and rescue of the crew, and the potential fate of the 700,000 gallons of diesel aboard 

the Deepwater Horizon rig. Early reports did not 

indicate the well was leaking. However, remotely 

operated vehicles (ROVs) diving near the wellhead 

as early as April 22 found hydrocarbons escaping 

from kinks in the toppled riser pipe. At this time, the 

RP was reporting a release rate of 1,000 barrels per 

day (BPD). Over the next several days other leaks 

were discovered as the ROVs continued to explore 

the wreckage and attempt to activate rams on the 

blow out preventer (BOP). At the surface, efforts 

began to shift from search and rescue to pollution 

reconnaissance. Trained aerial observers quickly 

realized the spill was much larger than the 1,000 

BPD estimate. When Coast Guard requested a more 

accurate estimate, NOAA reported on April 28 the 

spill was at least 5,000 BPD based on over-fl ights 

and satellite views. Five thousand BPD became 

the offi cial estimate. After the May 12, 2010 public 

release of videos showing the plume of hydrocarbons escaping from the damaged riser in the deep 

sea, many academic scientists insisted the fl ow rate 

was much higher than 5,000 BPD. On May 14, the 

NIC asked its Interagency Solutions Group (IASG) 

to provide scientifi cally based information on the 

discharge rate of oil from the well. On May 16, the 

RP placed the Riser Insertion Tube Tool (RITT), 

a snorkel-type device, in the broken riser end to 

capture some of the escaping oil. The sustained rate 

of this partial capture yielded 8,000 BPD, and only 

captured a fraction of the oil.

In response, the NIC IASG chartered the Flow 

Rate Technical Group (FRTG) on May 19, 2010. 

Experts from many scientifi c disciplines were 

brought together to perform the FRTG’s two primary functions:

1. As soon as possible, generate a preliminary 

estimate of the fl ow rate, and

2. Within approximately two months, use multiple, peer-reviewed methodologies to generate 

a fi nal estimate of fl ow rate and volume of oil 

released.

Several methods employed contained individual 

strengths and limitations. One technique, called 

mass balance, relied only on observations available on the ocean surface, and yielded a fl ow rate 

of 13,000 to 22,000 BPD early in the incident. Two 

techniques, video and acoustic, used observations 

from ROVs of the oil plume as it exited the well 

a mile deep. These techniques yielded consistent 

fl ow rates of 25,000 to 60,000 barrels per day. An 

in-place hydrocarbon sample not only improved 

those fl ow estimates, but also independently combined with surface collection data to yield a fl ow 

rate of 46,000 to 63,000 barrels per day. The fi nal 

approach, reservoir and well modeling, did not need 

new observations, but instead relied on industry 

proprietary data. This included seismic data on the 

reservoir structure and properties, well logs, and 

others. This approach produced the largest range 

and number of uncertain parameters in estimated 

fl ow rates, from less than 30,000 to more than 

100,000 BPD.

GULF OF MEXICO – Video 

acquired by a remotely 

operated vehicle is 

monitored and recorded. 

The video display 

shows a small pollution 

containment chamber, 

known as the “top hat” 

being lowered into the 

Gulf of Mexico. Photo 

courtesy of U.S. Coast 

Guard
3. Operations

33

The most defi nitive information came from data collected after installation of the capping stack on July 

12. This structure ultimately stopped oil fl owing into 

the Gulf. Pressure measurements were recorded as 

the choke valve closed to yield the most precise and 

accurate estimation of fl ow: 53,000 BPD just prior 

to shut in. The teams assigned an uncertainty on 

that value of ± 10 percent based on their collective 

experience and judgment. They then combined the 

fi nal fl ow rate with a well-calibrated simulation 

for the rate of depletion of the reservoir to produce 

an estimate of the fl ow rate as a function of time 

throughout the incident. The net result was a fl ow 

rate estimate that decreased over the 87 days from 

an initial 62,000 to a fi nal 53,000 BPD. This put the 

total amount released at 4.9 million barrels of oil, 

before accounting for containment. The estimated 

uncertainty on these fl ow estimate values was also 

approximately ± 10 percent.

The Fate of the Oil

Part of the National Incident Command Interagency Solutions Group, the Oil Budget Calculator Science and Engineering Team, developed 

a scientifi cally valid tool that could be used to 

calculate the fate of the oil discharged from the 

Macondo well. That is to say, how much was dispersed, mechanically recovered (through skimming, 

sorbents, etc.), evaporated, dissolved, or burned.

3.2 Dispersant Use and Monitoring

Oil on the surface posed an immediate threat to 

marine life that live and spawn in the open ocean 

or live and breathe at the interface of the ocean 

and atmosphere, such as marine mammals and 

sea turtles. Unrecovered oil on the ocean’s surface was a known threat to marine fi sheries and 

estuarine communities near-shore. The decision 

to use dispersants required a robust assessment of 

net environmental benefi ts and monitoring activities at the wellhead, in the benthos, water column, 

water surface, and along the shoreline. Despite 

political concerns and public misperceptions, those 

assessments and monitoring protocols generally 

supported continued application of dispersants 

aerially, on the surface, and sub-sea at the wellhead 

throughout the incident.

The FOSC and emergency responders clearly 

understood dispersants do not remove the threat 

Figure 3.2: Deepwater Horizon Oil Budget (August 4, 2010)
34

3. Operations

of oil pollution from the 

marine environment. 

Rather, dispersants provide a mechanism to alter 

the nature of the spilled 

oil’s fate, transport, and 

potential effects. Natural 

dispersion was occurring 

at the surface by physical 

wave action. A trade-off 

analysis determined the 

appropriateness of dispersant use. This analysis studied if a particular mitigation strategy would generate a lesser potential 

for long-term environmental impact relative to 

conventional response options. Ideally, the best 

response options would stop the fl ow of oil, or 

contain and remove the oil at the source. 

Prior to the Deepwater Horizon incident, dispersants were used to combat oil spills in the Gulf of 

Mexico (GOM) as a response tool to mitigate the 

effects from offshore oil spills on environmentally 

sensitive coastal habitats. Regional Response Team 

(RRT) VI developed a pre-approval plan for dispersants using the tools listed in 40 CFR 300.910, 

Subpart J, FOSC Dispersant Pre-Approval Guidelines and Checklist (2001), Special Monitoring for 

Applied Response Technologies V. Operationally, 

the FOSC followed this pre-approval plan during 

this incident on a daily basis. The FOSCs assigned 

to the Eighth Coast Guard District were familiar 

with this tool and were well-versed in its use for 

spills in the GOM Coastal Zone. In addition, all 

RRT VI and many National Response Team (NRT) 

members received briefi ngs on the past uses of dispersants and were aware of the trade-offs associated 

with the application of dispersants. NOAA and DOI 

consulted on the use of dispersants in the GOM and 

the Endangered Species Act (ESA) in 1995.

RRT VI FOSC Dispersant Pre-approval Guidelines 

and Checklist provided for meaningful, environmentally benefi cial, and effective dispersant operation. Both historically and during the response, the 

programmed checklist approach allowed the FOSC 

to arrive quickly at a logical go or no-go decision. 

This allowed dispersant operations to begin in a 

timely manner to maximize its effectiveness as a 

countermeasure. The parties requesting approval 

for use of a dispersant system underwent evaluation criteria for approval for use. In addition to the 

checklist, parties had to demonstrate the following 

to the satisfaction of the FOSC:

• That the application system was specifi cally 

designed for its intended purpose, and if not 

specifi cally designed for dispersant use, had 

been used previously and deemed to be effective and appropriate; also that it would be used 

again in a similar manner or by some other 

specifi c means, deemed to be effective and 

appropriate under the circumstances,

• That the design and operation of the application system could reasonably be expected 

to apply the chemical dispersant in a manner 

consistent with the dispersant manufacturer’s 

recommendation, especially with regard to 

dosage rates, and concentrations, and

• That the operation would be supervised or 

coordinated by personnel with experience, 

knowledge, specifi c training, or recognized 

competence with chemical dispersants and 

the type of system used.

The effectiveness of dispersants generally 

decreases as spilled oil weathers. It is therefore best 

to apply dispersants when the oil is freshest. The 

pre-approved dispersant area in the GOM includes 

offshore waters from the ten-meter isobaths and 

three nautical miles (nm)—whichever is farthest 

from the shore—to 200 nm offshore, encompassing the Exclusive Economic Zone boundary. This 

zone extends from the Texas-Mexico border and 

continues through the states of Texas and Louisiana to the boundary between federal Regions IV 

and VI. The requirement for dispersant product 

selection was that the dispersant must be included 

on the NCP (National Contingency Plan) Product Schedule and considered appropriate by the 

FOSC for existing environmental and physical 

conditions. The EPA product schedule listed and 

approved both COREXIT 9527A and 9500A for 

use. The Deepwater Horizon response effort used 

both. After responders exhausted the supply of 

9527A, the operation used 9500A throughout. In 

accordance with RRT VI guidelines, the Deepwater Horizon RP submitted its fi rst request to use 

aerial dispersants to the FOSC at Morgan City, La. 

The FOSC preauthorized its use at approximately 

1 p.m. on April 22, 2010, and the RRT received 

notifi cation a few hours later. Although there was 

an active search for the survivors of the MODU 

Deepwater Horizon, the FOSC, in concert with 

the Search and Rescue effort at the Eighth Coast 

Guard District, approved aerial dispersant use. 

There were no active searches in the target area, 

KEY WEST, Fla. – A 

staff member form the 

Florida Department 

of Environmental 

Protection demonstrates how the Neuston 

net is one of the 

mechanisms being used 

to monitor for oil from 

the Deepwater Horizon

oil spill. Photo courtesy 

of U.S. Coast Guard
3. Operations

35

Figure 3.5: Aerial 

Dispersant Group 

Assets

Figure 3.3. Diagram of the Aerial Dispersant Operations Group Structure 

Figure 3.4: Worldwide 

Dispersant Resource 

sources for Deepwater 

Horizon spill
36

3. Operations

and suffi cient safety controls were 

in place (e.g., spotter aircraft with 

embarked observers) in the event the 

Search and Rescue Mission Coordinator detected any survivors. The 

fi rst aerial application began at 1700, 

using 1,880 gallons of COREXIT 

9527. From aerial observations of 

the treated slick, the application was 

effective by employment of Tier 

I Special Monitoring of Applied 

Response Technologies (SMART) 

monitoring. The RRT received notifi cation within the 24-hour period via email on 

April 22, 2010.

Aerial Application

Aerial dispersant operations were coordinated 

through the aerial dispersant operations group 

located at the ICP in Houma, La. Initially, the 

operations were small, but expanded within one 

week to a large and comprehensive operation. The 

operations consisted of searching for slicks appropriate for dispersant application. This was done 

late in the day prior to the next day’s application. 

On the day of the operation, the slick target would 

be reacquired. Communication was made back to 

the ICP for launching dispersant planes. The group 

consisted of a spray aircraft and spotter aircraft and 

sometimes on-water SMART Tier II fl ourometry 

boats. The spotter plane guided the spray plane over 

the slick. After the spray operation, SMART boats 

would move in to conduct effectiveness monitoring 

if necessary.

The aerial application bases of operations were situated in the Stennis Space Center Airport in Mississippi and Houma-Terrebonne Airport, Houma, 

La. The Deepwater Horizon response deployed the 

largest mobilization of aerial dispersant assets and 

expertise from around the world.

Several types of aircraft conducted the operations, 

as noted in Figure 3.5.

During the Deepwater Horizon response, ninetyeight percent of the total volume aerially sprayed 

occurred more than 10 nm offshore. The closest 

area to land sprayed was just outside three nm 

from shore, in order to reduce the impact of several 

slicks from reaching Grand Isle and the Chandeleur Islands. There was no dispersant spraying over 

any land areas. Dispersants’ effectiveness decrease 

dramatically within hours of the oil being released. 

Thus dispersant application near shore would have 

been ineffective, as the oil would then have been 

on the surface for days.

The shaded area on Figure 3.6 shows boundaries 

of dispersant operations and does not suggest that 

the entire area was sprayed with dispersants. Each 

single, discrete operation applied dispersants to a 

confi ned and particular target area or slick. Aerial 

dispersant spraying operations could occur during daylight hours only. Responders made every 

Figure 3.6: 

Perimeter of All 

Aerial Dispersant 

Operations

HOUMA, La. – The crew 

of a Basler BT-67 fi xed 

wing aircraft release oil 

dispersant over an oil slick 

off the coast of Louisiana. 

Photo courtesy of U.S. 

Coast Guard. 
3. Operations

37

reasonable effort to make the fi rst dispersant application as soon as possible after the oil reached the 

surface, in order to achieve intended results.

As the Deepwater Horizon response was an ongoing major spill each day, the pre-designated FOSC 

in Morgan City approved dispersant operations 

daily. Later, the FOSC Representative (FOSCR) 

at ICP Houma and the FOSC at the UAC approved 

those operations jointly. After May 27, 2010, daily 

consultation with the EPA, via a senior representative at the UAC, was part of the required process as 

well. Throughout the response, limitations on aerial 

dispersant operations were as follows:

• Wind criteria for aircraft was less than 35 knots, 

however the RRT 6 guidance plan specifi ed 

25 knots; the increase in wind speed limit was 

only allowed when the aircraft could correct 

for spray drift.

• A 1,500 foot cloud ceiling was required, 

with 4 nm visibility for aerial applications to 

commence.

• No spray areas were permitted within 5 nm of 

the source, 2 nm of any vessel, 3 nm from shore, 

or where the water depth was less than 33 feet.

• Additional guidelines were in place for NOAA 

observers to ensure no dispersant operations 

within 3 nm of visible marine life.

• Each spray system was designed and built specifi cally for each aircraft.

• Dispersant application rate was 5 gallons per 

acre, applying a fi lm of approximately 0.0002 

inch at an altitude of approximately 50 to 75 

feet, at a speed of approximately 150 knots.

• All spray systems were fl ight-tested at 300 to 

500 micron droplet size at a swath width of 

approximately 60 to 150 feet. 

• Candidate slicks had to be continuous to avoid 

over spraying.

Aerial application of dispersants continued until 

sub-surface dispersant testing on April 30, 2010 

temporarily halted all use of dispersants. The Deputy Area Commander and the NOAA Scientifi c Support Coordinator (SSC) in Robert, La., requested 

an operational pause to review procedures, ensure 

training of oil target spotters, and ensure documentation of the monitoring data was submitted. After 

a two-day testing period, the operations continued. 

Operations resumed, and spotter plane assessments 

continued daily until aerial dispersant operations 

were limited upon receipt of the Dispersant Monitoring and Assessment Directive, Addendum 3 of 

May 26, 2010. This directive limited the use of surface dispersants to rare and unusual circumstances.

From initial application of dispersant on April 22 to 

May 26, responders used aerial dispersants 28 of 35 

days, with an average application of 24,386 gallons.

On May 26, the FOSC issued further instruction to 

the RP via written directive to reduce the amount of 

dispersants used. After negotiations with the EPA 

representative from Region VI and the EPA NRT 

chair, the FOSC agreed that:

1. The RP would endeavor to reduce the dispersant loading in the Gulf of Mexico by 75 percent, and

2. The RP would eliminate the use of surface 

dispersants entirely, unless issued a written 

exception approved the FOSC. This directive 

limited the use of surface dispersants to rare 

and unusual circumstances.

Between May 27 and July 19, aerial dispersants 

were used 33 of 54 days (61 percent), with an 

average application of 8,892 gallons, a 24 percent 

reduction in days used and a 64 percent reduction 

in the amount of dispersant applied as compared 

to the previous period of application from April 

22 to May 26.

Data from the Environmental Unit, established 

at the UAC in Robert, La., to assist the FOSC 

with environmental issues, showed a strong correlation between decreased dispersant use and 

increased shoreline oiling during the period of 

reduced application.

Sub-sea Dispersant Operations and Sub-Sea 

Monitoring

Feasibility Testing

Prior to Deepwater 

Horizon, the concept 

of sub-sea dispersant 

application had only 

been tested experimentally in shallow 

water, less than six 

times anywhere in the 

world. In late April 2010, the RP presented the 

UAC with the novel concept of applying dispersants directly at the source to mitigate oil in the 

offshore environment. At this point in the response, 

KILN, Miss. – A team 

of U.S. Air Force 

aerial spray aircraft 

maintainers from 

the 910th Aircraft 

Maintenance Squadron 

at Youngstown-Warren 

Air Reserve Station, 

Ohio, move a chemical 

pump into position 

in order to refi ll a 

chemical dispersing 

C-130 aircraft at Stennis 

International Airport. 

Photo courtesy of U.S. 

Air Force
38

3. Operations

hopes of a quick intervention and well shut-in had 

faded. Sub-sea dispersant injection at the source 

provided two major advantages over aerial application—greater effi ciency, and lack of daylight 

restrictions. The proposed method required less 

dispersant to oil dose ratios. The FOSC immediately forwarded this plan to the RRT VI for consideration. The plan consisted of a test application 

at the BOP stack leak, using a coiled tubing supply 

line from the merchant vessel Skandi Neptune, to 

inject 3,000 gallons of Corexit 9500A at 5,000 feet 

below the sea surface, using a remotely operated 

vehicle. During Test 1, one ROV held the injection wand into the plume and injected 9 gallons 

per minute of dispersants, while a second ROV 

collected samples and took video of the operation. During this test, the RP used 2,151 gallons 

of dispersant.

Test No. 1 resulted in a confi rmation that dispersant could be injected into the plume at the source 

without complication. It also provided qualitative 

observations of SONAR images taken before and 

after the dispersant injection, indicating that the 

density of the plume at depth was diminished. 

Overall results were diffi cult to interpret given the 

unique application of the technology, which was 

not calibrated. During Test No. 1, samples of the 

plume prior to and during dispersant application 

were not collected. Observers could not perform 

aerial observations of the test dispersed plume at 

the surface due to weather and visibility problems.

In addition, the captured video of the operation 

did not demonstrate the effectiveness of the oil 

dispersion. Observers requested a subsequent test 

with criteria for monitoring and sampling, which 

the RRT authorized on May 1, 2010.

The RRT approved a second test that included 

taking four samples at various depths. The RP 

did not apply aerial dispersants during the subsurface test. The aerial observation of the spill 

Figure 3.7: Shoreline impact Graph – Top graph shows cumulative shoreline impact, 

the bottom graph depicts aerial dispersant use.
3. Operations

39

area did document oil on the surface before and 

after the sub-sea dispersant application at depth. 

The second test used 13,000 gallons of dispersant. 

The RP collected samples of the non-dispersed 

oil and the dispersant and oil mixture at depth. 

Of the four samples, two were fouled and were 

not collected. The remaining samples had a very 

small amount of oil and water. Weather conditions 

offshore hampered aerial observation. Test No.2 

proceeded without aerial observation, and intermittent pumping continued until May 3. Aerial over 

fl ights resumed on May 4 and 5, but were inconclusive, highlighting the need for additional data. 

Because of the sampling problem and the lack of 

aerial visual assessment, EPA requested a meeting 

with the Environmental Unit located at Robert, La. 

The meeting was to obtain consensus on the way 

forward with respect to sub-sea dispersant use.

NOAA and Coast Guard representatives met with 

EPA representatives on May 7 to discuss the subsea dispersant operation. The discussion encompassed concerns, hindrances to the tests, and the 

monitoring plan.

Both operational tests were conducted during periods of bad weather that hampered the injection of 

the dispersant at depth and visual monitoring of 

the results. In addition, there were several delays 

due to mechanical failures of the wand used to 

apply the dispersants, and the availability of ROVs 

to conduct the test. The second test included the 

injection of 13,000 gallons of dispersant and lasted 

several hours longer than anticipated. Again, monitoring of the test visually or by SMART was not 

possible due to adverse weather—all of which 

contributed to concerns about whether to proceed 

with sub-sea dispersant application.

The agencies also discussed sub-sea dispersant 

operations monitoring plan. The parties agreed to 

work together to ensure that the sub-sea dispersant 

operation was effective and that robust toxicity 

testing took place. Additionally, the EPA and Coast 

Guard issued the RP a directive to construct and 

establish a monitoring plan for any further application of sub-sea dispersants. EPA, NOAA, and 

Environment Canada scientists continuously monitored the area in accordance with the dispersant 

directive, to ensure dissolved oxygen and toxicity tests remained within the defi ned parameters 

established by the EPA and NOAA.

The Dispersant Use Directive and the Decision to 

Approve Sub-sea Dispersant Application

On May 9, 2010, the FOSC and EPA outlined the 

initial monitoring requirements for sub-sea use 

of dispersants and signed their fi rst directive. It 

paralleled the development of an adaptive monitoring process created within the Environmental 

Unit, and principally with EPA and NOAA. The 

directive included requirements for monitoring 

oceanographic data such as temperature and oxygen concentration, detection of dispersed oil concentration using a fl uorometer system, collection 

of water samples at depth to assess oil concentrations, and biological assessment to rapidly screen 

observed dispersed oil toxicity. Oil concentration 

assessments also included tests for volatile organics, such as mono-aromatic hydrocarbons, and 

semi-volatile organics such as polycyclic aromatic 

hydrocarbons (PAHs).

On May 10, 2010 a third sub-sea dispersant test 

was requested and approved after a monitoring plan 

and shutdown criteria were developed by the RP in 

concert with the Environmental Unit at the UAC. 

Test No. 3 included use of a monitoring vessel on 

site during the test augmented with staff members 

from NOAA, EPA, and Environment Canada. The 

test collected samples for evaluation on board ship 

as well as laboratory analysis. The test demonstrated 

oil dispersion at depth.

On May 14, 2010, the RP submitted a plan to continue to use sub-sea dispersants. Because of the 

tests, EPA, Coast Guard, DOI, and NOAA gained 

concurrence through the RRT VI on May 15. With 

the consensus of the NRT, the FOSC proceeded 

with the use of sub-sea dispersants. On May 15, 

the FOSC approved the RP’s plan and issued an 

addendum to the fi rst dispersant directive requiring 

additional dispersant monitoring. A total of 771,000 

gallons of Corexit 9500A were injected sub-sea 

during the response.

Implementing the Decision to Use Sub-sea 

Dispersants

During the evolution of sub-sea dispersant use, 

the UAC established an Environmental Unit in 

Robert, La., to assist the FOSC. It quickly grew to 

include a wide range of federal, state, and industry 

scientists and representatives to coordinate elements of the sub-sea dispersant discussion. The 

Bureau of Ocean Energy Management, Regulation, and Enforcement provided data based on 
40

3. Operations

environmental impact studies and reports generated as part of the exploration and permitting 

process. The NOAA SSC was a member of the 

Environmental Unit, a leader for these activities, 

and functioned as a direct environmental consultant to the FOSC.

The Operations Section coordinated the primary 

responsibility for all sub-sea dispersant implementation and engineering development. The Environmental Unit initially focused on assessing the 

environmental trade-offs and providing the FOSC 

with guidance. By default, and given the expertise 

assembled, the Environmental Unit directly coordinated much of the operational monitoring for subsea dispersant use and evaluation. Based on NOAA 

recommendations, ICP Houma established a separate Sub-surface Monitoring Unit (SMU). However, 

the two groups maintained strong links throughout 

the response. EPA was an active participant in all 

discussions relative to the use of dispersants, and 

a member of both the Environmental Unit and the 

SMU. By the end of the summer, the combination 

of these activities characterized the Deepwater Horizon

response Sub-surface Monitoring Program. 

The Environmental Unit 

also collaborated with the 

Operations Section and 

Source Control on sub-sea 

dispersant issues in an effort 

to assess effectiveness and 

proof of action, especially 

during the initial trials and sub-sea dispersant 

tests. If the application of dispersants at the source 

were not successful or did not result in observable 

reduction of oil reaching the surface, then the continued trade-off discussions and evaluations were 

moot. The data gained from the proof-of-concept 

testing provided valuable information and initial 

confi rmation as to how the dispersants physically 

changed the transport of the oil. These were important elements in assessing overall trade-off risks 

and providing the FOSC and the RRT with the best 

information to proceed with a fi nal discussion about 

the merits of sub-sea dispersant use.

Command and control of sub-sea application assets 

for sub-sea dispersants use was accomplished from 

ICP Houston under the direction of source control 

via an Offshore Supply Vessel (OSV). When subsea application was authorized, an order was issued 

from the FOSC directly to the RP source control 

representative at the UAC and then to Houston. 

This information was then passed on to the OSV 

to begin and cease operations. The RP delivered 

dispersants either via portable tanks by an OSV on 

site, or by placing dispersants into integrated tanks 

on board the vessel. Port Fourchon, La. served as 

the base for monitoring vessels. When monitoring 

vessels arrived at the site, they always had an EPA 

or NOAA representative on board for data quality 

control purposes.

Impact Assessments and Considerations for Subsea Dispersant Application

Possible impacts and benefi ts to endangered species 

were included in the evaluation process. The only 

listed Gulf species known to swim at great depths is 

the sperm whale in search of giant squid. The Environmental Unit therefore placed particular focus on 

threats to sperm whales. Discussions included the 

effects on whales diving through dispersed oil in 

deep water or consuming squid that may have been 

exposed to deep water dispersed oil plumes. It was 

determined that risks to these animals were greatest 

at the surface, not in deep water.

Trade-off evaluations from an environmental perspective continued throughout the response with 

new information collected by the monitoring program. Understanding the transport, or movement, of 

dispersed oil was important in assessing the effects 

of dispersed oil originating 5,000 feet below the 

water’s surface. The deep waters of Mississippi 

Canyon 252 were very much a separate body of 

water when compared to the surface above. Much 

less information was readily available to assess 

possible effects of dispersants and oil in the deep.

The Gulf of Mexico is like two seas, one above 

the other, and each with its unique currents and 

ecosystems. The currents, water movement, and 

physical mixing mechanisms are different between 

the upper and deep sea. This is also true for temperatures, pressures, ecosystems, and marine life that 

inhabit the deep-water world. Unlike the warm, 

well lighted, mixed surface layer between zero 

to 700 feet, the deep sea is cold and dark, with 

mixing occurring only where currents intensify 

due to sub-sea terrain features. A density interface 

exists between the surface and deep sea. Scientists 

expected that interface to prevent movement of a 

dispersed oil plume above this depth, except at 

locations of upwelling that were much closer to 

the continental shelf than the wellhead.

The Chief Scientist on 

the NOAA research 

vessel PISCES works as 

part of the Unifi ed Area 

Command’s Subsurface 

Monitoring Unit. The 

PISCES completed a 

10-day mission in the 

northern Gulf as part of 

the Deepwater Horizon

response. Photo 

courtesy of NOAA
3. Operations

41

Natural oil seeps and methane vents are known 

processes of the deep-water world. The presence 

of natural seeps, and the understanding the deep 

sea had adapted to those oil releases, were factors 

in environmental trade-off discussions.

Initial trade-off discussions required extrapolation 

and hypotheses based on the use of dispersants 

in mixed systems, such as the surface waters in 

the open and previous laboratory and wave tank 

studies. These studies were not intended to assess 

deep-water conditions. There had been only one 

deep-water controlled release study, which took 

place off the Norwegian coast and did not include 

dispersants. The environmental trade-off discussion at the UAC did not have the benefi t of examining impacts of dispersant use during deep-water 

spills. The Norway experiment provided information regarding spill models for deep-water blowouts; thus the study offered a foundation for the 

initial transport discussion.

The Environmental Unit contacted the scientists 

directly involved with the Norway experiment to 

assist in the Deepwater Horizon response. Use of 

sub-sea dispersants required actual observation 

monitoring to lessen uncertainties. The entire process was managed by a strategy that continuously 

looped observations and new information directly 

into the continued decision-making process. Scientists incorporated the terms ‘adaptive management’ 

and ‘adaptive monitoring’ as requirements for subsea dispersant use. Sub-sea dispersant data collected 

underwent continual evaluation in relation to the 

trade-off justifi cations for approval and continued 

support by the FOSC. Monitoring was adapted to 

new concerns identifi ed by responders and stakeholders, and to better data collection methods. 

Implementation of Addendum 3 to Reduce 

Dispersant Application

As noted above, on May 26, 2010 the FOSC and 

EPA jointly issued Addendum 3 to the May 9 Dispersant Use Directive. This addendum signifi cantly 

impacted aerial, surface, and sub-sea dispersant 

operations for the remainder of the response. 

Addendum 3 was specifi cally aimed at reducing 

the amount of dispersants used, and was intended 

to focus RP efforts on the use of other available 

response methods, including booming, skimming, 

and in situ burning, rather than dispersants alone. 

Addendum 3 placed dispersants in a category for 

use as a last resort. The directive required the RP 

to request an exemption from its general prohibition on dispersant use in order to use dispersants. 

Addendum 3 achieved the desired effect: the RP 

focused on all response options and the amount 

and frequency of dispersant use dropped (see Figure 3.6). 

After May 26, the FOSC, in consultation with 

RRT VI, was empowered to consider granting 

exemptions from the dispersant use restrictions 

imposed by Addendum 3 for two reasons. First, 

the FOSC and RRT VI could permit sub-sea and 

vessel surface application of dispersants based on 

a documented need to control Volatile Organic 

Compounds in the vicinity of the vessels working to control the source at the well site. Second, 

the FOSC and RRT VI could grant an exemption 

to allow aerial dispersant application based on a 

FOSC assessment that, given weather conditions 

and response resources available, aerial application was the only means to address a signifi cant 

accumulation of oil on the surface before the oil 

moved into more highly sensitive environments.

The directive also outlined data collection and documentation requirements that the RP was required 

to meet for sub-sea dispersant use and approval.

Two elements of the directive were go or no-go 

indicators, and required daily evaluation for 

approval of continued dispersant use. The fi rst 

GULF OF MEXICO – A U.S. 

Coast Guard Petty Offi cer 

lowers a fl uorometer 

into the Gulf of Mexico. 

The instrument collects 

water samples and 

data to help determine 

the eff ectiveness of 

dispersants in breaking 

down the oil. Photo 

courtesy of U.S. Coast 

Guard
42

3. Operations

element measured oxygen concentration, which 

could not drop to a hypoxic level, or below two 

milligrams per liter. The rotifer assay, the second 

element, could not show signifi cant toxicity relative to background. The intent of the test was to 

provide a qualitative indicator to the scientists 

evaluating the fi eld data (80 percent rotifer survival 

rate). These elements did not fail the criteria at any 

time during the monitoring. The application of a 

direct toxicity assay on living organisms provided 

the FOSC with another source of fi eld data regarding potential threats. For sub-sea monitoring, a 

standardized rotifer test was used. The test exposed 

microscopic invertebrates (rotifers) that are sensitive to chemical hazards, to water collected from 

the dispersed plume. Rotifer survival rates were 

then compared to those exposed to background 

water versus impacted water.

Surface Application of Dispersant After 

Addendum 3

After adopting Addendum 3 and until the source 

was secured, the RP was compelled to request the 

use of surface dispersants due to health and safety 

concerns of personnel working on board vessels 

drilling relief wells, and the work that was continuing on the LMRP at the source. Each of these 

working vessels contained monitors and alarms to 

stop work when volatile organic compound readings reached above the threshold limit value of 

benzene (fi ve parts per million (ppm). Benzene is a 

known carcinogen. When vessels were close to the 

source control applied dispersants, the reduction 

in VOCs was signifi cant. Based on data received 

from ICP Houston, readings were at times well 

above 200 ppm.

High levels of VOCs were more than a respiratory 

hazard, they were also a signifi cant fi re hazard. 

The events that drove increases in VOCs were 

not simply a result of oil fl owing from the well. 

Even when RRT VI allowed sub-sea dispersants, 

weather, specifi cally lightning strikes in the area 

of the small city of vessels tethered to the well, 

required cessation of on-deck activities, including 

those necessary to operate the sub-sea dispersant 

applicator. Thus, a thunderstorm near the well site 

could lead to a dramatic increase in VOCs on the 

surface soon after the storm passed. As a result, in 

accordance with Addendum 3, the FOSC routinely 

allowed the RP to use surface dispersants to control 

VOCs at the source, in order to protect the health 

and safety of workers. EPA conducted air monitoring that confi rmed that the use of dispersants had 

lowered VOC levels.

Aerial Application of Dispersant After 

Addendum 3

ICP Houma implemented a decision fl ow process 

to request the surface application of dispersants 

only when a slick moved beyond the recovery capacity of skimmers and in situ burn task 

forces, or when skimmers and in situ burn task 

forces could not operate due to weather conditions, making shoreline impact of highly sensitive 

environmental areas inevitable. Dispersing the 

oil in deeper Gulf of Mexico waters, which are 

rich with oil-eating bacteria, was determined to be 

preferable to risking shoreline impact in sensitive 

environmental areas such as pelican nesting sites.

Additional Activities of Note Related to 

Dispersant Operations

Conducting such deep-water oceanographic 

assessments and monitoring a mile below the 

ocean surface required highly sophisticated equipment. It also required vessels capable of properly 

deploying sensor packages and water sampling 

equipment. Highly trained scientists and technicians were sought to conduct monitoring, maintain 

equipment, and interpret data collected. The RP 

selected the merchant vessel Brooks McCall, and 

adapted it as the sampling platform for the initial 

oceanographic monitoring cruise. Federal employees and contractors integrated with RP scientists 

and technicians to ensure the process fully incorporated federal oversight and validated all data.

In late May 2010, LSU assembled an external 

workshop to evaluate the known information 

and initial monitoring data. With its fi ndings, the 

workshop would provide the FOSC additional 

guidance on the role of dispersants specifi c to the 

Deepwater Horizon response. There was consensus from the LSU meeting that, up to that point, 

the use of dispersants and the effects of dispersed 

oil into the water column had generally been less 

environmentally harmful than allowing the oil to 

migrate on the surface into the sensitive wetlands 

and near-shore coastal habitats.

The LSU workshop confi rmed that oxygen, a key 

monitoring criterion, needed continual monitoring. 

Oxygen is required for microbes to degrade oil and 
3. Operations

43

for most marine life to survive via respiration. Scientists initially believed there was suffi cient oxygen 

in these waters. However, the demand on oxygen 

caused by degradation of dispersed oil at depth was 

unknown. Biodegradation is slower at cold temperatures, potentially reducing oxygen availability 

in the deep-water ecosystem. Therefore, what may 

take days in warm surface water may take weeks, 

months, or longer in deep cold water. The deep Gulf 

contains microbes that have the ability to degrade 

oil, as observed in seep communities. The concern 

was the possibility of overloading the deep-sea system and dropping oxygen concentrations to levels 

that created a dead zone like those which naturally 

occur off the Mississippi Delta. The monitoring and 

sampling protocols in place throughout the response 

helped document that these potential risks and concerns would not materialize.

Trade-off discussions throughout the response also 

included the impact of additional carbon loading. 

This concern arose from the additional methane 

entering into the deep-sea system. The deep-sea 

food web depends on organic carbon that drifts 

down from the upper sea and surface. This suggested 

the ecosystem could accommodate and process oil 

droplets once the oil toxic compounds dissolved 

out of the oil droplets or degraded. However, larger 

PAHs that might have persisted for long periods in 

the colder water environment could adversely affect 

very early life stages of fi sh. No mechanism was 

in place to assess this during operational monitoring. Input from the scientifi c community, damage 

assessment process, and long-term studies would 

be required to fi ll data gaps. Oil in the sea was an 

environmental threat, dispersed or not. The goal of 

the response was to manage the response strategy 

to reduce the overall impact of the spill.

The FOSC concluded, based on the continued 

review of guidance, that the potential environmental 

benefi ts in this spill justifi ed sub-sea dispersant use 

within the parameters established. This determination came in part because the long-term environmental impacts to the near-shore and estuarine 

environments were well known, and other response 

options were limited at this stage of the response. 

Monitoring for Eff ects

The FOSC continually enhanced 

the monitoring process of the 

response, which included the 

number of vessels deployed and 

addressed new and broadening 

questions (such as the presence 

and fate of any additional oil in the 

offshore environment that might 

be subject to a removal action). On 

August 3, 2010, the National Incident Commander issued a directive requiring that Deepwater Horizon monitoring 

and assessment activities be broadened to assess any 

residual oil pollution that would require removal. 

This implementation plan required enhanced sampling in three spatial domains, including:

1. Near-shore: from the marshes and beaches to 

3 nm offshore,

2. Offshore: from 3 nm to the shelf break, or the 

200 meter depth contour, and

3. Deep water: from 200 meter to 2000 meter 

water depth.

The wellhead was in 5,000 feet of water. Monitoring results and trajectory models for the deepwater 

layer, where oil and residual oil contamination 

had previously been detected, guided sampling 

in deep waters. The directive required enhanced 

sediment sampling, particularly on the continental 

shelf and in deep environments. The directive also 

required the FOSC to expand interactions with the 

academic community.

To fulfi ll this requirement, NOAA hosted a series 

of three listening sessions with the academic 

community during late August and early September. Each session focused on the sub-surface 

monitoring plan and collected feedback from the 

community to ensure the plan did not miss any 

essential pieces. Many academic vessels on scene 

participated in the daily mission guidance calls. 

Engaging the academic community through realtime maximized vessel time and sample location. 

Some academic vessels accommodated a NRDA 

sampler, or data processor, which allowed realtime data collected to be added to the sub-surface 

monitoring data. NOAA also enlisted numerous 

academics as the Chief Scientists on cruises. The 

communication allowed for collaboration between 

the needs of UAC and the ongoing research. The 

GRAND ISLE, La. – NOAA 

personnel collect water 

and sediment samples 

off the coast of Grand 

Isle State Park in the Gulf 

of Mexico to test for oil 

and dispersant levels. 

Photo courtesy of U.S. 

Coast Guard
44

3. Operations

SMU, in coordination with NOAA and National 

Science Foundation, employed an academic liaison 

at the UAC.

As a result, the UAC extended and focused monitoring activities to address the specifi c elements of 

the directive. The directive in many ways defi ned 

and validated activities that had already been 

expanding in the monitoring program. Eleven 

ships were directly or indirectly under the FOSC’s 

coordination and control as part of the Sub-surface Monitoring Program, including three NOAA 

research vessels. In addition, seven university vessels conducted cruises and research associated with 

the oil spill and coordinated with the submerged 

monitoring unit (SMU).

The degree to which monitoring was conducted at 

the direction of the FOSC in the Gulf of Mexico 

waters was unprecedented. It provided actionable 

information and documentation to assess and determine the location, fate, transport of oil, and dispersants. The FOSC also instituted a multi-agency 

Operational Science Advisory Team (OSAT I) at 

the UAC. The mission of OSAT I was to provide 

assessment and analysis of the data collected by the 

Sub-surface Monitoring Program and to inform the 

FOSC for the need to conduct any additional monitoring or response actions. During the course of the 

response, over 17,000 samples collected underwent 

environmental review by OSAT I per the monitoring 

requirements defi ned in the May 9 and August 3, 

2010 directives. The last samples collected as part 

of the Sub-surface Monitoring Program occurred 

on October 23, 2010, nearly two and a half months 

after the leak had been stopped.

Oceanographers from NOAA provided data they 

used for oil trajectory and shoreline threat probability modeling. Besides collecting urgently 

needed information, BOEMRE modifi ed and 

extended research studies already under way at 

the time of the spill. The Lophelia II expedition, 

Loop Current monitoring, socioeconomic studies, and others provided data to help evaluate the 

impacts of the spill.

Challenges to Dispersant Use

Dispersants are monitored by using the SMART 

protocol, which measures dispersant effectiveness, 

not its effects. Before the Deepwater Horizon spill, 

Self-Monitoring, Analysis, and Reporting Technology (SMART) had been effective, and dispersant 

use research revealed little or no harmful effect to 

the environment in the numerous cases where it 

had been deployed in the United States. Because 

of the unprecedented volume of dispersants applied 

to this spill, the SMART protocol was amended to 

include effects monitoring. The amount of data generated by normal SMART procedures and the new 

requirement for effects monitoring was enormous, 

and quickly generated a signifi cant data management requirement. In addition, effects monitoring 

is not real-time, so there was signifi cant delay in 

data availability. There was also disagreement on 

proper monitoring and interpretation of the data. 

This lack of supporting data fueled uncertainty on 

the effects to the environment.

End of Dispersant Use

The well was capped on July 15, 2010. The last 

use of dispersants took place on July 19. The last 

sighting of recoverable oil offshore was observed 

August 1. The volume and duration of dispersant 

use during this response were unprecedented and 

included surface and sub-sea applications. The 

amount used caused public concern and led to 

the reduction in the frequency and amount of dispersant. However, dispersants were an effective 

response tool, and prevented millions of gallons of 

oil from impacting the sensitive shorelines of the 

GOM states. This response tool made it possible 

to continue source control efforts by the vessels 

operating at the well site, and were used when other 

response options were not suitable.

GULF OF MEXICO-Dark clouds of smoke and fi re emerge during a 

controlled burn in the Gulf of Mexico. Photo courtesy of U.S. Navy
3. Operations

45

3.3 In Situ Burn Operations

Due to the enormity of the release, initial skimming 

assets were not suffi cient to contain and collect the 

surface oil. On April 26, 2010, the use of in situ 

burning in the response was proposed. As part of 

its laboratory analysis, NOAA tested the combustibility of MC 252 oil, to ensure it was amenable 

to burning activities and to determine on what 

scale this technique could be applied. Between 

April 28 and July 19, 2010, the Controlled In Situ 

Burn (CISB) Group under the Offshore Operations Branch of ICP Houma conducted 411 burns, 

removing fi ve percent of the 4.9 million barrels of 

discharged oil. Burn Task Forces conducted burns 

within the specifi ed and approved CISB Burn Area, 

typically within three to eight miles of the Mississippi Canyon 252 oil spill source.

RRT Region VI published an In Situ Burn Operations Plan in 1994. The plan specifi ed how to determine when to conduct in situ burns, how to conduct 

them, interaction with other response activities, 

the ignition process, and residue cleanup procedures. The plan also required safety and health 

monitoring, operational monitoring, effectiveness 

monitoring, and guidelines for use of the Vessels 

of Opportunity (VOO). The One Gulf Plan and 

ACPs referenced the RRT Plans. In order to fulfi ll 

the criteria of the RRT VI Pre-Authorization for in 

situ burning, the NOAA SSC helped implement the 

SMART in situ burning monitoring protocols for 

the fi rst test burns. Coast Guard Strike Team personnel deployed with in situ burning monitoring 

equipment to an offshore platform approximately 

13 miles southwest of the planned burn site. This 

was the closest location where non-responding 

personnel were located. SMART in situ burning 

monitoring protocols are designed to protect the 

general population and response workers from 

smoke particulates. SMART sampling revealed no 

detectable particulates in work zones and population centers.

Additionally, NOAA worked with the National 

Atmospheric Release Advisory Center (NARAC) 

to model potential plume releases from in situ 

burns. It was determined that the offshore location 

(a great distance from any populated areas) and 

atmospheric conditions would not pose a problem 

to the general population from particulates from 

the burns. SMART monitoring was not required 

for further burns.

Overview of Operations

In late April 2010, in accordance with the existing in situ burn plans, the OSC determined in situ 

burning was a viable response method for several 

reasons. First, weather and sea-state did not allow 

continuous skimming and the response needed 

alternatives to these methods. Second, skimmers 

and dispersants could not completely remove the 

oil releasing from the well. Finally, the OSC determined in situ burning was a safe and effective way 

to remove large volumes of oil from the ocean 

surface, based on in situ burn data from previous 

spills.

Over the course of the CISB Group’s operations, 

the team grew from fi ve people to a 264-person 

group. At the peak of operations, the CISB Group 

had three task forces, utilizing 43 vessels and two 

twin-engine aircraft. Each task force had a threevessel ignition team, two task force vessels, one 

supply vessel, a safety team, and fi ve two-vessel 

fi re boom teams. The fi re boom team vessels were 

VOO from the Houma. Coast Guard personnel, 

technical advisors, oil spill contractors, commercial fi shermen, NOAA, and EPA representatives 

staffed the CISB Group.

Personnel in each task force underwent training 

prior to engaging in situ burning operations. The 

training was a combination of four hours classroom and 12 hours on-water instruction. Some 

of the teams had underway practice days as well.

VENICE, La. – An igniter 

package is being 

placed in oil contained 

by fi re boom in the Gulf 

of Mexico in order to 

ignite an in situ burn 

near the Deepwater 

Horizon oil spill site. 

Photo courtesy of U.S. 

Air Force
46

3. Operations

Off shore Vessel Fleet

Two spotter planes provided continuous air observation for offshore in situ burning operations. To 

facilitate identifi cation and communications with 

the spotters, the fi re boom teams color-coded vessels using different colored tarps suspended over 

the back deck of the boats. In addition, the CISB 

Group used the Automatic 

Identifi cation System (AIS) 

to identify the offshore burn 

vessels from the air and confi rm their positions.

Safety and air monitoring 

personnel manned the lead 

boat (one of two) for each fi re 

boom team, which included 

fishing vessels. With the 

exception of adverse weather 

days, the in situ burning Task 

Forces and all support vessels 

were available on location by daybreak each day. 

Throughout each burn day, spotter aircraft guided 

fi re boom teams to the heaviest concentrations of 

oil. Using two King Air fi xed wing spotter planes 

fl ying two sorties each, the in situ burning Technical Advisors, Spotters, and Documenters were 

able to stay on location for approximately two and 

one-half hours before returning to Houma Airport 

for fuel. To get more spotting time coverage, the 

team attempted to fl y soon after sunrise and late in 

the evening. The CISB Group learned from these 

efforts that the angle of the sunlight determined the 

effectiveness of spotting and thus fl ights early in the 

morning and late in the day proved not as useful.

Simultaneous Operations

The Offshore Operations Branch of ICP Houma 

managed an integrated response using mechanical skimming, aerial dispersants, and controlled 

in situ burning to address approximately 16 percent of the total oil discharged from the Macondo 

Well. They safely managed high-risk operations to 

optimize oil removal for more than 40 to 50 miles 

offshore. In addition, the Operations Branch protected source control efforts at the well site using 

zone defense and a command and control vessel, 

merchant vessel Seacor Lee, to help coordinate 

removal operations.

The in situ burning task forces had to perform operations simultaneously with both the mechanical 

skimming teams and the dispersant group. The 

CISB Group originally used a burn box to place 

a boundary around the burn operations in accordance with the RRT in situ burning plan. Over 

time, the burn box was replaced by a burn circle. 

This allowed CISB Task Forces to cover greater 

areas because their turning radius conformed better 

to a circular rather than a box pattern.

Once on station, spotters circled the area observing 

oil concentrations and vectoring fi re teams to the 

oil. A log of events (times of arrival and departure 

for the spotter aircraft, times of ignition, durations 

of burn, etc.) was contained in the ICS 214 forms 

recorded for each burn day. Operations moved 

through heavy patches or long streamers of oil 

(without defl ection), and then ignited the oil once 

a suffi cient amount of oil was contained within 

the fi re boom. By late July 2010, the oil was more 

weathered and igniting became more challenging.

Wildlife Monitoring

Burning effectively removed large amounts of oil, 

approximately 265,450 barrels, from the sea surface, but had potential trade-offs with air quality 

and wildlife, most particularly turtles. Beginning 

July 5, 2010 trained and qualifi ed protected species 

observers were placed within each in situ burning 

task force to monitor for any sea turtles present 

within the fi re boom area prior to ignition. The 

observers did not spot turtles in or near fi re boom 

during the period of time when they were deployed 

on the burn vessels. 

Safety and Smoke Plumes

Attention to safety was always paramount. There 

were no injuries or illnesses resulting from the 

burning operations. Vessels downwind from the 

plume easily removed themselves from paths of 

exposure. The SMART monitoring results indicated no health impacts to the burn group members. There were some readings generated by the 

fi re boom pumps used to water-cool the fi re boom. 

This was easily remedied by moving the pumps 

from the front of the vessel to the rear.

The Coast Guard directed air sampling for dioxin, 

a known carcinogen by-product of burning operations. With the assistance of the Environmental Protection Agency, extensive sampling was performed. 

Results indicated no dioxin threat to workers and 

GOM residents.

GULF OF MEXICO – Two 

fi shing vessels drag an 

oil boom after trapped 

oil is set ablaze in the 

Gulf of Mexico as part of 

a controlled burn to aid 

in preventing the spread 

of oil. Photo courtesy of 

U.S. Navy
3. Operations

47

In the course of the 411 burns at sea, responders only intentionally extinguished two. The fi rst 

occurred with the longest burn of 11 hours and 48 

minutes. Although continuing to catch oil and feed 

it into the fi re boom, crews began to show signs of 

fatigue. They intentionally extinguished the fi re by 

increasing towing speed, which caused the oil to 

wash over or entrain under the boom. This thinned 

out the oil, which caused the fi re to extinguish.

The second occurred when a very large area fi re 

spilled out of the containment boom, and continued 

to grow in size and intensity while moving across 

the three-mile buffer zone around the source control efforts. The crews of the source control vessels 

were concerned that the fi re was encroaching on the 

three-mile buffer between the source control vessels 

and this particular burn. While the CISB determined 

the burn was still within safe parameters, the crews 

extinguished the fi re. This took approximately 90 

seconds to accomplish.

Mega Volume Burns

The CISB had their best burns on June 18, 2010. 

A total of 16 different burns were conducted with 

an estimated 50,000 to 70,000 barrels of oil consumed. The seas were unusually calm, which provided optimal conditions for burning. Some burns 

extended outside the fi re boom containment, but 

were allowed to continue to burn because they did 

not spread signifi cantly.

Burns were sustained by using aircraft to direct Task 

Forces into streamers of oil that could feed the fi re. 

There was concern that the fi re could travel up the 

boom toward the towing vessels. Careful monitoring 

and regulation of towing speeds ensured the fi re 

stayed well within the towed boom confi gurations. 

Because of the condition of the oil (weathered and 

emulsifi ed), feeding of oil into an existing burn 

was safe and effective. The fi re remained within 

the fi re boom and downstream of the towed boom 

confi guration. The CISB was able to burn some 

emulsifi ed oil, which by itself is not burnable, by 

towing existing oil fi res into emulsifi ed oil patches.

The CISB expansion to two task forces with fi ve fi re 

boom teams each required 10,000 feet of fi re boom 

available at all times. To accomplish this, CISB 

received boom from South America, Alaska, and 

Algeria. One boom design with continuous infl ation chambers sank several times during operations 

and was therefore determined to be unusable and 

potentially a safety risk. The three main types of fi re 

boom, water-cooled, stainless fl oat, and ceramic, 

all lasted well beyond expected service life. The 

most destructive action related to the boom occurred 

when crews attempted to remove a used boom from 

the water, as the stresses of a crane lifting usually 

resulted in damaging a boom beyond repair. Early 

burns revealed that in most cases, fi re boom lasted 

longer than expected, even though fi res destroyed 

between 400 and 500 feet daily.

This was the largest in situ burn operation in U.S. 

history. The burns conducted during this operation 

dramatically exceeded any previously documented 

in duration and in magnitude.

Burn Volume Calculation

Controlled In Situ Burn Summary volume calculations for each burn included a minimum and maximum estimate. The minimum volume estimate 

was based on the lower of any multiple air and 

GULF OF MEXICO – A controlled burn in the Gulf of Mexico 

is monitored by members of industry and Coast Guard 

Gulf Strike Team personnel. Photo courtesy of U.S. Navy

GULF OF MEXICO – 

Vessels of Opportunity 

pull oil into a fi re 

boom in a controlled 

burn with a second 

controlled burn visible 

in the distance. Photo 

courtesy of U.S. Coast 

Guard 
48

3. Operations

surface estimates of burn 

size, the duration of burn, 

and a burn rate of 0.05 gallons per minute (gpm) per 

square foot—the rate commonly associated with the 

controlled burning of crude 

oil that is 25 percent to 40 

percent emulsified. The 

maximum volume estimate 

was based upon the higher 

estimates of burn area, the 

duration of burn for each of 

those areas, and a burn rate 

of 0.07 gpm per square foot—the rate commonly 

associated with the burning of oil that is 10 percent 

to 20 percent emulsifi ed.

3.4 Skimming

During the Deepwater Horizon response, skimming was a key measure taken to contain, capture, 

recover, and remove oil from the environment. 

Skimming operations covered a wide geographic 

area. Hence, skimmers were a critical resource that 

required strategic management to ensure suffi cient 

capability was available at the right time, in the 

right place, and with the right support to achieve 

the best effects. Skimmers were employed in three 

types of geographic zones offshore, near-shore, 

and beach, bays, and marshes. Skimmers were 

also placed inshore, in protected waters.

Figure 3.8: Geographic skimming areas

The UAC through the ICPs employed a layered 

approach to oil containment and recovery. The 

most effective response method was containment 

of the leak at the wellhead and the recovery and 

fl aring of the captured oil and gas. Beyond this, 

the team employed a combination of sub-surface 

dispersant use, in situ burning, targeted surface 

dispersant application, and skimming to minimize 

shoreline impacts. The recovery operation of last 

resort was shoreline cleanup.

A skimmer is defi ned as any mechanical device 

specifi cally designed for the removal of oil (or oil 

and water mixture) from the surface of water without altering its physical or chemical characteristics. 

A skimmer’s performance is measured by the rate 

at which the machine recovers pure oil from an 

oily environment, the recovery effi ciency (relation 

between recovered oil and recovered fl uids), the 

throughput effi ciency, and the relation between 

recovered oil and encountered oil. A skimmer’s 

performance is affected by:

• The type of oil,

• The condition or maturity of the oil,

• Oil viscosity,

• The oil slick thickness, the presence of debris 

(e.g., driftwood, seaweed), and

• The environmental conditions including wind, 

wave, current, and the current air and sea 

temperatures.

Although skimmer effectiveness could vary dramatically based on all of these factors, given the 

indeterminate nature of the Deepwater Horizon

spill, aggressive skimming was a key component 

of the success of this response. 

There were several vessels and vessel systems used 

to skim free fl oating oil offshore. These included 

Oil Spill Response Vessels, Coast Guard Buoy 

Tenders equipped with Spilled Oil Recovery 

GULF OF MEXICO – The Coast Guard Cutter Oak skims 

thick brown oil off the coast of Alabama. Photo courtesy of 

U.S. Coast Guard

GULF OF MEXICO – Oil 

is collected in skimming 

boom attached to the U.S. 

Coast Guard Cutter Elm

operating approximately 

21 miles off the coast of 

Perdido Key, Fla. Photo 

courtesy of U.S. Coast 

Guard 
3. Operations

49

Systems (SORS), vessels equipped with Vessel 

of Opportunity Skimming System (VOSS), and 

fi shing vessels equipped with boom and skimmers 

as part of the VOO fl eet. OSRVs are designed and 

built specifi cally to recover spilled oil. These vessels have temporary storage for recovered oil and 

have the ability to separate oil and water aboard 

ship using oil-water separation systems. To sustain 

cleanup operations, most OSRVs transfer recovered oil onto other vessels or barges. VOSS are 

self-contained systems that include booms, skimmers, pumps, and temporary storage devices that 

are placed on vessels of suffi cient size to deploy 

the equipment safely. SORS equipment includes 

boom, pumps, skimmers, and storage that are part 

of a Coast Guard Buoy Tender equipment package, available for use when needed and put away 

when not in use. Finally, commercial fi shing vessels from the VOO fl eet were reconfi gured to carry 

boom and skimmers instead of nets. One of the 

biggest issues faced by the offshore skimming 

group was the offl oad of oil and oily water from 

temporary storage devices. The oil became very 

viscous, making the offl oad slow and diffi cult, 

and until a good method to offl oad the devices 

was found, this affected the ability to keep all 

assets skimming. It was important to understand 

the effect weathering and skimming had on the 

physical characteristics of the oil to determine the 

best temporary storage devices and ways to offl oad 

them in a safe and rapid manner.

By the end of April 2010, the UAC established a 

structured offshore branch comprised of 26 vessels 

capable of working in deep water, seven dedicated 

tugboats, and three offshore oil storage barges, 

which could collectively support and sustain longterm skimming operations near the source. From 

early June through mid-July, the number of skimmers fi ghting oil in the Gulf increased to 593 and 

the UAC increased skimming and beach cleanup 

activities, and prepared to move to 24-hour cleanup 

and skimming operations.

Off shore

The offshore zone encompassed the area immediately above the source where fresh oil fi rst emerged 

at the surface and outward to where the slick 

became broken and discontinuous. The extent of 

this area varied with wind, current, and wave conditions. The types of vessels sourced to this area 

were at least 50 feet long and equipped with high 

volume skimming capabilities, temporary storage, 

and crew accommodations to remain underway for 

an extended period. OSRVs and VOO Skimming 

Systems used in the offshore zone were large and 

required a lot of sea room to operate. The vessels’ 

advancing speeds averaged one knot due to the 

limitations of towing boom in dynamic offshore 

waters. Some skimming systems 

were able to attain three to fi ve 

knots due to their unique design 

and affinity for the type of oil 

spilled.

In the offshore zone, vessels 

typically encountered fresh oil, 

which then manifested in large, 

continuous brown oil slicks, some 

of which became emulsifi ed. The 

offshore environment provided 

the best opportunity for skimming oil where it 

was abundant, fresh, and far from shore. This was 

the fi rst line of defense for surface oil recovery. 

Given favorable skimming conditions—generally 

seas below six-foot swells and two-foot choppy 

waves—the number of skimmers in the offshore 

zone could be increased and directed to the heaviest concentrations of oil with aerial support to optimize recovery.

On April 28, 2010, Marine Safety Unit Morgan 

City requested immediate assistance from U.S. 

Navy Supervisor of Salvage and Diving (SUPSALV). SUPSALV equipment began arriving in 

theatre on April 29th, and SUPSALV continued 

to fi ll requirements offshore, near-shore and on 

shore until there was no oil their skimmers could 

recover in those zones.

MOBILE BAY, Ala. – A Vessel of Opportunity sets up its 

equipment as it prepares for oil-skimming activities in the Gulf 

of Mexico. Photo courtesy of U.S. Coast Guard

HOUMA, La. – A 

sweeping arm skimming 

system fi tted on a 

commercial vessel 

collects oil in the Gulf of 

Mexico. Photo courtesy 

of U.S. Coast Guard 
50

3. Operations

By late June, the Seacor 

Lee, a 280-foot Offshore 

Supply Vessel (OSV), 

became the command 

and control vessel for 

the offshore skimming 

fleet. The fleet consisted of twelve offshore 

skimming vessels and 

numerous small independent one- and twovessel operators. The RP 

retained an emergency 

response management company to provide services 

via the offshore branch.

The Seacor Lee was large, stable work platform. 

The bridge was large enough to provide a separate 

work area for response workers and not interfere 

with the Seacor Lee vessel crew. The vessel had 

satellite Internet connectivity and wireless local area 

network. The RP contractor also provided four individuals as communications technicians who stood 

watch on the communications stack twenty-four 

hours a day. Almost all communication was VHF 

Marine Band radios and mobile phones using the 

oil fi eld offshore networks. Email to those vessels 

was also available.

Communication with 

response vessels only 

using VHF became a 

problem when they 

had to operate at distances greater than 

twelve miles from 

Seacor Lee—this 

included many of the 

smaller assets. The offshore fl eet had to rely 

on relaying messages 

through several other 

vessels; this resulted in 

ineffi cient communications and misinterpreted instructions. The sheer volume of traffi c on the VHF radio frequencies made 

communication diffi cult and garbled.

Roll call of all vessels was conducted at 7:00 a.m. 

when vessel assignments were relayed. The representative based assignment decisions on the 

information available from the aviation assets, 

observations taken from vessels operating in the 

area, and the guidance provided by the UAC. Wind 

direction, sea state, and the movement of the oil 

due to tides and currents were important factors 

in the positioning of assets each day. The size and 

capability of each vessel was also a factor. Another 

dynamic was the on board storage and processing capability of the vessel. As the oil aged and 

became more viscous, the number of assets capable 

of removing that oil became limited. Removing oily 

water mixture from vessels and returning them to 

service was time consuming.

New skimming equipment, including the Big Gulp

weir skimmer, was deployed offshore. Weir skimmers collect oil fl oating on the water surface via 

weir technology, a mechanical wall whose top edge 

is placed at the oil water interface to allow the oil 

to be separated by the water. Once collected, the oil 

transferred from the weir central sink by gravity or 

by pump to storage tanks. The Big Gulp was a converted barge that acted as a large-capacity skimmer. 

A tugboat guided the barge-turned-skimmer into 

a patch of oil, often near the spill site. Oil entered 

the skimmer through a big opening in the bow of 

the barge, gathering against a bulkhead and fi nally 

spilling over into a holding tank. From there, oil 

was pumped into two holding tanks, where gravity 

separated the oil from the heavier water. Crewmembers opened a valve, sending clean water back into 

the Gulf, while capturing a mix that was 98 percent 

oil. Similar barges worked in shallow waters and 

were called Little Gulps.

The Coast Guard owns and maintains pre-positioned 

VOSS equipment suites throughout the country at 

three spill response strike teams and at strategic 

sites within each Coast Guard District. The Coast 

Guard utilized the equipment suites in support of 

the response. There are 22 cleanup systems located 

nationwide to ensure a rapid fi rst response to an oil 

or chemical spill.

Each Coast Guard VOSS consists of two of the 

following:

• Outrigger assembly with lifting davit,

• Sweep boom to collect the oil, DESMI 250 

floating weir skimmer with diesel-driven 

hydraulic prime mover and control stand and 

air compressor to recover the oil,

• Submersible 6-inch off-loading pump, or 

• Portable infl atable barges (26,000 gallons) to 

store the oil.

A Whale arrived in the Gulf of Mexico on June 

GULF OF MEXICO – The 

Seacor Lee served as one of 

the command and control 

centers for the off shore 

Deepwater Horizon oil spill 

response. Photo courtesy of 

U.S. Coast Guard. 

GULF OF MEXICO – Crew 

members from U.S. Coast 

Guard Cutter Harry 

Claiborne remove an oil 

covered boom that was part 

of a Vessel of Opportunity 

Skimming System. Photo 

courtesy of the U.S. Navy
3. Operations

51

30. A Whale, a 1,115-foot long supertanker, was 

retrofi tted and converted into a skimmer in Portugal 

to assist in the Deepwater Horizon response. The 

vessel went through an extensive operational review 

by a multi agency team under the supervision of the 

Coast Guard. After an extended trial period during which the supertanker-skimming vessel was 

given an opportunity to demonstrate its capability 

to remove oil in open seas of the Gulf of Mexico, 

the FOSC announced on July 16 that it would not 

be deployed as a part of the Deepwater Horizon 

oil spill response. (See more detailed discussion in 

Alternative Technologies section of testing 

of A Whale.)

The crew boats available to the offshore 

skimming group were 

strained by the number of crew changes 

and vessel transfers 

conducted. These 

boats were older 

vessels—built in the 

1970s—and generally were 75 to 90 feet 

long. They proved 

too small and unstable to provide safe crossing 

between vessels. This made personnel transfers 

between vessels challenging and resulted in several 

aborted transfers for safety reasons. Some smaller 

vessels and assist boats were also older and not 

outfi tted to sustain operations.

Near-shore Zone

The near-shore zone encompassed the geographic 

area just off the coast and out three miles where surface oil manifested itself in smaller, widely spread 

patches. The types of vessels sourced to this area 

were typically less than 50 feet long. Agile skimming platforms were more effective in this area 

because the vessels could quickly move between 

patches of oil. The vessels in the near-shore zone 

were equipped with weir skimmers or other types 

of skimmers appropriate for the oil encountered.

In the near-shore zone, oil manifested itself in a 

variety of ways, from bands of emulsion to racks 

of semi-solid tar balls and mats that combined with 

debris in bands. Response parties organized nearshore skimming operations into task forces that 

operated within branches along the impacted coastal 

areas. In addition, the Coast 

Guard stationed the task 

forces in gaps between barrier islands to skim oil before 

it entered sounds where it 

could impact environmentally sensitive areas. Aerial 

observations provided directional targeting to maximize 

oil recovery.

In the early stages of the 

Deepwater Horizon incident, near-shore and inland Oil Spill Response 

Organizations (OSROs) mobilized extensive 

resources. Resources cascading into the Gulf 

region supplemented the robust OSRO network 

already in the region from all areas of the country. 

The majority of skimming assets owned by the 

OSRO community are designed for near-shore 

and inland environments. During the Deepwater 

Horizon response, much of the oil that reached the 

near-shore environment co-mingled with debris or 

was tar-like and diffi cult or impossible to skim. 

As such, many of the skimmers mobilized to the 

offshore sites were ineffective in removing this 

material. To retrieve oil, manual methods such as 

nets, pool skimmers, and absorbents were more 

effective for work in this environment. 

By June, SUPSALV deployed 18 Marco Class 

V skimmers to conduct near-shore skimming 

operations in Pensacola, Fla., Panama City, Fla., 

Gulfport, Miss., Ship Island, Miss., Bayou LaBatre, Ala., Slidell, La., and Venice, La. Skimmers 

such as the Marco skimmers 

proved effective because the 

viscosity of the oil particularly suits the belt skimmers, 

and that the mobile skimming system could work 

both close inshore and 

offshore.

Nearshore and inshore skimming operations led to the 

design and use of the Little 

Gulp. The effi cient design 

of the Big Gulp skimmer for offshore served as 

the template for design of Little Gulp skimmers. 

Used primarily in shallow water environs, like the 

Big Gulp, Little Gulp skimmers employed a barge 

design that transported oily water on board, and 

then separated the oil from water.

GULF OF MEXICO - The converted tank ship 

A Whale conducts a test of its oil skimming 

capabilities on open water as part of the 

Deepwater Horizon response. Photo 

courtesy of U.S. Coast Guard

GRAND ISLE, La. – Two 

Vessels of Opportunity 

converted to oil skimmers 

conduct skimming 

operations in the waters 

near Grand Isle, La. Photo 

courtesy of U.S. Air Force 

RIGOLETS, La. – A fi shing 

vessel equipped with 

skimmers makes its way 

up and down the Rigolets 

as a precautionary 

measure to capture any 

stray tar balls. Photo 

courtesy of U.S. Coast 

Guard
52

3. Operations

Beach, Bays, and Marshes

The beach, bays, and marshes zone encompassed a 

wide range of shoreline types in the inshore environment where water and land meet. This was the most 

diverse skimming operating area due to the varied 

combinations of shoreline type, accessibility, oil 

type, and sensitivity of the environment involved.

This zone sourced a variety of skimmer types, 

including vacuum, brush, oil mop, disc, drum, belt, 

and weir skimmers. The skimmers deployed from 

land or small vessels and barges in inaccessible 

areas.

Oil in this area occurred in a wide range of conditions, including highly weathered mousse and 

pockets of black oil, tar balls, and mats of weathered 

oil and sheens. Local conditions determined the 

method skimming equipment deployed to remove 

recoverable oil.

3.5 Shoreline Protection 

(Boom, Berms, Hesco)

Across the Gulf Coast, the current ACPs and other 

spill response plans were reviewed to determine if 

they contained incorrect or obsolete information. 

As a result, the UAC and ICP Houma worked with 

federal, state, and local stakeholders, including environmental subject matter experts to draft, approve, 

and implement the Unifi ed Command Contingency 

Plan (UCCP).

They developed the UCCP during the spill to correct inconsistent or obsolete information contained 

in the current ACP, State Contingency Plan, and 

Geographic Response Plans (GRP). The current 

plans contained inaccurate refl ections of the land 

topography and the locations of critical resources 

because of recent hurricanes and storms in the 

region. In the UCCP, the UAC and ICP developed 

a tiered approach for the planning of and strategic 

use of boom quantities and its placement at the local 

level. The tiered approach as outlined in the UCCP 

included Tier 1–ACP, Tier 2–State Oil Spill Contingency Plan, and Tier 3–UCCP. The State On-Scene 

Coordinator (SOSC), the FOSC, the Responsible 

Party Incident Commander (RP IC), as well as eight 

of the 11 parishes along the Louisiana shoreline 

approved, signed, and implemented the fi nal UCCP 

document.

The UAC utilized the UCCP as a tool for boom 

allocations across the area parishes and counties, 

as agreed upon by all parties at the time. The UAC 

also designated boom as a critical resource. The 

UCCP acted as a priority mechanism for boom 

placement at the branch level, once the UAC designated containment boom as a critical resource 

nationally.

The Coast Guard based booming planning strategies that took into account local currents, wind, sea 

states, and shoreline types throughout the response 

area. The overall shoreline protection strategy 

included skimming, mechanical oil removal, burning, applying dispersants near the source, detecting and skimming oil not contained or removed 

by other means at the source, and placing boom 

near-shore in attempt to keep oil from entering 

inland water passes. Skimming vessels deployed 

in a staggered formation from offshore to inshore 

waters, and air assets guided them to specifi c 

response locations. Shallow-draft skimming vessels removed oil that passed through protective 

barriers and reached inland waters. ACPs and the 

UCCP required that boom deploy with the purpose 

of shielding environmentally and politically sensitive areas and beaches. For the oil that reached 

beaches, work crews removed the oil using hand 

tools and beach cleaning equipment.

For shoreline protection, responders employed multiple near-shore booming tactics. Defl ection boom 

was deployed near shorelines to defl ect oil onto 

pooling areas and allow recovery from land. The 

defl ection approach was utilized appropriately for 

higher current areas. Containment boom surrounded 

the collection areas created by the defl ection boom. 

Once responders corralled the oil into a collection 

HOPEDALE, La. – A 

concrete pumper has 

been converted into a 

shallow water skimmer 

and marsh washing 

system used to remove 

oil from the shoreline. 

Photo courtesy of U.S. 

Coast Guard 
3. Operations

53

area surrounded by containment boom, skimming 

vessels or portable skimmers—also known as vacuums—removed the product. Responders used isolation boom, also known as barrier or protection 

boom, in areas of high environmental sensitivity 

with very low or no current, such as within inland 

estuaries. They deployed it just off a shoreline or 

marsh area in an attempt to keep oil from reaching 

the sensitive areas. Responders took extra care not 

to disturb the environment when deploying boom 

into these areas. Most of this type of boom was 

never deployed unless the potential for oil contamination was identifi ed in the area. Instead, responders 

staged the boom and made it ready for deployment 

if needed.

Across the response area in an effort to plug the 

potential gaps in the shoreline protection efforts, 

ICP Houma began utilizing ocean booming tactics 

and techniques in an attempt to ensure free-fl oating 

oil would not impact environmentally sensitive 

areas. The UAC’s Critical Resources Unit, ICP 

Houma, together with individual states sourced, 

delivered, and implemented various types of shoreline protection strategies, such as the use of rigid 

pipe boom (defl ection boom) and fl exible boom 

placed between pilings and barges.

Upon completion across six Louisiana parishes and 

multiple counties in Alabama and Florida, more 

than 2,000 pilings were installed to hold rigid pipe 

boom and fl exible boom to protect inlets, beaches, 

and marshes. Despite lighting and other visible 

markings, this strategy posed risks to boaters 

and kayakers operating near the pilings and fi xed 

boom sections. Ultimately, the high currents in the 

passes, the lack of buoyancy in the weathered oil, 

and periodic heavy weather in the operational area 

defeated this type of protective barrier.

In contrast, some Florida counties used the strategy 

that followed the doctrine presented in the Coast 

Guard Research and Development Report entitled “Oil Spill Response in Fast Currents: A Field 

Guide” (CG-D-01-02). The swift water booming 

strategy was much less expensive and required no 

pilings or other permanent construction to operate. 

Responders staged defl ection boom in a format that 

took advantage of the natural current and tidal fl ow 

to defl ect the product into containment areas lined 

for removal. This booming strategy is illustrated 

in Figure 3.9.

Responders deployed large amounts of protection and defl ection boom throughout the response 

area. The protection strategy for St. Joseph Bay in 

Florida called for boom across the entire opening 

of the bay with several smaller sections of defl ection boom positioned near the shipping piers for 

collection, and a fi nal layer of protection boom 

stretched along the inner shoreline. Responders 

deployed most of this boom, but soon discovered 

that the boom did not protect from oil inundation 

but rather blocked the opening to the bay, and thus 

was impractical. Through the Mobile ICP, the UAC 

was able to revise the protection plan for St. Joseph 

Bay. The new plan employed VOO to tow collection boom with skimmers to collect any product 

reported in the area.

A final type of boom utilized throughout the 

response was snare boom. Instead of being a traditional protection or defl ection type of boom, snare 

boom works by collecting oily residue much like a 

common household mop. Snares are composed of 

multiple small oleophilic fi brous strands extending 

from a central point in a ball or pom-pom shape. The 

individual snares were then combined in continuous lines to form snare boom. The lengths of boom 

were then deployed along shorelines, marshlands, 

or in the water to absorb oily product. Snare boom 

is different from sentinel snares. Sentinel snares 

are crab trap-like devices that sit on the sea bottom 

tethered to a fl oating line. Attached to line at set 

intervals are pom-pom snares intended to mark the 

presence of oil. Sentinel snares were utilized in the 

water column as part of the sub-sea sampling and 

monitoring programs to help indicate the presence 

or absence of sub-sea oil.

JEFFERSON PARISH, La. – 

A vessel places containment boom along 

Barataria Bay to prevent 

oil from coming ashore. 

Photo courtesy of U.S. 

Coast Guard
54

3. Operations

In addition to Piling Projects and boom strategies, 

the ICP utilized Tiger Dam to plug gaps onshore 

where boom could not be used to protect certain 

environmentally sensitive areas. Tiger Dam is a 

heavy, thick water boom consisting of three layers 

of water-fi lled tubes utilized to mitigate the extent 

of oil impacting shorelines. Tiger Dam protected 

shorelines in several locations throughout Louisiana, such as seven miles at the Southwest Pass and 

a seven-mile stretch near Grand Isle.

Once the assigned boom was deployed to the satisfaction of the ICP Operations Section and other 

vested parties, boats and crews spent time inspecting, tending, and replacing boom as needed. Air 

crews conducted daily over fl ights to survey the 

deployed boom. Results of the surveys were routed 

daily to the fi eld for Operations personnel to conduct boom removal, replacement, and repair as 

necessary. The use of aircraft signifi cantly reduced 

the response time to tend or remove misplaced 

boom. After the wellhead was capped, operations 

focused on boom removal. Removal took several 

weeks, despite the many resources devoted to the 

tasks, including barges and cranes for boom storage. 

As part of the Florida boom removal process, the RP 

established a boom decontamination station in Port 

St. Joe, Fla. to clean non-oiled boom. Once clean, 

responders shipped the boom to an airfi eld in Tallahassee, where it was stored until it could be returned 

to its owner. The RP established other similar boom 

cleaning stations and storage facilities throughout 

the response area, such as the boom decontamination and storage facility in Prichard, Ala.

Mobile Bay Booming

ICP Mobile faced the task of protecting over 500 

separate environmentally sensitive sites that had 

been pre-designated in the Area Contingency Plan 

(ACP). These sites were located across several hundred miles of coastline along Mississippi (94 sites), 

Alabama (113 sites), and the Florida panhandle (300 

sites). As the response evolved, additional locations 

were identifi ed and added to the lists as part of the 

ACP 2.0 process. Highly diverse and sensitive ecosystems and resources were at stake throughout the 

coastal region.

Figure 3.9: 

Swift water 

booming strategy 

eventually 

adopted for East 

Pass.

GRAND ISLE, La. – A 

section of rigid pipe 

boom, which is more 

resistant to rough seas, 

is deployed in the waters 

near Grand Isle to help 

contain oil from the 

Deepwater Horizon spill. 

Photo courtesy of U.S. 

Air Force
3. Operations

55

In the Florida Panhandle Coastal Areas, these consisted of approximately:

• 80 Bird species, 6 of which are threatened or 

endangered,

• 4 Reptile species, all of which are threatened 

or endangered,

• 4 Mammal species, all of which are threatened 

or endangered,

• 9 Shellfi sh species,

• 25 Sensitive Human Use or Wildlife Refuge 

and Management areas/resources, and

• 7 barrier islands of concern, 4 Gulf islands 

National Seashore Management Areas.

In the Alabama Coastal Areas, these consisted of 

approximately:

• 112 Bird species, 13 threatened or endangered,

• 113 Fish species, 2 threatened or endangered,

• 16 Invertebrate species,

• 4 Mammal species, 3 threatened or endangered,

• 11 Reptile species, 10 threatened or endangered,

• 19 Sensitive Human Use or Wildlife Refuge 

and Management areas/resources, and

• 1 barrier island of concern.

In the Mississippi Coastal Areas, these consisted 

of approximately:

• 71 Bird species, 6 threatened or endangered,

• 78 Fish species, 1 threatened or endangered,

• 9 Shellfi sh species,

• 4 Reptile species,

• 7 Mammal species, and

• 4 barrier islands of concern, which are all Gulf 

Islands National Seashore management areas.

In May ICP Mobile signed a Decision Memo that 

laid out the fi nal booming strategies developed 

jointly by the U. S. Coast Guard, the states of Mississippi, Alabama and Florida, the U. S. National 

Park Service, and the EPA. Although the boom 

was already in the process of being deployed 

throughout the region, this memo refi ned and 

defi ned the strategies. Through this document and 

its accompanying boom maps, the ICP Mobile 

and the relevant stakeholders formally agreed to 

the overarching strategy and the amount of boom 

needed to meet the basic requirements of the ACP. 

It was understood by all parties that the strategies 

would likely be modifi ed depending on operational 

needs, environmental conditions, the intensity of 

oiling, and the availability of hard boom, but the 

strategies served as a well defi ned and agreed upon 

baseline.

Under the strategies, all priority environmental 

sites within the states of Mississippi and Alabama 

were boomed. A two tiered booming system was 

deployed in Florida, with Tier One sites boomed 

fi rst. Tier One sites were defi ned as select environmentally sensitive sites listed in the ACP, as 

well as entrances to inlets that contained multiple 

environmentally sensitive sites. If there were multiple sites within the same inlet, it was acceptable to 

boom the entrance to the inlet. Tier Two sites were 

environmentally sensitive sites contained within 

those inlets. This strategy ensured that sensitive sites 

identifi ed in the ACP would be initially protected 

by at least one layer of hard boom.

To accomplish this deployment, ICP Mobile split 

its AOR into three geographic Branches—one each 

for Mississippi, Alabama, and Florida.

The Mississippi Branch was divided into 10 

Divisions:

Region Number of 

Divisions

Initial Hard 

Boom 

Requirement

Hancock County 1 50,500 ft

Harrison County 5 139,950 ft

Jackson County 4 211,300 ft

DAUPHIN ISLAND, Ala. – An oil spill worker posts stanchions to ensure 

that the snare booms remain along the shoreline. Photo courtesy of BP
56

3. Operations

The Alabama Branch was divided into seven 

Divisions:

Region Number of 

Divisions

Initial Hard 

Boom 

Requirement

Mobile County 4 277,250 ft

Baldwin County 3 133,750 ft

The Florida Branch was divided into 21 Divisions:

Region Number of 

Divisions

Initial Hard 

Boom 

Requirement

Escambia 

County 3 131,400 ft

Okaloosa 

County 2 12,900 ft

Walton County 2 15,300 ft

Bay County 3 42,800 ft

Gulf County 3 56,300 ft

Franklin County 4 115,900 ft

Wakulla County 2 30,600 ft

Jeff erson 

County 1 4,400 ft

Taylor County 1 2,300 ft

Total hard boom required to accomplish this initial 

booming strategy was estimated to be approximately 1.2 million linear feet. This provided a 

single layer of hard boom to protect the specifi ed 

sites. These numbers grew substantially, however, 

and by July 17th, 2010, over 1.6 million linear feet 

of hard boom had been deployed along with another 

500 thousand feet of absorbent boom. The increases 

in numbers were attributable to double and triple 

booming of some environmentally sensitive sites, 

the redesigning of strategies at some sites to better protect those locations, the addition of sites in 

Hancock County, Miss, and the subsequent booming of Tier Two sites in Florida.

In addition, ICP Mobile established a “Skunk 

Works” team tasked with developing innovative 

boom deployment strategies to cover large areas 

containing multiple sensitive sites. The most noteworthy of these attempts was what became known 

as the Mobile Bay Solution. Mobile Bay has three 

main access points from the Gulf of Mexico. From 

west to east there is the Gulf Intracoastal Waterway access under the Dauphin Island Bridge, the 

mouth of Mobile Bay, and fi nally Perdido Pass. If 

oil could be prevented from entering those three 

access points, the entire Bay would be protected.

The Intracoastal Waterway, as it passes under the 

Dauphin Island Bridge, allows Gulf water to enter 

Mobile Bay from the Mississippi Sound and Katrina 

Cut. Hard boom was deployed at this location, but 

the currents fl owing through the area were substantial and reduced its effectiveness. In addition, the 

Gulf Intracoastal Waterway is a major thoroughfare 

for commercial traffi c. As a result the boom was 

pre-positioned so that the waterway could be closed 

off when the threat of oil was imminent.

The mouth of Mobile Bay presented unique challenges as it was a major artery for commercial deep 

draft vessels and the currents through it were swift. 

A lock system was developed using ocean boom. 

All vessels would be required to pass through this 

boom-lock system. The outer gate of the lock system was located south of the bay’s entrance and the 

inner gate was located north of the bay entrance. 

The boom that made up the southern portion of 

the lock extended from the tip of Pelican Island 

to Fort Morgan, Ala. The northern lock reached 

from Dauphin Island to Fort Morgan, Ala. Inbound 

vessels were required to enter a gate installed in the 

southern lock, be examined for oil contamination, 

and exit into Mobile Bay through the gate in the 

northern lock. The Coast Guard Cutter Saginaw 

drove pilings to attach the ocean boom while several contracted vessels deployed the boom.

Unfortunately, this lock system did not work. The 

currents were so swift in the area that they exerted 

forces on the boom that snapped multiple pilings. 

In addition to problems with entrainment, the currents also tore off boom fi ttings, anchor points, and 

caused other damage despite the fact that heavyduty ocean boom was used.

As an alternative, ocean boom was deployed in the 

form of in a series of open chevrons south of the 

Mobile Bay entrance. The goal of this system was 

to defl ect the oil away from the entrance. Despite 

multiple attempts and redesigns, this system did 

not work either. The force of the currents caused 

the boom to act like a sail. The boom dragged 

several thousands of pounds of anchors across the 

seabed and could not be kept on station. The boom 

also suffered signifi cant physical damage from 

the forces that the currents applied to it. Lastly, 

and most importantly, there are pipelines that run 
3. Operations

57

ashore from offshore platforms along the seabed 

in that area. The risk of dragging an anchor across 

one or more of those pipelines and damaging them 

was too great.

Perdido Pass was protected by ocean boom laid 

out in a chevron pattern similar to that discussed 

above for Mobile Bay. This design did not work at 

Perdido Pass either. Currents and wave action kept 

damaging it and shifting its position. An alternate 

system was designed and installed inside of the 

pass. This system involved a long run of ocean 

boom that extended along the entire length of the 

pass in a defl ection pattern. A gate was installed in 

it to allow recreational vessels to enter and depart 

the pass. This system, while showing initial signs 

of success, failed in the end due to the swift currents in the pass.

Louisiana

In some locations where boom was not deployed, 

Louisiana parishes took it upon themselves to 

employ and stage barges across local waterways and 

entrances to bays in an attempt to prevent oil and 

tar balls from entering the area. Responders considered the barges an additional protection measure 

to preserve the water quality in Lake Pontchartrain, 

for instance, which environmental groups such as 

the Basin Foundation had spent decades restoring. 

These fl oating barriers stretched across the Rigolets 

and Chef Menteur Pass, the deep waterways that 

connect Lake Pontchartrain and Lake Borgne in the 

Orleans and St. Tammany Parish areas. The line of 

barges across the Rigolets included a small opening at the end to allow for boat traffi c, but it could 

be closed should oil threaten. The barges proved 

ineffective on July 5, 2010, when tar balls reported 

at the Rigolets entrance to Lake Pontchartrain and 

had washed ashore as far west as Treasure Island 

subdivision in Slidell.

Responders utilized Hesco Baskets to plug other 

additional gaps along the Louisiana shoreline. 

Hesco Baskets were primarily used along the 

northern edge of Grand Isle in Jefferson Parish and 

Cameron Parish. These baskets are constructed of 

wire-mesh with fabric containers, which are then 

fi lled with sand. The sand-fi lled baskets were supposed to serve as a barrier to help prevent oily product from washing past the barrier installation and 

further onto protected beaches.

As a result of the Deepwater Horizon Oil Spill, 

the State of Louisiana requested the RP be held 

responsible to build over 100 miles of sand berm 

along the Louisiana coastline in order to catch oil 

and protect the estuaries and marshes. The original 

request included 15 sections of berm (W1-W15) 

west of the Mississippi River and four sections 

(E1-E-4) east of the Mississippi River. The berm 

construction proposals and the approved permit 

covered state owned lands and waters west of 

the Mississippi River and the federal and Department of Interior lands, 

along with the Chandeleur Islands, which 

are part of the U.S. Fish 

and Wildlife Agency’s 

Breton National Wildlife 

Refuge.

These berms did require 

a permit from the ACOE. 

After a series of meetings, the Louisiana Offi ce 

of Coastal Protection and 

Restoration (OCPR) submitted a permit request 

to the ACOE to build a 

berm over 100 miles long 

that would require over 

96 million cubic yards 

of material. OCPR estimated completion of the 

entire berm to take 6 to 9 

months with an estimated 

cost of $250 million.

Many agencies, including the Department of the 

Interior, Fish and Wildlife Service (FWS), Coastal 

Scientists with the U.S. Geological Survey, and 

other stakeholders voiced concerns. These concerns covered a broad range of topics, including 

the feasibility of the project, the constructability of 

the berms, the potential for environment impact, 

and the potential damage to the National Wildlife 

Refuge islands and aquatic habitat that could result 

from the dredging operations.

In particular, damage to the National Wildlife Refuge islands and aquatic habitat caused by dredging 

was a concern voiced by the Department of the 

Interior (DOI). The state’s original request identifi ed dredge areas closest to the barrier islands 

RIGOLETS CHANNEL, 

La. – Barges are affi xed 

together in a long line to 

act as a massive boom in 

an eff ort to keep tar balls 

from making their way 

into Lake Pontchartrain. 

Photo courtesy of U.S. 

Coast Guard
58

3. Operations

both on the seaward and inland sides of the islands. 

Dredging would remove sand that could be used 

for future, planned barrier island restoration projects and could accelerate erosion and loss of the 

islands. Coastal scientists with U.S. Geological 

Survey showed that taking sand for the berm from 

the originally identifi ed dredging locations would 

have negative impacts on the islands. They identifi ed two alternative sand borrow sites that would 

not negatively impact the island. The decision by 

the FWS not to oppose the project was based on 

the best available science using studies conducted 

by the U.S. Geological Survey (USGS Scientifi c 

Investigations Report 2009-5252: Sand Resources, 

Regional Geology, and Coastal Processes of the 

Chandeleur Islands Coastal System: An Evaluation 

of the Breton National Wildlife Refuge). The FWS 

felt the project would not protect the coast as the 

state implied, but that as long as the project did not 

negatively impact the refuge and other resources, 

FWS would not oppose the project.

The use of sand berms as an oil spill response tactic 

was untested. It was unclear if the berms would 

prove benefi cial in reducing the impacts of the oil, 

taking into consideration the long duration of construction versus the rapid movement of oil. The 

time, effort, and funding 

that were required to construct the temporary berm 

barrier brought into question the projects’ feasibility in comparison to other 

spill response techniques 

under consideration or 

being employed over the 

response area.

To construct the berms, a 

large amount of dredging 

equipment needed to be 

available in a short period 

of time. The dredging had 

to produce a large quantity 

of materials such as sand 

to construct the berms 

within the proposed specifi cations. Given the proximity to hurricane season, 

the oil and gas pipelines 

in the area, the presence 

of protected animal migration and nesting areas 

within the proposed dredging sites, and the potential 

for impact to the existing coastal Gulf restoration 

plans, it was unclear if the project would be able to 

be constructed on schedule. An added complexity 

was the resulting land and berms would be both 

private and federal (USFWS Refuge) lands.

Instead of waiting for approval, parish and state 

offi cials in Louisiana announced on national media 

they would begin the berm project utilizing local 

moneys without federal approval. In response, a 

section of Louisiana’s barrier island project proposal was approved for implementation by the 

ACOE. Under this permit, but without coordination with NIC and the UAC, ACOE authorized 

Louisiana to construct the barrier islands at its own 

expense. ACOE allowed this as long as construction met their terms and conditions and Louisiana 

obtained all other required permits. If Louisiana 

opted to move forward with the project, they would 

be required to address all potential costs and environmental impacts.

On May 27, 2010, the ACOE offered an emergency permit to the state of Louisiana for portions 

of their barrier island plan. The permit was issued 

under Emergency Permit NOD-20, with special 

conditions, authorizing the state to proceed with six 

reaches, E3 and E4 to the east of the Mississippi 

River, and W8, W9, W10, and W11 to the west. The 

six sections included 49 miles instead of the 100+ 

miles requested. The plans called for the berm to 

be 320 feet wide at the base 20 wide at the crown 

and six feet elevation. The sand borrow areas were 

predicted to be between 500 and 10,500 feet wide 

and 30-50 feet deep. On June 3, Louisiana accepted 

the permit and conditions. The permit issued was 

for only 49 miles and the six sections of berm to 

be completed. The NIC and RP approved funding 

in the amount of $360 million dollars.

In September 2010, the FOSC notifi ed Louisiana 

that although no oil had been seen on the berms in 

several months and the amount found early in the 

response was small, the ACOE permit would allow 

construction of the berms to continue and thus the 

project could continue until it was complete or the 

state expended the entire $360 million. There were 

two instances where the National Guard visited 

the berm under directions of the state to collect tar 

balls. These two instances were the only records 

MISSISSIPPI DELTA – An 

Army National Guard UH60 Blackhawk helicopter 

crew transports sandbags 

over the Mississippi Delta 

in an eff ort to shore up the 

state’s coastline as the oil 

spill approaches. Photo 

courtesy of U.S. Coast 

Guard
3. Operations

59

of oil landing on, or oil requiring removal from the 

eastern berm. To complete some of the berms, the 

most economical sources of fi ll were borrow areas 

under the jurisdiction of BOEMRE. After NOAA 

and the USFWS expressed concern over the number 

of turtle takes that had occurred already in the berm 

construction operation and other possible endangered species and essential fi sh habitat impacts of 

using the borrow areas, BOEMRE declined to allow 

the state to use them. This required bringing fi ll from 

farther away, driving up the overall costs, and thus 

reducing the amount of berms that could be built 

for the original $360 million.

In September, the Fish and Wildlife Service 

requested the state to consider moving the berm 

closer to the Chandeleur islands. On November 3, 

ACOE approved the state’s request to modify the 

emergency permit. A few days later, they realigned 

the berm construction closer to the Chandeleur 

Islands. The alignment would build the berm in 

shallower water, thereby reducing costs while providing more benefi t to the islands.

Smaller berm projects were also developed to protect sensitive habitats in Alabama. At Bon Secour 

National Wildlife Refuge near Gulf Shores, Alabama, work began in early May to protect Little 

Lagoon, an 8-mile wide estuary that provides nursery habitat for juvenile fi sh, shrimp, crabs, octopus, 

and other marine life. Refuge personnel constructed 

this berm across a pass that was formed between the 

Gulf of Mexico and Little Lagoon when Hurricane 

Ivan made landfall in 2004. Berms were also constructed in front of storm blowout areas to protect 

the dune ecosystem on the refuge, which provides 

habitat for endangered species such as the Alabama 

beach mouse and nesting sea turtles.

The shoreline protection tactics, techniques, and 

procedures utilized by the Operations Sections, and 

within individual states across the response area 

ensured a layered defense beyond sub-sea dispersant, skimming at the source, in situ burning, aerial 

dispersant use, and VOOs skimming. All those measures helped minimize the environmental impacts 

of oiling along the Gulf Coast. The protection plans 

and actions were made possible through cooperation 

between federal, state, and local offi cials, the RP, 

and environmental experts. These plans and actions 

minimized not only the threat, but also the actual 

impact of oil in the marshes and on the beaches.

3.6 Search and Respond Standards and 

Quick Reaction Forces

In June 2010, it became apparent that the response 

organization needed to react more nimbly to reports 

of oil. The decision to apply Search and Respond 

standards, use dedicated resources, and build Quick 

Response Forces stemmed from this continuing 

challenge. 

Search and Respond Standards

The ICP Mobile and ICP Houma FOSCRs developed a system to react quickly to oil reports. The 

proposed solution employed Coast Guard Search 

and Rescue Standards. These included launching 

within 30 minutes and arriving on-scene within 

two hours. The Coast Guard assigned this mission to deployed Coast Guard Marine Safety and 

Security Teams (MSSTs) in Louisiana and other 

response resources operating throughout the areas 

of responsibility.

Usually, the MSSTs did not participate in oil spill 

response. The MSSTs received a qualifi ed Coast 

Guard oil spill responder with prior training and 

experience in quantifying and qualifying observed 

oil. This was critical, as the information relayed 

back informed the decisions of ICP Houma on how 

to prioritize response efforts. If new oil observations 

reported larger volumes, a threat to sensitive areas, 

natural resources, or health and human safety, the 

branch resources responded to the new site.

This concept took the form of a Standard Operating Procedure (SOP) done in concert with a team 

of Louisiana National Guardsmen and ICP stakeholders. This group was instrumental in facilitating working meetings, capturing ideas, concepts, 

and goals, and then working them into draft standard operating procedures that could be easily and 

quickly fi nalized.

Quick Reaction Forces

Although the Search and Respond standards 

(SARES) quickly proved their usefulness, branches 
60

3. Operations

had diffi culty relying on shifting assignment of 

resources—such shifts could be cumbersome and 

time consuming. Moving resources engaged in one 

site cleanup to another site required withdrawal of 

gear, often long transit distances, and fully equipped 

supplies and logistics needed for cleanup. SARES 

development led quickly to planning for a light, 

mobile force that sat in reserve for instances where 

an area observed by a SARES team needed urgent 

action that could not wait on branch resources. 

Also, once response resources were at a branch, 

they became diffi cult to move from that area due 

to concerns of local offi cials. Similarly, placing 

standby resources at a branch for contingencies 

was diffi cult as oil continued to bear down on the 

shorelines.

Starting with the ground rule that branch level service personnel could not transition out of service at 

the branch level, planners employed another Coast 

Guard concept: a self-contained strike team able to 

support a 72-hour deployment to a site regardless 

of location—including berthing, food, water, PPE, 

skimmers, and boom. To avoid confusion with the 

term strike team, the term Quick Reaction Force 

(QRF) was adopted. This name corresponded with 

the FOSC’s expectations and avoided any confusion with the Coast Guard’s National Strike Force 

(NSF) teams. The QRF abbreviation also was generally consistent with ICS terminology, as they were 

essentially a task force. Initially, the Coast Guard 

assembled only one QRF, operated out of Houma. 

The basic unit was a contracted OSRO, complemented by Coast Guard members with NSF experience and a direct tie into the Operations Section at 

ICP Houma. Prior to initial deployment, the QRF 

engaged in mock operations to ensure this capability was openly communicated and that responders 

could meet the standards set.

Based on the success of the fi rst QRF, the Coast 

Guard created others in Grangeville, Slidell, and 

Joint Air Station New Orleans. As time went on, 

the effi ciency and effectiveness of these teams 

improved and they were a highly sought resource 

by the branches and provided invaluable assistance.

Over time, the SARES and QRFs proved the 

response organization could act quickly to reports 

of oil, and local leaders and members of the public 

expressed fewer concerns. Responders developed 

a thorough knowledge of where the accumulations 

of oil in the Louisiana marshes were most severe. 

This steadily improved the planning for response 

force placements.

Containment boom was deemed a critical resource. 

Allowing the QRFs to stockpile a modest supply in 

the rear proved successful. Once responders provided boom to a local staging area, it was diffi cult 

to move, even if operations needed it elsewhere. As 

the response continued and the QRFs matured, the 

success of the QRFs eliminated concerns regarding boom assignment as response times continued 

to improve.

Overall, the SARES and QRFs dramatically 

improved perceptions about the responsiveness of 

cleanup efforts in Louisiana. After the QRFs were 

built, drilled, expanded, and deployed, the ability to 

take the next step and respond to the triaged sites, 

essentially eliminated concerns about the timeliness 

of response. SARES and QRFs demonstrated innovative, adaptive thinking, developed and executed 

with precision in a short period.

3.7 National Guard and Department of 

Defense Support

During the Deepwater Horizon response, the 

National Guard and Department of Defense (DOD) 

were exceptional partners across a wide range of 

response activities. More than 1,530 National Guard 

members were involved in response efforts. From 

May 12, when DOD authorized the use of National 

Guard assets, throughout the response, National 

Guard aviation crews fl ew over 3,600 hours, hauled 

8,000 tons of cargo, equipment, and supplies, and 

carried over 6,500 passengers. In addition, National 

Guard personnel positioned sandbags, conducted 

evacuations, and provided air operations, public 

affairs, chaplain, communication, and transportation services.

Command and Control of National Guard and 

Department of Defense Assets

The FOSC recognized that National Guard personnel would serve as a critical force multiplier 

in the response. However, it was unclear how to 

activate and employ National Guard and other DOD 

resources. The Department of Defense had no mechanism to accept funding from the Deepwater Horizon RP. Thus, funding for any DOD support had 
3. Operations

61

to be accomplished through the Oil Spill Liability 

Trust Fund. DOD also wanted funding in advance, 

rather than through the usual practice of providing 

an invoice to the FOSC and the National Pollution 

Funds Center for payment of services rendered in 

accordance with a Request for Assistance. A funding solution was developed through the Secretary 

of Defense.

An additional hurdle to accessing DOD assets was 

FOSC coordination of domestic DOD support. 

Domestic coordination of DD resources is usually 

the responsibility of NORTHCOM. Coordinating 

permission for use of the National Guard and other 

DOD assets involved senior DOD personnel, the 

Joint Staff, NORTHCOM, and the National Guard 

Bureau. This was a complicated, time-consuming 

process. In the end, outside the National Guard, 

there was limited DOD involvement. The U.S. Navy 

Supervisor of Diving and Salvage, an organization 

that regularly participates in oil spills, was present in force. Transportation Command arranged 

for C17 support to transport resources to the Gulf 

Coast. DOD also provided some planners and Public Affairs specialists.

Obtaining National Guard support was complex as 

well. Competing interests and concerns existed over 

National Guard activation under United States Code 

Title 10, which is federally controlled and funded, 

versus United States Code Title 32 activation, which 

is state controlled and federally funded. State active 

duty is also available to recall National Guard members and it is state controlled and funded. Ultimately, 

on May 10, DOD recalled National Guard members 

to active duty under Title 32.

National Guard personnel were under state control, 

but utilized in support of a federal oil spill response 

mission guided by the NCP. Although funded by 

the FOSC, the National Guard primarily performed 

missions directed by the states, frequently without 

involvement of the Unifi ed Area Command or Incident Command Posts. The NCP addresses state and 

local participation in a response. According to the 

NCP, the designated lead state agency is responsible for determining 

the lead state response 

official (a member of 

the UAC) and communicating with any other 

state agencies (including National Guard). In 

the Deepwater Horizon

response, affected states 

designated senior members to represent state 

equities at the UAC and 

ICPs.

GULF OF MEXICO – A fl ight engineer with Florida 

National Guard’s Detachment 1, Company H, 171st 

Aviation, is part of the air support, which fl ies along 

the coast to locate oil and expedite the eff orts of 

skimming and booming along aff ected area. Photo 

courtesy of U.S. Army

GRAND TERRE EAST, 

La. – Louisiana National 

Guardsmen with the 

2225th Multi-Role Bridge 

Company support beach 

cleanup operations by 

facilitating the transport 

of heavy machinery to the 

barrier islands that were 

aff ected by the oil spill. 

Photo courtesy of the U.S. 

Coast Guard
62

3. Operations

While each state was represented at the ICPs, state 

representatives did not coordinate National Guard 

resources for their respective states. Soon, military 

Liaison Offi cers (LNOs) represented the Coast 

Guard Incident Commander at the ICPs. The primary duty of the Military LNO was to coordinate 

National Guard and DOD activities in support 

of the Deepwater Horizon response. The LNOs 

provided technical and subject matter expertise 

regarding state processes and resources available 

to assist the Coast Guard. Military and agency 

LNOs were embedded in the ICPs to provide faceto-face coordination and to include agency LNOs 

in the incident planning cycle.

A challenge for both military and agency LNOs 

was to wed the Deepwater Horizon command and 

control structure with the existing National Guard 

command and control structure. Under the NCP, 

a unifi ed command directs and coordinates the 

actions of all resources toward common objectives. The ICS management structure supports the 

unifi ed effort and decision-making.

Demobilization of National Guard Forces

Every mission assigned to these assets stays operational until the ICP Incident Commander specifi -

cally requested the National Guard to demobilize 

the capability. The process of demobilization can 

take up to 10 weeks.

3.8 Shoreline Assessment, Cleanup, 

Shoreline Cleanup Assessment 

Technique

The Shoreline Cleanup Assessment Technique 

(SCAT) program in response to the Deepwater 

Horizon incident addressed two key challenges—

the size of the affected area and the long duration 

of the response. In addition to these challenges, 

other issues included the potential for re-oiling 

before the successful capping of the well and carrying out fi nal cleanup in progressive stages. The 

areas impacted by the oil spill expanded between 

Galveston, Texas and Franklin County, Fla.

The SCAT program started in April 2010 and was 

completed at some point after April 2011. The UAC 

established two ICPs and the SCAT program was 

managed consistently across all states, from Houma, 

La., and Mobile, Ala. One of the most unique challenges characterizing the fi rst few months of the 

response was oiling and subsequent recontamination 

of the shoreline from an uncontrolled, continuous 

fl owing pollution source located beneath 5,000 of 

water in the Gulf of Mexico. This data, along with 

natural resources information, was used to develop 

cleanup priorities, identify site-specifi c or temporal 

constraints, and understand and approve the proposed cleanup plan. Using Shoreline Treatment 

Recommendation (STR) forms, teams implemented 

initial shoreline cleanup operations for designated 

shoreline segments. To ensure consistency, improve 

communications, and effectively coordinate the 

treatment recommendations with the numerous 

Operations Branches across the full geographic 

area of the response, new SCAT Operations Liaison Teams were created at all ICPs. These teams 

ensured accurate documentation of all fi ndings. 

For example, the Deepwater Horizon Shoreline 

Inspection Report (SIR) forms were updated with 

annotations for the following indications: “No Oil 

Observed,” or where no treatment was recommended at that stage, “No Further Treatment.” This 

close engagement between the UAC leadership and 

the local Branches continued throughout all subsequent stages of the shoreline assessment.

JEFFERSON PARISH, La. – A U.S. Coast Guard Petty Offi cer observes 

the state of an oil-impacted beach, taking note of the water, sand, 

and debris during a shoreline assessment on Grand Terre Island. 

Photo courtesy of U.S. Coast Guard
3. Operations

63

Following the well control, when the threat of reoiling substantially reduced, Stage III operations 

began, which initiated the fi nal stage of the response. 

This was carried out in several phases to achieve 

clearly defi ned goals of cleaning, protection, monitoring, resurvey, and further cleaning as necessary. 

Stage III commenced with an area-wide re-survey 

in fall 2010. Treatment recommendations were then 

generated to reduce oiling levels to lowest practical 

levels based primarily on Net Environmental Benefi t principles. When these levels were achieved, the 

next phase (Stage III.2) involved monitoring and 

maintenance to assess natural attenuation of any oil 

residues within individual segments.

A spring 2011 SCAT survey (Stage 4) is generating further STRs for further treatment where 

deemed necessary, for remaining oiled shorelines 

to achieve agreed Stage 4 No Further Treatment 

(NFT) guidelines. The fi nal step involves inspection by the UAC SCAT teams with the landowner 

or manager, or resource trustee or manager for each 

shoreline segment to confi rm suffi cient treatment 

has been completed.

U.S. Geological Survey Site Sampling

Even before the deployment of Shoreline Cleanup 

Assessment Technique teams, the USGS Science 

Centers in Texas, Louisiana, Mississippi, Alabama, 

and Florida began pre-landfall sampling of water 

and bottom material at 70 sites in priority areas 

of the northern Gulf of Mexico. Areas specifi cally 

sampled were the coastal wetlands and DOI lands 

at highest risk for oil contamination, including 

wetlands, shorelines, and barrier islands, which 

could suffer environmental damage if oil from the 

Deepwater Horizon spill came ashore. The prelandfall assessment occurred from May 7 through 

July 2, 2010.

The purpose of the pre-landfall assessment was 

to defi ne pre-existing or baseline conditions in 

the physical, chemical, biological, and microbiological quality of the near-shore environment. The 

USGS independently collected data to develop a 

perspective on pre-landfall conditions for future 

comparison to post-landfall samples from the same 

locations. The pre-landfall assessment is very valuable from a scientifi c perspective as this information provides a baseline to facilitate comparison 

of samples taken after-the-fact of the spills impact. 

It was hoped that these data would have a high 

degree of transfer value and be informative for 

response and recovery purposes.

All samples were collected, processed, and shipped 

under chain of custody according to methods listed 

in the USGS National Field Manual for the Collection of Water-Quality Data (NFM) (http://pubs.

water.usgs.gov/twri9A/) as well as other USGS 

standard operating procedures. By using a standard, documented set of protocols encompassing 

the entire data-collection process, the integrity, 

consistency, and comparability of the data from 

site-to-site and among sites is ensured.

The post-landfall assessment sampling was undertaken from October 5 through 17, and focused 

specifi cally on a subset of 48 of the 70 pre-landfall 

sites in a manner consistent with the pre-landfall 

assessment. Data collection and analysis activities included sampling water and bottom material 

for the physical, chemical, biological, and microbiological quality of the near-shore environment. 

These studies were undertaken after shoreline 

arrival of petroleum-associated product on beach, 

barrier islands, and wetland environments of the 

Gulf of Mexico coastal states. 

All post-landfall assessment samples were collected, processed, and shipped in the same manner 

as the pre-landfall samples. In addition, the USGS 

wrote and published an addendum to the USGS 

NFM National Field Manual for the Collection 

of Water-Quality Data (NFM), http://pubs.water.

ST. MARY’S POINT, La. – 

A Shoreline Cleanup 

Assessment Technique 

team leader from the 

University of New 

Orleans checks impacted 

shoreline as part of the 

Deepwater Horizon 

response. Photo courtesy 

of the U.S. Coast Guard
64

3. Operations

usgs.gov/twri9A/, which provides the basis for 

the post-landfall USGS sampling protocols. The 

USGS also found it necessary to develop a method 

for the analysis of dispersant components in the 

Corexit product used in the oil spill response, as 

none previously existed at the time of sampling 

(although EPA also developed a method).

Shoreline Cleanup Assessment Technique

The objective of SCAT and subsequent shoreline 

cleanup operations was to accelerate the physical 

removal and natural weathering of stranded oil. 

These operations facilitated the return of the ecosystem to pre-spill conditions as soon as practical, 

using environmental best management practices. 

The essential elements of SCAT methodology are 

mobility, surgical deployment, and speed.

Traditionally, SCAT is a survey process used by 

response agencies to document shoreline oiling. 

The technique employs a systematic approach to 

assess and develop cleanup treatment recommendations, as well as constraints for cleanup operations. The magnitude of the Deepwater Horizon

oil spill pushed SCAT well beyond its traditional 

usage; fortunately, SCAT has intrinsic fl exibility 

and operates as a continuous process from just 

prior to impact until fi nal restoration begins. In 

most oil spills, the response is centered on a one 

time, single spill with a set quantity of product, 

in a somewhat stable environment. Deepwater Horizon exceeded all traditional 

parameters.

The initial focus of SCAT 

activities was to help establish oil trajectory models. 

SCAT Teams then divided the 

shoreline within the response 

area into geographic segments 

based on a combination of factors such as physical features, 

distance, and natural barriers. 

Early in the response, the former Mobile Sector Planning 

Section developed and implemented a Natural Resource 

Adviser (NRA) program. Personnel from various 

private sector environmental contracting fi rms 

were hired, trained, and deployed to all operational 

divisions. The NRA program became an important 

interface between the Planning Section, Operations 

Section, and OSRO contractors deployed in the 

fi eld. Volunteers were also trained and deployed 

as Wildlife Observers to ensure sensitive species, 

such as turtles and nesting migratory birds, were 

not affected by oil removal operations. The NRAs 

ensured that the staging of equipment utilized in 

oil removal operations did not impact dune and 

marsh habitats. Agency representatives from the 

FWS and National Park Service (NPS) were also 

embedded as liaisons, as discussed in Chapter 5 

of this report, Planning.

A SCAT process was implemented for the Deepwater Horizon response and teams of trained 

observers were deployed to survey affected coastal 

habitats to document the shoreline oiling conditions and the presence of sensitive and cultural 

resources. At a minimum, a SCAT team is typically comprised of three positions representing the 

responsible parties, the federal trustees, and the 

state trustees. There are additional slots available 

for land managers and owners, and archaeologists 

as necessary.

Shoreline Treatment Recommendations (STRs) 

were developed in collaboration with the Coast 

ST. PETERSBURG, Fla. – A U.S. Coast Guard Petty Offi cer 

discusses oil identifi cation procedures with fellow 

team members during a Shoreline Cleanup Assessment 

Technique team training scenario held at North Shore 

Beach near downtown St. Petersburg. Photo courtesy of 

U.S. Coast Guard
3. Operations

65

Guard, NOAA National Marine Fisheries Service 

(NMFS), Fish and Wildlife Service (FWS) Section 

7, and Section 106 Archeologists. Other natural 

resource trustees, and state representatives such 

as Alabama Division of Emergency Management 

(ADEM), Florida Department of Environmental 

Protections (FDEP), Louisiana Department of 

Environmental Quality (LDEQ), and Mississippi 

Department of Environmental Quality (MDEQ) 

also participated. Furthermore, cleanup operations 

required compliance with the protection policies 

of the Endangered Species Act, the National Historic Preservation Act, and the Archaeological 

Resources Protection Act. See Chapter 8, Natural 

Resources and Wildlife, for more information. 

Throughout the summer of 2010, the SCAT teams 

were physically located within each state’s operational branch and were managed from two ICPs. 

All operations for Louisiana spill response were 

located at ICP Houma, whereas ICP Mobile managed spill response for and was the reporting hub 

for Alabama, Florida, and Mississippi. A SCAT 

Liaison was embedded into each branch and the 

ICPs to facilitate communications between SCAT, 

operations, and the ICPs.

The SCAT Management Teams established Core 

Groups at each ICP to maximize stakeholder 

involvement, address special concerns for natural, 

cultural, and amenity areas, and to promote a unifi ed 

approach to the cleanup process. Each SCAT Core 

Group adopted appropriate and effective cleanup 

strategies by developing a Stage III SCAT Shoreline 

Treatment Implementation Framework. The strategies outlined the stages of cleanup and survey and 

verifi cation methodologies. In addition, the strategies implemented a standardized Net Environmental Benefi t Analysis (NEBA) to ensure further 

damage was not caused by the cleanup techniques, 

and developed NFT guidelines. To support the 

Core Groups, three Technical Working Groups 

(TWG) were assembled to conduct detailed evaluations of cleanup techniques and environmental 

response considerations for three specifi c shoreline 

types: sand beaches, marshes and mangroves, and 

man-made shorelines. The Core Groups, in conjunction with the three TWGs, provided cleanup 

options and recommended technologies. The 

options addressed the environmental impacts to 

the shoreline, critical habitat, endangered species, 

and cultural concerns for both natural and nourished shorelines that ranged from lightly stained 

to heavily oiled.

The options included the 

following:

• Natural attenuation, 

which referred to 

processes such as 

evaporation, wave 

action, fl ushing by 

tidal movements, 

rainfall flushing, 

and degradation 

by microbial and 

photo-oxidation,

• Grooming,

• Manual removal of oil, oiled sediment, and 

debris,

• Mechanical Beach Cleaning Machines 

(sifters),

• Sediment relocation,

• Sediment tilling and mixing,

• Sand treatment (M-I SWACO),

• Raking and cutting vegetation,

• Low pressure, ambient temperature fl ushing,

• Use of sorbents, and

• Vacuuming.

Methods not utilized included in situ burning, 

chemical cleaning agents, nutrient enrichment, 

and solidifi ers.

The physical location of the spill presented logistical, tactical, and training challenges as many areas 

could only be reached by boat, skiff, or helicopter. 

This was especially true in Louisiana. For example, tide cycles periodically restricted shoreline 

survey work as certain stretches of shoreline segments were rendered inaccessible to foot traffi c 

or inundated areas impacted by oil. Storm events 

and periods of high wind and wave action often 

resulted in the burial or redistribution of stranded 

oil, requiring additional SCAT surveys and more 

intrusive survey methods such as auguring, and a 

combination of plowing and sifting for oil buried 

within sand berms.

For Deepwater Horizon, SCAT teams employed a 

three-stage plan; Stages I and II were implemented 

prior to the source being secured, and Stage III 

commenced after the source was secured. For Stage 

I, the plan emphasized the on-water recovery of 

fl oating oil slicks in near-shore waters. At Stage II, 

FORT PICKENS, Fla. – 

Members of a Snorkel 

Shoreline Cleanup 

Assessment Technique 

team fi nd and record 

evidence of oil below the 

water’s surface at Fort 

Pickens. Photo courtesy 

of U.S. Coast Guard
66

3. Operations

the plan required initial cleaning of bulk oil from 

inter-tidal areas until the oil source was secured. 

For Stage III, SCAT focused on oil removal from 

specifi c habitats and the determination of No Further Treatment (NFT) status. SCAT teams combined data collected from land and waterborne 

fi eld surveys, aerial reconnaissance, and reports 

of oil sightings from outside sources to project 

fl oating oil slicks and bulk shoreline oiling. That 

information was updated daily in standard forms 

and mapping products, and was used to prioritize 

offshore and near-shore cleanup, as well as document which shoreline segments would likely be 

impacted fi rst and worst.

Initial STRs were drafted to cover each division 

in support of Stage I and II bulk oil collection 

and cleanup. These products prescribed appropriate techniques used to address bulk surface oiling 

only. Branch directors were advised to focus on the 

largest concentrations of oil using best management practices for surface oil recovery, site access, 

and resource conservation. Supplemental information on endangered species and the preservation 

of sensitive archaeological, cultural, and historical 

objects and sites was also included. Data was also 

recorded for shoreline segments where no oil had 

been observed and no bulk cleanup conducted. 

Those areas received Shoreline Segment Inspection Reports (SIRs) recommending only natural 

attenuation with NFT in 2010 (NFT-2010) and 

were forwarded for Incident Command and UAC 

review. Shoreline segments placed in NFT-2010 

status were subject to periodic monitoring pending 

a comprehensive resurvey of all affected areas in 

spring 2011. Tables 2 and 3, provided by the FWS, 

outline the guidelines that must be met before an 

area transitioned into the NFT phase of cleanup.

Commencement of Stage III roughly corresponded 

with permanent well kill and no further observation of waterborne oil slicks. Stage III STRs 

(STR-3s) were drafted for groups of shoreline 

segments that required detailed cleanup measures 

well beyond the scope of bulk cleanup. Stage III 

STRs often prescribed treatment below the beach 

surface and addressed sub-surface oil buried under 

layers of sand due to wave and tidal action. The 

total number of segments for the Deepwater Horizon impacted area was in the thousands; however, 

segments could be grouped depending on several 

factors including terrain and the method of cleanup 

utilized, and sometimes by landowner and managers or state boundaries. As part of the shoreline surveys, SCAT would note observations of stranded 

boom to assist the Stranded Boom Removal Team.

After the shoreline surveys were completed, SCAT 

teams interacted with local offi cials and the Operations Section to identify the appropriate cleanup 

methods for the contaminated zones. The SCAT 

teams then returned to Houma to develop the formal STR. SCAT also assisted in drafting STRs to 

provide guidance for the specifi c task of Stranded 

Boom Removal (STR-126). This collaboration 

allowed for a faster approval process.

Oiling Group Cleanup Methods

Recommended Surface Oil Subsurface Oil

Oiled Residential and 

Amenity Beaches 

Mechanical (sifting);

Manual removal;

Tilling;

Sediment relocation

No visible oil above 

background levels

No visible oil above 

background levels

Oiled Non-Residential 

Beaches 

Mechanical (groomingsifting);

Manual removal; 

Sediment tilling and 

mixing; 

Natural recovery

< 1% visible surface oil and 

oiled debris; and no SRBs 

>5cm (2 inches)

No sub-surface oil 

exceeding 1-3 cm in 

thickness and patchy (10-

50%) distribution that is 

greater than Oil Residue

Other Oiled Beaches in 

Special Management Areas 

(state and federal wildlife 

refuges, parks, wilderness 

areas, which may also have 

a mix of oiling conditions)

Mechanical (groomingsifting);

Manual removal; 

Sediment relocation; 

Natural recovery

< 1% surface oil and oiled 

debris; no SRBs >2.5cm (1 

inch)

Subject to direction of 

Special Area Managers: No 

sub-surface oil exceeding 

3 cm in thickness and 

more than patchy (10-50%) 

distribution that is greater 

than Oil Residue

Table 3.2: NFT 

Guidelines for 

Sand Shorelines 
3. Operations

67

The STR approval process involved routing through 

approximately nine different agencies, including 

USFWS and NMFS Section 7 (Endangered Species 

Act review), Section 106 (Historic and Cultural 

Properties review), NOAA, Environmental Unit 

Leader, Land Managers, local offi cials, the state, 

and the FOSC. In addition to approving the STR, 

Section 7 required attachment of Applicable Best 

Management Practices (BMP) Checklists to the 

STR. The checklists indicated which BMPs were 

applicable to protect the endangered and threatened species, and critical habitats located in those 

segments contained in that particular STR. Per the 

BMPs, Section 7 consulted on the appropriate number of Natural Resource Advisors and Resource 

Advisors (READs) required to ensure SCAT and 

the Operations Section were in compliance with 

implementing the BMPs in the fi eld. Early in the 

Stage III process, the State of Mississippi made the 

choice to take over the grooming of its mainland 

amenity beaches in preparation for spring 2011.

Due to the complexity of the response and the 

number of stakeholders involved, it was diffi cult 

to achieve timely consensus or full UAC endorsement of STRs, the Stage III Framework, and other 

SCAT plans. The combined framework for Alabama, Florida, and Mississippi was fully endorsed. 

Louisiana offi cials had concerns. SCAT members 

and the UAC Governmental Affairs Director met 

with Louisiana local and state offi cials to review and 

explain the Stage III Framework. On December 20, 

the Louisiana framework was approved.

The federal trustee role and position on an offi cial 

SCAT Team may be fi lled by any of a number of 

federal entities including Department of the Interior, NPS, NOAA, or the Coast Guard.

Prior to February 2011, only seven of the more 

than 40 Coast Guard members involved with SCAT 

activities worked 25 or more days on SCAT teams; 

NOAA contractors primarily fi lled the federal representative position.

SCAT will continue for much of 2011. Coast Guard 

Reserve Marine Science Technicians will move 

into 14 federal representative slots on the spring resurvey SCAT teams, which began February 2011. 

A 7-14 day overlap with NOAA will provide training. This is the fi rst survey of nearly all segments in 

the Deepwater Horizon

area of impact since May 

2010; therefore, it will be 

a comprehensive examination of the aggregate 

impact of the entire oil 

spill. Table 3.4, provided 

by the FWS, outlines the 

total shoreline oiling estimates by state as of January 26, 2011.

Over the course of the 

response, the scale of 

the SCAT operations contributed to technological innovations. SCAT teams employed electronic 

data loggers, such as TRIMBLE units, which also 

served as handheld GPS devices. These electronic 

logs improved effi ciency by reducing fi eldwork 

note taking and report preparation time, and 

allowed SCAT data to be fed directly into the 

Common Operating Picture platform and database provided by NOAA through ERMA and GIS. 

This allowed the incident commander to have near 

real-time situation awareness of SCAT progress.

Cleanup Methods Recommended NFT Guidelines

Low-pressure, ambient-temperature fl ushing No fl ushable oil on the vegetation or soils

Use of sorbents (on water) No release of sheens that can aff ect sensitive resources

Manual removal

Use of sorbents (on substrate) Vacuum

No thick or pooled oil at the edges of, the marsh, or

the beach and shell berm, and over wash areas

No thick or pooled oil in the marsh interior, including 

isolated oiling patches within the marsh

Vegetation cutting No pooled oil inside dense Roseau cane

be accessed by other means

Natural recovery For all other oiling conditions

Table 3.3: NFT 

Guidelines for 

Coastal Marshes 

and Mangroves

GRAND ISLE, La. – A U.S. 

Coast Guard Shoreline 

Cleanup Assessment 

Technique team member 

observes workers and 

heavy equipment 

removing oiled sand and 

tar balls during beach 

cleanup operations. 

Photo courtesy of U.S. 

Coast Guard
68

3. Operations

Shoreline Clean Up Operations

The SCAT process defi ned where the oil was, in 

what quantity, and assessed cleanup techniques that 

were appropriate for the shoreline habitat. Following from approved shoreline treatment recommendations were actual shoreline cleanup operations. 

Most of the impacted shoreline was either sandy 

beach or salt marshes. The two types of areas 

required very different shoreline cleanup methods.

In general, cleanup of oiled marsh required recognition that the marsh vegetation was very easily 

damaged and thus people and machinery could 

not be placed on the marsh. There were two broad 

categories of sandy beaches: those owned by federal trustees such as the National Park Service, 

and FWS, and public “amenity beaches” used for 

swimming and recreation. The federally owned 

beaches were, for the most part, sensitive habitats 

that required careful planning to avoid damage, 

although the cleanup techniques available could be 

more invasive than for marshes. Amenity beaches 

demanded extensive cleaning in order to address 

public concerns about coming in contact with oil 

while using the beaches.

Beaches

Beaches were impacted in Louisiana, Mississippi, 

Alabama, and Florida. Florida and Alabama in 

particular had beaches in areas frequented by tourists, and thus cleaning beaches was a high priority 

in those communities because of concern of the 

impact oiled beaches would have on tourism, a 

mainstay of those local economies. Public beaches 

were also impacted in Louisiana and Mississippi. 

Although in general not as sensitive an ecosystem 

as marshes, sensitive beach areas, many of which 

belonged to the National Parks Service or U.S. Fish 

and Wildlife Service, were also impacted, mostly 

in Mississippi, Alabama, and Florida. Mississippi 

was uniquely challenging because much of the 

beach impact areas were on barrier islands several 

miles offshore with little to no public access. The 

deployment of equipment and manpower to the 

barrier islands, especially in high winds and seas 

across Mississippi, proved complex, and delayed 

more timely response.

Beach cleanup is a time consuming, labor intensive 

process. SCAT identifi ed oil impacts to beaches 

in three areas:

• Subtidal, below mean low water,

• Intertidal, between low and high tide, and

• Supratidal, above high tide to dunes.

In subtidal areas, cleanup techniques were limited. Where tar mats could be identifi ed in shallow 

enough water to permit responders to reach them 

safely, response crews waded into the water with 

modifi ed scoops and dug out the mats, scoop by 

scoop, collected the materials, and packaged them 

for disposal. Where the the tar mats became too 

deep for wading, the only effective technique was 

to map the areas where the mats were known to 

be and then regularly visit the intertidal areas near 

the submerged mats to recover tar balls. Some limited attempts were made to scoop the tar mats by 

mechanical mean in areas where the mats were close 

enough to be reached by a backhoe bucket arm, 

but often the sand proved an unstable foundation 

to support the equipment and most tar mats were 

beyond mechanical reach.

In intertidal areas, a variety of techniques were used. 

When oil was still arriving at the shoreline, sorbent 

boom of various kinds was placed on beaches and 

then regularly tended. Workers manually removed 

oil from the surface of the intertidal sand with shovels and rakes. Once oil stopped reaching the beaches, 

efforts were made to clean the intertidal areas as 

thoroughly as possible. By this point, most of the 

oil was in the form of tar balls in the intertidal areas. 

This required scooping sand and sifting through 

Table 3.4: Shoreline Oiling Estimates as of January 26, 2011

 State Total Miles Miss., Ala., 

Fla. Shoreline Habitat 

Surveyed

Heavy Moderate Light Very 

Light Trace (<1%) No Oil 

Observed

La. 3147.4 27.3 50.4 82.1 108.4 40.2 2839

Miss. 295.7 0.3 1.3 26.3 4.9 55.0 208.0

Ala. 266.9 0.3 15.1 1.2 43.1 207.1

Fla. 516.1 0.4 8.7 83.0 423.9
3. Operations

69

screens of various sizes to remove the tar balls from 

the sand. Work crews did this with shovels, rakes 

and hand sifters. Several types of commercial beach 

machines were used with modifi ed screen separators. As these beach machines were constructed to 

remove trash and debris, some modifi cation proved 

infeasible. In all, these machines were used only 

for surface sand cleaning. Furthermore, at above 

75 degrees Fahrenheit the tar balls on the beach 

tended to liquefy. Although visibility was reduced 

during darkness, the beach machines were most 

effective during nighttime operations when cooler 

temperatures congealed the oil. Later a mechanical 

cleaner, known as the Sand Shark, was employed. 

This scooped sand to a uniform depth that could 

be modifi ed, sifted the sand, collected the tar balls, 

and then deposited the sifted sand back onto the 

beach. After initial tests with the Sand Shark, the 

RP moved to acquire more of these machines to 

speed the beach cleaning process, particularly in 

public “amenity” beaches where tolerance for any 

form of oil being present was low.

In the supratidal areas, the major concerns were tar 

mats pushed beyond the intertidal area by storm 

and tidal activity. These mats could be submerged 

under a signifi cant depth of sand, and later reexposed by storm action or wind. However, these 

areas were also frequently near vegetation critical 

to beach ecosystems; this meant that cleanup had 

to be more cautious to avoid damage. Removal of 

the supratidal mats usually had to be done by work 

crews working with shovels who would dig down 

to the mat, sift the sand as they dug, and then dig 

out the mat by the shovelful.

Beaches belonging to the federal trustees required 

more careful treatment. These areas were generally more environmentally sensitive, and not used 

nearly as much for tourism. As a result, the trustee 

agencies had to balance the need for removal of 

as much oil as possible against the impact to the 

ecosystems on those beaches. Digging in search 

of buried tar mats, and for the removal of tar balls, 

was limited to a depth of six inches in these areas. 

Mechanical cleaning equipment was also not used; 

recovery was done almost entirely by work crews 

using rakes, shovels and hand sifters.

Heat and Beach 

Cleaning

During the summer of 

2010, the heat had a major 

impact on beach cleaning 

operations. The workers removing oil were in 

exposed areas. With a heat 

index that regularly rose 

above 100 degrees Fahrenheit, workers needed 

to limit their exposure to 

the oil; and with the labor 

intensive, physically demanding nature of the 

work, it became necessary to provide beach workers a place to get out of the sun and heat and keep 

them hydrated for their own safety. As recounted in 

Chapter 4, this meant limiting the amount of time 

workers could actually work between rest periods 

out of the sun. It also led ICP Mobile, in particular, 

to adopt night operations where possible, as this 

allowed work crews to spend more time removing 

oil from the beaches because the heat related risks 

were signifi cantly reduced at night.

Operational Science 

Advisory Team II Report 

on Remaining Oil on 

Beaches

After the well was capped, 

the entire impacted shoreline was evaluated by the 

SCAT process. This process continued past the 

end of hurricane season 

and into the winter. The 

FOSC requested that trustee agencies develop an 

assessment of the impact of oil on sandy beaches 

to help determine when to stop cleanup operations. 

This report was delivered to the FOSC in February 2011. It characterized the impact of oil that 

remained in the beach areas after cleanup operations. The report examined what oil remained on 

the beaches, and noted the fact that there was oil 

present from sources other than the Deepwater 

Horizon spill. It contained specifi c review of 

impact of the estimated remaining oil on sandy 

beaches to human health, sea turtles, water birds, 

terrestrial animals, and aquatic invertebrates and 

fi sh. The report used four locations, Grand Isle, 

VENICE, La. – Response 

workers clean up tar balls 

that washed up along the 

beach. Photo courtesy of 

U.S. Coast Guard

PASS CHRISTIAN, 

Miss. – Beach cleanup 

crews rest during oil 

recovery operations 

on Ship Island due 

to the oppressive 

summer heat. Photo 

courtesy of the U.S. 

Coast Guard
70

3. Operations

Louisiana, Petit Bois Island, Mississippi, Bon Secour, Alabama, and Fort Pickens, Florida as case 

studies for in-depth analysis.

The report’s analysis indicated that the environmental effects of the remaining oil after cleanup 

were relatively minor, particularly given the prespill background exposure to oil, and that continued cleanup to attempt to remove any trace of 

oil would increase the risk of negative impact to 

habitats and associated resources.

Marshes

Table 3.5 lists potential cleanup techniques for oiled 

marsh developed by the National Response Team.

The methods used most during the course of the 

response were vacuuming, sorbent boom, and absorbent peat when the oil was fresh and coming into 

shore in the marshes. As erosion of the existing 

marshes in coastal Louisiana is a signifi cant concern, and oiling suffi ciently severe to kill marsh 

grasses would accelerate erosion, fi nding ways to 

prevent oil from killing the marsh vegetation was 

a high priority. One of the techniques tried at the 

recommendation of several agencies was use of 

bagasse, the fi brous residue from sugar cane processing, which was readily available in Louisiana. 

This method proved diffi cult to deploy and then 

recover, however. Small, carefully targeted barriers constructed in appropriate locations did shield 

some particularly sensitive areas from heavy oiling. 

Still, there were some marsh areas that were heavily 

impacted. Areas of Barataria Bay and Bay Jimmy 

were the most heavily oiled marsh areas.

In an effort to identify techniques to remove oil 

from heavily impacted areas, a pilot project was 

conducted in Bay Jimmy. The project tested a range 

of cleanup techniques in small plots of heavily oiled 

marsh in an attempt to identify which technique 

would prove most effective. Techniques used in the 

plots included burning, raking, low pressure fl ushing, vacuuming, and hand application of sorbents. 

None proved dramatically effective or clearly more 

effective that natural attenuation, particularly when 

balanced against the risk of further damage being 

caused by the cleanup technique itself.

Because of the remote location of marshes, there 

were many challenges involved with these operations. First, during the summer, heat was a signifi -

cant concern, as was the threat of severe weather 

(such as thunderstorms) to those responding from 

shallow draft boats. Second, logistics to continue 

operations in these areas were complex. Getting 

supplies to these areas involved lengthy transits. 

In order to keep people on scene for longer periods of time jack up boats and fl otels were used 

to house workers near the impacted sites. Third, 

response operations generated waste that then had 

to be transported considerable distances just to get 

to a point where it could be collected and moved 

to an appropriate disposal facility in order so that 

response operations could continue. Sorbent boom 

had to be promptly recovered and removed to avoid 

risk of further damage to marsh grasses. Vacuuming 

and skimming generated oily waste that required 

on site storage, and then transportation for disposal. 

And fi nally, great care had to be taken to avoid 

damaging marsh further through actions to remove 

the oil, or just from contact with responders.

BAYOU LA BATRE, Ala. – Cleanup workers push an airboat back 

into the water which is loaded with bags of oily debris found in the 

marshes on Coff ee Island. Photo courtesy of the U.S. Coast Guard
3. Operations

71

Response Method Oiling Condition Advantages Disadvantages

Natural Recovery 

(allow the oil to 

degrade in place 

or be removed 

by tidal and wave 

action) 

Lightly or very 

lightly oiled 

marshes 

Minimal impact, avoids physical disturbance from 

cleanup actions; studies have shown rapid recovery. 

Potential oiling of birds or wildlife using the 

marsh during the time it takes the oil to be 

removed. 

Vacuuming/

Skimming (mostly 

conducted from 

boats, in conjunction 

with fl ushing to 

increase recovery 

rates) 

Moderately or 

heavily oiled 

marshes 

Removes large quantities of oil from the marsh; bulk 

oil removal will speed natural recovery of remaining 

oil. 

Diffi cult to bring equipment into marsh 

without causing some impacts such as 

crushing of vegetation; impacts may be 

considerable if not conducted properly. Only 

very shallow‐drafted vessels would be able 

to access some marsh areas. Collected oil and 

water must be transported and stored (small 

oil/water separators would reduce volume of 

oil to be treated). 

Low‐pressure 

Flushing (with water 

comparable to marsh 

type, or near water 

source) 

Moderately or 

heavily oiled 

marshes 

Can assist in oil removal by herding oil to collection 

points (used with vacuuming/skimming); lifts oil off 

sediment surface (when marsh is not fl ooded). 

Pressure must be carefully controlled to 

prevent eroding the marsh soils (erosion 

would expose vulnerable rhizomes). Must 

be carefully monitored; can cause physical 

impacts during placement of hoses and 

pumps. Can be diffi cult to achieve without 

removing above‐ground vegetation. Can 

be diffi cult to fl ush oil in desired seaward 

direction without penetrating into marsh, 

but foot traffi c on oiled marsh greatly 

compromises recovery prospects. May wash 

away loose soils exposing roots and making 

them susceptible to further oiling in tidal 

areas. 

Manual Removal 

(by hand or 

mechanized 

equipment) 

Moderately or 

heavily oiled 

marshes 

Can be best way to access pooled oil in the 

marsh interior, using boardwalks to minimize soil 

disturbance. 

Can result in signifi cant damages to the 

marsh, including soil compaction; Very 

slow, with challenging logistics for waste 

management. 

Natural Sorbent 

Materials 

(Technique A) 

A) Shredded 

sorbents applied 

to oiled marsh 

shorelines 

(including bagasse, 

hay, rice hulls, and 

cotton lint)1 

Potentially all 

oiling conditions. 

Materials can 

be applied both 

independently 

and in 

coordination with 

other remediation 

methods. 

Shoreline application of sorbents in strips 

(2 inches deep by 4‐6 feet wide) can prevent further 

penetration of oil into the interior portions of marsh 

areas. Low impact on marsh vegetation and soils, as 

sorbents are applied from shallow‐draft boats with 

blowers onto oiled shoreline areas. Natural materials 

absorb oil off vegetation and from contaminated 

soil. Sorbents provide substrate for in situ microbes 

to attenuate oil, speeding rate of oil degradation. 

Sorbent materials will also biodegrade quickly. 

Reduces risk of residual oil to wildlife from both 

contact with oiled vegetation and released sheens. 

Available in large quantities at low cost in the Gulf 

Coast region. 

Recovery of loose sorbents is not likely, so 

use is not appropriate in areas with lots of 

free‐fl oating bulk oil. Loose materials may be 

eroded by wave and tidal action from marsh 

fringe, where the oil is most likely to strand. 

Limited prior use and wide‐scale application 

or information on eff ectiveness. Heavily 

oiled material could be more persistent. 

Loose natural sorbents may contain residual 

pesticides and should be tested. 

Natural Sorbent 

Materials 

(Technique B) 

B) Shredded sorbents 

applied to unoiled 

marsh shorelines 

at imminent risk of 

oiling (including 

bagasse, hay, rice 

hulls, and cotton lint) 

Pretreatment of 

unoiled marsh 

shorelines in 

imminent danger 

of oiling 

Pretreatment prior to oiling may prevent damage to 

shoreline vegetation and soils. Shoreline application 

of sorbents in strips (2 inches deep by 4‐6 feet wide) 

can prevent further penetration of oil into the interior 

portions of marsh areas. Applied with minimal physical 

disturbance (by blower from shallow‐draft boats). 

Sorbents provide substrate for natural microbes to 

attenuate oil, speeding the rate of oil degradation. 

Sorbent materials will also biodegrade quickly. Reduces 

risk of residual oil to wildlife from both contact with 

oiled vegetation and released sheens. Available in large 

quantities at low cost in the Gulf Coast region. 

Loose materials may be eroded by wave and tidal 

action from marsh fringe, where the oil is most 

likely to strand. Limited prior use and wide‐scale 

application or information on eff ectiveness. If 

removed after oiling, increases the total amount 

of material to be removed. Oiled material will be 

transported to other areas. Heavily oiled material 

could be more persistent. Oiled materials that 

disperse into open water may sink. Loose natural 

sorbents may contain residual pesticides and 

should be tested. 

Note: This NRT table provides a list of potential response activities to be taken in an oiled marsh. This list is not to be construed as approval by the NRT, 

but rather to show potential activities that can be considered by the Incident Command.

Table 3.5: Potential oil spill response methods for marshes.
72

3. Operations

3.9 Alternative Technologies

Federal Agency Response Research and 

Development Funding

The OPA 90 establishes an Interagency Coordinating Committee on Oil Pollution Research 

to “coordinate a comprehensive program of oil 

pollution research, technology development, and 

demonstration among the Federal agencies, in 

cooperation and coordination with industry, universities, research institutions, State governments, 

and other nations, as appropriate, and . . . foster 

cost-effective research mechanisms, including 

the joint funding of research.” The Coast Guard 

chairs the committee, which includes representatives from fourteen federal agencies. The Committee produced the fi rst Oil Pollution Research 

and Technology Plan in 1992, and a second plan 

and the most updated plan in 1997.

Coast Guard Oil Spill Research

The Coast Guard conducts oil spill research 

through its Research and Development Center in 

Groton, Connecticut. Coast Guard’s budget for oil 

spill research was $5.6 million in 1993, held constant at $3.5 million from 1998 through 2004, and 

was $500,000 per year between 2007 and 2010. 

The Coast Guard allocated its research and development budget to four main areas: spill response 

planning and management, spill detection and surveillance, vessel salvage and on-board containment, and spilled oil cleanup and countermeasures.

Assessment of Alternative Response 

Technology at the Unifi ed Area Command 

and Incident Command Posts

The Alternative Response Technology Evaluation System (ARTES) teams reviewed over 10,000 

submissions for ideas for the cleanup operations. 

Despite their tremendous accomplishments, they 

were quite understaffed. ARTES has existed since 

1993 and has been effective in addressing ideas 

submitted during past oil spill responses. The Coast 

Guard Research and Development Center staff provided the key positions for the ARTES team.

Interagency Alternative Technology 

Assessment Program

On May 10, 2010, the National Incident Command established the Interagency Technology 

Assessment Program (IATAP). The NIC established IATAP to allow government-led evaluation 

of the thousands of offers of innovative response 

technologies from both domestic and international 

entities. This was made possible by means of a 

Broad Agency Announcement (BAA) for vendors 

to submit proposals. Proposals were evaluated 

based upon overall scientifi c and technical merit, 

feasibility, the availability of the proposed solution, and a rough order of magnitude cost. As of 

September 2, the IATAP received approximately 

3,900 submissions, 96 percent of which underwent 

evaluation and adjudication. Proposals that had the 

potential to assist in the response were forwarded 

to the Critical Resources Unit at the UAC for possible implementation.

A Whale: An Example

Not all innovative technologies tested during the 

response were successful. Some were tried after 

they caught press and public attention. When such 

applications proved ineffective, considerable time 

and effort were required to explain why these tools 

were not used further. A Whale is an example of 

this phenomenon.

In May, an owner proposed the modifi cation of 

the 1,100 foot, “very large ore and oil carrier,” A 

Whale, to make it the world’s largest weir skimmer. Weir skimmers function by allowing the 

thin surface layer of oil to pass over the top of 

the weir while the water is held back. Effi ciency 

is determined by how accurately this oil layer is 

“sliced” to produce a high oil-to-water recovery 

ratio. A Whale’s design theorized that the ship’s 

huge capacity and ability to separate oil from water 

would make up in volume what it lacked in fi nesse 

(in terms of effi cient oil/water intake ratio).

A team of specialists representing naval architecture (for ship strength and stability concerns), spill 

response technology, and ship operations reviewed 

the proposal and concluded that the design theory 

could not overcome the sea conditions and the low 

oil encounter rate the ship would experience on the 

Gulf of Mexico. (“Encounter rate” is the amount of 
3. Operations

73

oil presented to the skimmer and is determined by 

oil thickness, sweep width and speed of advance.) 

Due to the thin layer of oil surfacing in the Gulf, 

encounter rates were low and required very effi -

cient booming operations. Sea conditions, even 

swells as low as one to two feet, would cause far 

more water to be taken in than oil. Ship stability 

and structural loads were also a concern. Based on 

the expert review, the offer was declined.

The owner of A Whale proceeded to modify the 

ship in Europe, again made an offer to assist (this 

time directly to the government through the IATAP 

process), set sail for the US east coast, and hired a 

publicist “to help negotiate with federal regulators 

and to create public pressure in favor of A Whale.” 

(Roanoke Times, June 26, 2010.) When A Whale 

arrived in the Gulf of Mexico, the owner, FOSC, 

and RP agreed to a proof-of-concept test in the 

vicinity of the spill site where the other “large” 

skimmers were operating. (“Large” is relative: at 

208 feet, the oil skimming ships owned by MSRC 

were dwarfed by A Whale.)

In early July, the initial design was tested. The 

design incorporated large slits near the bow to 

act as a weir for oil and water intake. The slits led 

into a chamber intended to break up thick, heavy 

oil into a form that would fl ow more easily. The 

inboard bulkhead of the chamber, opposite the 

weir, had a series of pipes that could be opened 

to allow oil and water to enter the cargo tanks to 

begin separation. Because more water entered the 

chamber past the weir than could fl ow through the 

pipes leading into the cargo tank, water also fl owed 

back out of the weir as the trough of a swell passed. 

The turbulence created around the intake by this 

constant in and out fl ow of water created a barrier 

to oil fl oating on the surface (see photo below).

After two days of testing, including the use of a 

boom to increase the encounter rate, A Whale collected virtually no oil. It was evident that the barrier created by the turbulence prevented oil from 

entering the weir. The owner requested, and the 

FOSC approved, an extension of time in which to 

modify A Whale’s design to one in which the side 

openings would be directly piped into the cargo 

system. The new design was tested in mid-July. 

It resolved the turbulence problem, but the intake 

effi ciency was very low, even in “calm” seas in 

which the opening was alternatively submerged 

and “high and dry” as the crest and trough of a 

swell passed. After a full day of testing, no oil 

was found in the main cargo tank and only residue 

found in an intervening wing tank. Based on the 

testing, the FOSC concluded that A Whale was 

ineffective in the conditions found on the Gulf—

thin, patchy oil in a slight to moderate sea state.

GULF OF MEXICO – The Coast Guard Cutter Resolute steams 

alongside A Whale, which is a tanker converted into an oil skimmer. 

Photo courtesy of the U.S. Coast Guard

GULF OF MEXICO-The A WHALE, a cargo ship converted to a 

weir skimmer, discharges water while undergoing proof of 

concept testing
74

3. Operations

3.10 Concurrent Emergency Response 

and Natural Resource Damage 

Assessment

A major goal of OPA 90 is to make the environment and public whole for injury to or loss of 

natural resources and services due to a discharge 

or substantial threat of a discharge of oil (referred 

to as an incident). This goal is achieved through 

returning injured natural resources and services to 

the condition in which they would have been if the 

incident had not occurred, otherwise referred to 

as baseline conditions. It is also achieved through 

compensating for interim losses from the date of 

the incident until recovery of such natural resources 

and services through the restoration, rehabilitation, 

replacement, or acquisition of equivalent natural 

resources and services.

The Natural Resource Damage Assessment 

(NRDA) process in the OPA90 regulations 

includes three phases: Preassessment, Restoration Planning, and Restoration Implementation.

The purpose of the Preassessment Phase is to determine if the trustees have the jurisdiction to pursue 

restoration under OPA 90 and, if so, whether it is 

appropriate. In the case of Deepwater Horizon, the 

trustees did determine that they had the jurisdiction 

to pursue restoration. The preliminary assessment 

phase began when the trustees were notifi ed of the 

incident by response agencies. Once notifi ed of the 

incident, trustees fi rst determined the threshold 

criteria that provided their authority to initiate the 

NRDA process. Based on early available information, trustees made a preliminary determination 

that natural resources or services had likely been 

injured. Through coordination with response agencies, trustees next determined whether response 

actions were expected to adequately address injuries resulting from the spill.

Restoration Planning evaluates potential injuries 

to natural resources and services, and uses that 

information to determine the need for and scale 

of restoration actions. The Restoration Planning 

Phase has two basic components, injury assessment and restoration selection.

Injury assessment determines the nature, degree, 

and extent of any injuries to natural resources and 

services. This information is necessary to provide 

a technical basis for evaluating the need for, type 

of, and scale of restoration actions. Under the OPA 

90 regulations, injury is defi ned as an observable 

or measurable adverse change in a natural resource 

or impairment of a natural resource service.

COCODRIE, La. – Absorbent 

boom, which helps reduce 

the amount of oil reaching 

the marshes, lies in the 

marshes near Cocodrie. 

Photo courtesy of the U.S. 

Coast Guard
3. Operations

75

In considering both natural resources and services, 

trustees are addressing the physical and biological 

environment, and the relationship of people with 

that environment.

NOAA’s Damage Assessment Remediation and 

Restoration Program (DARRP) acts on behalf of the 

public as a trustee to manage, protect, and restore 

coastal and marine resources. Public lands, waters, 

and living resources are held in trust for the benefi t 

of all people and future generations. Stewardship 

of the nation’s natural resources is shared among 

several federal agencies, states, and tribal trustees.

When possible, NOAA works cooperatively with 

the parties responsible for the injury. By working 

with the RP and co-trustees to collect data, conduct assessments, and identify restoration projects, NOAA avoids lengthy litigation and achieves 

restoration of injured resources more effi ciently.

The scope of the Natural Resource Damage 

Assessment will include impacts to fi sh, shellfi sh, 

marine mammals, turtles, birds, and other sensitive 

resources, as well as their habitats, including wetlands, beaches, mudfl ats, bottom sediments, corals, 

and the water column. The trustees will assess any 

lost human uses of these resources, for example, 

fi shing, hunting, and beach recreational closures. 

The trustees will also determine the effi cacy of 

evaluating impacts from the response, including 

burning, and dispersant use at the surface and at 

depth.

NOAA’s DARRP is coordinating this effort with 

natural resource trustees in fi ve states (La., Miss., 

Ala., Tx., and Fla.), the Department of Interior FWS 

and National Park Service (NPS), and the RP. Multiple agencies from each state are engaged. DoD is 

also a trustee in this case due to impacted property, 

though they do not actively participate.

Natural resource trustee agencies (including NOAA, 

DOI, state agencies, and Tribal Governments) are 

responsible for trust resources as designated by the 

National Contingency Plan (40 CFR 300.600).

The DOI trust resources include migratory birds, 

andromous fish, endangered species, marine 

mammals, federally owned minerals, and certain 

federally managed water resources. DOI is also a 

trustee for natural resources for which an Indian 

tribe would otherwise act as trustee. In those cases 

the United States acts on behalf of the Indian tribe.

State trust resources include wetlands, surface 

waters, ground waters, air, soil, wildlife, aquatic 

life, and the habitats on which they depend

The work that is being conducted under the Pre 

Assessment Phase of the NRDA is being carried out 

cooperatively with RP. This means that the trustees are jointly meeting with RP to discuss NRDA 

actions, and that RP is integrated into several NRDA 

Technical Working Groups (TWGs) that have been 

formed to investigate potential injuries to particular 

resource groups or habitats.

The focus of the TWGs is to assemble a variety 

of existing data on resources, their habitats, and 

their human uses, and to collect baseline, or prespill, data wherever possible. Information about 

impacts on these resources and their uses is also 

being assembled. NOAA is providing scientifi c and 

technical expertise and information management to 

many parts of the overall NRDA effort.

Trustees are required to demonstrate causality 

between the release—or substantial threat of a 

release—of oil, and injured resources, lost services, or lost human use of those resources and 

services. This requires linking the release of oil, 

its fate, and transport in the environment, exposure of natural resources to the oil, and its effects 

on the biota and human uses. Determining the 

amount of injury and appropriate restoration also 

requires consideration of the condition of the natural resources and human uses if the spill had not 

occurred, i.e., baseline conditions.

GRAND ISLE, La. –

 Laughing gulls 

congregate in the 

marshes near Bay 

Jimmy. These marshes 

are home to many 

species of birds 

including brown 

pelicans, egrets, roseate 

spoonbills, and stilts. 

Photo courtesy of the 

U.S. Coast Guard
76

3. Operations

Trustees seek to restore injured resources and services to baseline and to compensate the public for 

interim losses, i.e., the time it takes the resources 

to recover. Over the course of the NRDA process, 

the trustees assess the nature and extent of the injuries, develop a restoration plan, seek compensation 

from the RP for damage assessment and restoration 

costs, oversee or implement the restoration plan, 

and conduct and oversee monitoring to ensure restoration has occurred. Liability for natural resource 

damages is in addition to liability for cleanup.

During an oil spill, response and NRDA activities 

may be occurring simultaneously. It is sometimes 

assumed that these two processes exist independently of each other and that the data collected to 

guide the response operations are different from 

the data gathered for NRDA. However, a review 

of OPA 90 and guidance documents indicates that 

these activities are intended to work in a cooperative, holistic manner. Typically, trustees work in 

the environmental unit under the ICS, providing 

data such as resources at risk. However, they may 

also be trying to gather ephemeral data necessary to 

support a NRDA and looking for opportunities for 

emergency restoration projects that may mitigate 

further injury or help the injured resource recover 

more quickly.

Trustees have a somewhat different job from that 

of the oil spill-response personnel. Responders, 

such as the SCAT teams, do not generally have 

time to do detailed scientifi c studies. Their interest 

is in reducing the impact of the spill and cleaning 

it. The trustees, on the other hand, need to assess 

the extent of the injuries and may use data gathered 

from SCAT to determine oiled habitats requiring 

further assessment. The assessment can be used 

to determine the extent of the impacts and scale 

of restoration necessary to compensate the public 

for the lost resources.

Funds eventually recovered through the NRDA 

process are used to restore injured resources, or the 

RP may implement restoration projects with trustee 

oversight. Much of the evidence of these injuries 

is ephemeral and will gradually be removed by 

cleanup and natural processes, therefore the trustees need to be on scene to collect the injury data 

immediately following an incident. In addition to 

assessing damage for long-term restoration, the 

trustees may be able to identify emergency restoration actions that will reduce the impacts from 

spills, thus assisting the responders.

However, OPA 90 makes it clear that NRDA 

does not and should not trump response actions. 

If emergency restoration actions are proposed to 

occur during the active response phase, which 

may impede the response, these regulations ensure 

that the OSC is the fi nal word on whether this 

emergency restoration should be undertaken. If 

response actions are still under way, trustees must 

coordinate with the OSC to ensure emergency restoration actions will not interfere with or duplicate 

ongoing response actions. The OPA 90 regulations also prescribe that trustees make an effort to 

coordinate emergency restoration actions with the 

RP. Typically, there is a formal invitation from the 

trustees to the RP for a cooperative assessment, but 

this usually occurs after the response phase ends or 

is nearly ended. However, coordination between 

the trustees and RP usually begins soon after the 

trustee and RP representatives arrive on scene.

OPA 90 also provides guidance on how ephemeral data should be collected and treated during 

an ongoing response. The regulations state that 

trustees may conduct data collections that are reasonably related to Preassessment Phase activities. 

However, data collection must be coordinated 

with response actions such that collection of the 

data does not interfere with response actions. 

Trustees may collect and analyze ephemeral data; 

and information needed to design or implement 

anticipated injury assessment procedures. Examples of ephemeral data include:

• Surface water or soil likely to contain oil, 

where those samples may be necessary 

for identifi cation and for measurement of 

concentrations,

• Samples that may be lost because of factors 

such as dilution, movement, decomposition, 

or leaching,

• A source sample, vital for fi ngerprinting that 

can be used to calibrate and verify model 

results,

• Counts of dead or visibly injured organisms 

because of factors such as decomposition, 

scavenging, or water movement, and

• Scavenging experiments that may need to be 

performed to understand how quickly dead 

and injured wildlife may have been removed 

from the area.
3. Operations

77

The Incident Management Handbook (IMH) is 

another good resource to determine how NRDA 

activities relate to response activities. It prescribes responsibilities to parties that act in the 

response planning, logistics, and operations, 

as well as the command staff. For example, it 

states that the Liaison Offi cer should coordinate 

response resource needs for NRDA activities with 

the OSC during oil and hazmat responses.

The IMH also states that the Lead Administrative 

Trustee (LAT) is responsible for coordinating 

NRDA needs and activities of the trustee team. 

NRDA activities generally do not occur within 

the structure, processes, and control of the ICS. 

However, particularly in the early phases of a 

spill response, many NRDA activities overlap 

with the environmental assessment performed for 

the sake of spill response. Therefore, the trustees 

should remain coordinated with the spill response 

organization through the Liaison Offi cer. The 

trustees then may need to work directly with 

the unifi ed command , Planning Section, Operations Section, and, if working on the spill, the 

NOAA Scientifi c Support Coordinator to resolve 

any problems or address areas of overlap. This 

includes close coordination with the Liaison Offi -

cer for obtaining timely information on the spill 

and injuries to natural resources. The trustees 

should seek the OSC’s cooperation in acquiring 

response-related samples or results of sample 

analyses applicable to NRDA. Furthermore, they 

should obtain necessary safety clearances for 

access to sampling sites. It is worth noting that 

often NOAA’s SSC and not the Liaison Offi cer 

becomes the conduit between the trustees and 

the OSC. This often occurs because the SSC has 

more knowledge of the NRDA process than most 

Liaison Offi cers.

CHAUVIN, La. – A shrimp boat captain sets his rig to pull in his catch after trawling on Robinson Canal during the third day of commercial fi shing 

season. Photo courtesy of U.S. Coast Guard 
78

3. Operations

3.11 FOSC Key Points 

Response and Restoration, Removal, and 

Damage Assessment

It is diffi cult to explain the differences and distinctions between oil spill response, performed under 

the FOSC’s supervision, and Natural Resource 

Damage Assessment (NRDA), performed separately under the oversight of natural resource 

trustees agencies. Particularly in large spills, the 

National Incident Commander or FOSC acts as a 

single spokesperson for government involvement 

with the response. While NRDA frequently begins 

before response activity stops, it may continue for 

years. The FOSC does not participate in NRDA, 

but this lack of participation is confusing to offi -

cials and the public. A process is needed to preidentify a lead spokesman for NRDA activities 

during major spills to work alongside the FOSC, 

to explain the full scope of activities.

Ineff ective Boom Deployment

In hindsight, extensive petroleum-based containment boom was deployed in unmanageable areas, 

and then retrieved and disposed of as waste. Tending such long expanses of containment boom along 

the vast Gulf of Mexico shorelines while subject 

to tide, current and sea conditions, was not possible. Environmentally sensitive areas (ESAs) 

where containment boom was appropriate were 

not shown in plans, tested, or identifi ed well. FWS 

noted that this resulted in oil getting to the wrong 

(protected) side of the boom and then being held 

there adjacent to the ESA. Explaining the nuances 

of entrainment and permeability of containment 

and defl ection booming proved diffi cult. Most of 

the booming was counter-productive, but became 

viewed as necessary as oil approached the shore 

from 50 miles at sea.
4. Safety

79

The aggressive safety program throughout 

the entire Deepwater Horizon response 

proved effective. Lightning strikes and 

other severe weather (in addition to heat) were also 

a problem Considering the size of the operation, 

the heat index, and the nature of the duties performed—from source control efforts, skimming, 

burning, dispersant application, beach cleanup, 

to decontamination of thousands of vessels—the 

injury rate was extraordinarily low. Safety was 

a focus of the entire response organization. All 

personnel associated with the response kept personnel safety as a daily focus and immediately 

addressed any lapses. For several weeks, there 

were thousands of vessels and hundreds of aircraft 

working to respond to the spill. Some of the activities were very hazardous, such as in situ burning. 

Yet the number of injuries was exceptionally low. 

Deepwater Horizon response safety exemplifi ed an 

all-hands-on-deck approach, with a genuine focus 

on the safety of its team members.

During the Deepwater Horizon response, the 

federal government and the Responsible Party 

(RP) took action to prevent injuries, illnesses, 

and exposure to hazardous substances among 

response personnel and the public. Additionally, 

actions were taken to ensure the safety of seafood 

from areas of the Gulf of Mexico affected by the 

oil spill, to monitor the potential health impacts 

of the oil spill in the short and long term, and 

to facilitate access to care to those impacted by 

the spill. To achieve these objectives, the Federal 

On-Scene Coordinator (FOSC) worked with the 

RP, U.S. Department of Health and Human Services (HHS), the U.S. Department of the Interior, 

U.S. Environmental Protection Agency (EPA), the 

National Oceanic and Atmospheric Administration (NOAA), Centers for Disease Control and 

Prevention’s National Institute for Occupational 

Safety and Health (NIOSH), and multiple state 

level health and safety agencies.

4.1 Public Health and Safety

Under the National Contingency Plan, in those 

instances where a possible public health emergency exists, the FOSC and RP may notify HHS. 

Throughout response actions, the FOSC may call 

upon an HHS representative for assistance in 

determining public health threats and call upon 

OSHA and HHS for assistance on worker health 

and safety issues.

From the time of the announcement of the Deepwater Horizon explosion and fi re, HHS Assistant Secretary for Preparedness and Response’s 

Regional Emergency Coordinators in Region VI 

(which includes Louisiana and Texas) and Region 

IV (which includes the rest of the Gulf States) 

were in close communication with the ICPs. HHS 

Liaison Offi cers were deployed to the UAC, to the 

ICPs in Houma, La., 

and Mobile, Ala., and 

to the National Incident 

Command in Washington, D.C.

Due to the concern 

about public exposure, 

the RP and EPA under 

the UAC began and 

continued an air-monitoring program onshore to determine any 

hazardous exposures. 

The air-monitoring program had several facets. 

There were stationary air-monitoring locations. EPA 

used its Trace Atmospheric Gas Analyzer bus and 

Airborne Spectral Photometric Environmental Collection Technology aircraft to monitor air quality 

levels. The air monitoring did not indicate harmful 

exposure levels.

Incident Commanders worked with experts in the 

fi eld to present information to the public about 

their safety concerns. Information about air quality 

testing, dispersant use, seafood safety, and cleanup 

efforts was disseminated in a wide variety of ways, 

including interviews with the press, meetings 

with local offi cials, and expo type meetings with 

affected communities to disseminate information 

on efforts to ensure public health.

Although not covered in the National Contingency 

Plan, the combined effects of the spill on a population that had only fi ve years earlier endured 

Hurricane Katrina raised concerns about impacts 

on the mental health of the people living near oilimpacted areas. The National Incident Commander 

worked with state and federal agencies and the RP 

to fund and establish mental health centers.

The process of fi sheries closures and their subsequent reopening was largely driven by concerns 

over public health.

GRAND ISLE, La. – 

An Environmental 

Protection Agency 

contractor makes 

notations in log book 

as an air sampling 

instrument is replaced 

after a 24-hour cycle. 

Photo courtesy of EPA 
80

4. Safety

Fisheries Closures

The NOAA Fisheries Service prohibited fi shing 

in certain federally controlled areas of the Gulf of 

Mexico as part of the Deepwater Horizon response 

effort. This was a precautionary measure taken 

in early May 2010 to 

ensure public health 

and assure consumer 

confi dence in Gulf seafood. NOAA updated the 

closed areas often.

The area closures prohibited commercial 

and recreational fishing, including catch 

and release; however, transit through the area 

was allowed. To give ample time to comply 

with changes, National Marine Fisheries Service 

announced daily changes at noon, Eastern Time; 

closures became effective at 6 p.m. that day.

NOAA’s Fisheries Service closed areas in anticipation of oil impacts based on trajectory forecast analyses produced by the NOAA Offi ce of 

Response and Restora tion. NOAA has the legislative authority to close and open federal waters 

for seafood harvesting, while the states have the 

authority to close and open waters under their 

jurisdiction. The models projected oil movement 

over 24, 48, and 72 hour periods. Weather, satellite imagery, ocean buoy data, and ocean currents 

informed the computer models, and over-fl ights 

verifi ed the model trajectory and confi rmed the 

actual extent of the oil

The fi rst closure in early May covered about three 

percent, or 6,817 square miles, of Gulf federal 

fi sheries waters. As oil continued to spill from 

the wellhead, the fi sheries closure area grew in 

size. The peak of area 

closure occurred on June 

2, 2010, with 37 percent, 

or 88,522 square miles, 

of Gulf waters closed for 

fi shing. Altogether there 

were 33 closures in the 

Gulf of Mexico federal 

fi sheries waters.

NOAA announced the 

fi rst reopening of 26,388 

square miles of federal 

waters on July 22, 2010. There were 23 modifi cations to the closed area prior to the fi rst reopening. 

There have been 12 reopenings in total, with the 

most recent occurring on Feb 2 2011. An area covering 1,041 square miles immediately surrounding 

the Deepwater Horizon wellhead remains closed to 

all commercial and recreational fi shing. [Update: 

As of April 19, 2011 there have been 13 reopenings. All of the Federal waters closed to fi shing 

due to the Deepwater Horizon oil spill have been 

reopened.]

Seafood Safety Sampling

There are two ways oil can be determined to cause 

seafood to be unfi t for consumption. The fi rst is 

through the presence of certain levels of chemicals known as Polycyclic Aromatic Hydrocarbons 

(PAHs), some of which are carcinogenic. Oil is 

composed of many chemicals, but the PAHs are 

of the greatest concern. These can be harmful if 

consumed in suffi cient amounts over a prolonged 

period of time. The second way is if seafood smells 

of a petroleum product (taint). The law considers 

a product tainted with petroleum to be adulterated, and its sale as food prohibited. Petroleum 

taint itself is not necessarily harmful, and may be 

present even when PAHs are below harmful levels.

NOAA developed sampling analyses to test for 

taint and PAHs through sensory and chemical 

testing. During the response to the spill, a test for 

the dispersant Corexit was also developed. Certain water areas were already reopened prior to 

its development; therefore analysis of archived 

samples for those reopened areas was performed. 

After the dispersant test was developed, both this 

test and the Polycyclic Aromatic Hydrocarbon 

(PAH) chemical test analyzed all samples for 

reopening areas.

ST. PETERSBURG, 

Fla. – Biologists sort 

through and identify 

baseline samples at 

the Florida Fish and 

Wildlife Conservation 

Commission’s Fish and 

Wildlife Research Institute 

in St. Petersburg, Fla. 

Photo courtesy of U.S. 

Coast Guard 

SHELL ISLAND BAY 

COUNTY, Fla. – Coast 

Guard Rear Admiral Paul 

Zukunft looks at shrimp 

while checking them for 

signs of oil aboard a 41-

foot shrimp boat. Photo 

courtesy of U.S. Coast 

Guard 

PASCAGOULA, Miss. – Steven Wilson, the chief quality offi cer for 

NOAA’s Seafood Inspection Program, demonstrates sensory analysis 

of a sample of shrimp at NOAA’s National Seafood Inspection 

Laboratory in Pascagoula, Miss. Photo courtesy of NOAA. 
4. Safety

81

Sampling for seafood safety began April 28, 2010. 

The initial survey design used a selection of random stations in pre-oil spill near-shore waters 

along the Alabama, Florida, Louisiana, and Mississippi coasts. In early May 2010, a more formal 

survey design was developed and implemented 

due to the increased size of the closed fi shing area. 

The closed area was separated into grids, extending 

out from the state-federal boundary (three miles 

offshore in Alabama, Louisiana, and Mississippi, 

and nine miles offshore on the western Florida 

coast). Grids stretched to the outer boundary of 

the closed area.

Figure 4.1 illustrates these grids, relative to the 

July 22, 2010, closure boundary. 

Figure 4.2 displays the breakdown of the closed 

area into four separate broad zones. Each zone is 

based on the extent of cumulative oil inundation 

from the initial leaking of the Deepwater Horizon well. The zones helped determine the level 

of sampling in each grid, based on the amount of 

oil inundation within each.

Figure 4.2 describes these zones as areas A, B, C, 

and D. Area A included the closed fi shing area off 

the western Florida shelf. It experienced minimal 

to no oil inundation. Area B included the closed 

fi shing area south of the Macondo wellhead to 

Area A. It experienced moderate oil inundation. 

Area C included the state-federal boundary to the 

Deepwater Horizon wellhead, which experienced 

heavy oil inundation. An additional area, Area D, 

encompassed the perimeter of the closed area to 

ensure the closed fi shing area was effective.

Figure 4.1: 

Sampling design of 

the closed fi shing area 

based on 30 nautical 

miles by 30 nautical 

miles grids

Figure 4.2: 

Map of cumulative oil 

inundation from the 

Deepwater Horizon

wellhead
82

4. Safety

Cumulative oil inundation data from the initial 

leaking Deepwater Horizon wellhead determined the intensity of sampling within each grid. 

Grids exhibiting heavy cumulative oil inundation 

received more sampling. NOAA measured the 

intensity of sampling as the minimum number of 

stations successfully sampled per grid. This then 

related to the target sample size. Oil inundation 

dictated the number of successful sampling stations. With the exception of pelagic longline sampling, random selection of the vessels determined 

the stations.

Four classifi cations of sampling occurred throughout the response, including: 

1. Surveillance sampling: perimeter, closed area, 

or reopened area, 

2. Reopening sampling, 

3. Enforcement sampling, and 

4. Dockside sampling. 

On April 28, 2010, NOAA initiated perimeter surveillance sampling to attain the maximum extent 

of the closed fi shing area. The perimeter surveillance samples provided a baseline of pre-oil conditions for comparison of specimens analyzed for 

chemical analysis. The closed area surveillance 

sampling encompassed specimen collection within 

the closed areas. These samples underwent both 

sensory and chemical analysis, and the area was 

monitored prior to reopening. Reopened area 

surveillance sampling took place one week after 

reopening, and continued through two seven-day 

sampling periods, separated in time by at least a 

week. These samples also underwent sensory and 

chemical analysis for both PAHs and dispersant, 

and assured the continued safety of seafood from 

these areas. As of February 2011, this type of sampling was ongoing, and would continue through 

the end of May 2011.

To conduct reopening sampling, response personnel collected specimens within each grid in the 

closed area to test for PAHs and dispersants and 

to conduct sensory analyses. These samples provided the foundation for the reopening of closed 

grids. All specimens collected within the closed 

fi shing area had to pass both sensory and chemical analysis before an area could be reopened. If 

any sample failed the sensory analysis then the 

area failed. If a sample passed the sensory analysis 

but then failed the subsequent chemical analysis, the area would also fail and could not reopen. 

NOAA later resampled and retested failed areas. 

Law enforcement offi cials sometimes seized catch 

from illegal fi shing within the closed area. These 

specimens were transported by proper chain of 

custody to the National Marine Fisheries Service 

(NMFS) National Seafood Inspection Laboratory for analysis and further investigation. Major 

ports in Alabama, Florida, Louisiana, and Mississippi implemented dockside sampling. Southeast 

Fisheries Science Center (SEFSC) port samplers 

acquired these samples and transported them by 

chain of custody to the National Seafood Inspection Laboratory for processing and analysis. These 

samples helped to minimize the risk of tainted 

seafood reaching the market.

NOAA developed a list of key species based on 

importance to commercial and recreational fi shing, prevalence, and ecosystem function. Sampling 

collection targeted these species; however, species collected varied by area depending on habitat 

type, depth, and other factors. Near-shore waters 

were sampled for both fi nfi sh and shrimp specimens. Sampling in waters greater than 600 feet 

deep focused on pelagic species, such as tunas, 

mackerels, and royal red shrimp. Hard-bottom sampling areas focused on species such as snapper and 

GULF OF MEXICO – NOAA 

administrator Dr. Jane 

Lubchenco joins NOAA 

fi sheries researchers to 

conduct a trawl survey of the 

coast of Pascagoula, Miss., 

to obtain samples of fi sh and 

invertebrates for biological 

testing at the NOAAFDA Seafood Inspection 

Laboratory. Photo courtesy 

of NOAA.
4. Safety

83

grouper. Species such as sardines and anchovy are 

included in the list of specimens to represent prey 

trophic levels. Sampling of near-shore areas, which 

included waters less than 600 feet deep, included 

trawl, bandit, vertical longline, bottom longline, 

or a combination of these fi shing gears. Even with 

only one or two stations chosen for pelagic longline 

sampling, one set of longline gear could almost 

completely sample a grid of 30 nautical miles by 

30 nautical miles. Trolling hook and line sampling 

supplemented sampling in many areas, as it is the 

main type of recreational fi shing gear. NOAA 

standardized the sampling gear and gear used on 

fi shery independent surveys to be consistent with 

commercial and recreational fi shing.

Several types of vessels conducted sampling, 

including NOAA ships, SEFSC small vessels, 

commercial trawlers, commercial bottom longline 

vessels, commercial pelagic longline vessels, and 

for-hire vessels. SEFSC identifi ed and provided 

sampling stations and standard sampling protocols 

to all vessels. All sampling vessels carried one or 

more scientifi c staff responsible to ensure the chain 

of custody of all specimens, as well as to measure 

and weighing the catch.

NOAA, FDA and States’ Reopening Protocol

In order to ensure consumer safety and market 

credibility, there needed to be an agreed-to protocol executed by the federal agencies and states 

to reopen areas to fi shing. After the closures were 

instituted, NOAA, U.S. Food and Drug Administration (FDA), and EPA, in conjunction with the 

state health and fi sheries commissioners, developed procedures for reopening sampling and testing areas. FDA oversaw the state reopening process 

while NOAA, in conjunction with FDA, handled 

federal waters. An important element in keeping 

seafood safe during the response was ensuring its 

harvest from areas that did not present a chemical 

or biological hazard. The reopening process started 

once an area was oil free for 72 hours.

Computer modeling projections and daily overfl ights provided the basis for area closure decisions 

and subsequent closure expansions. If confi rmed 

through water quality sampling, aerial surveillance, or satellite imagery that a harvest area had 

never been exposed to oil, it was reopened without 

fi rst testing seafood samples.

The second, more common type of reopening was 

that of areas previously exposed to oil. The fi rst 

criterion for this type of reopening was that the 

water was free of oil. Free of oil does not include 

free from a sheen resulting from light oil. The 

presence of light oil as sheen was, and is, a regular 

occurrence in the Gulf of Mexico. Once the oil 

had dissipated, NOAA would send a sampling 

plan to the FDA for approval. These plans outlined 

the sampling of areas designated for reopening. 

After the FDA accepted the sampling plan, NOAA 

began sample analysis. For a closed area to reopen, 

samples taken from the area had to pass both sensory examination and chemical analysis. The FDA 

and the Offi ce of Management and Budget then 

reviewed and accepted a reopening package for 

the closed area.

For sensory analysis, a seafood sample consisted 

of the edible portion of the species being tested. A 

panel consisting of seven expert sensory assessors 

evaluated each sample in both a raw and cooked 

state. Consideration for reopening from a sensory 

standpoint required that a minimum of 70 percent of the expert assessors found no detectable 

petroleum or dispersant odor or fl avor from each 

sample. If any sample failed, that collection site 

remained closed. If all samples from a collection 

site passed the sensory criteria, additional samples 

underwent chemical analysis to determine if harmful levels of PAHs were present, and if the levels 

of PAHs in the seafood samples did not pose a 

PASCAGOULA, Miss. – 

NOAA’s leader for the 

Deepwater Horizon

oil spill seafood safety 

testing program is 

interviewed at the NOAA 

Fisheries Mississippi lab in 

Pascagoula, Miss. Photo 

courtesy of NOAA
84

4. Safety

health concern, the site was eligible for reopening. 

All contiguous sites had to pass both sensory and 

chemical testing for an area to reopen.

Seafood Safety and Sampling Protocols

The overall sampling protocols implemented were 

consistent with protocols used by the SEFSC to 

conduct fi shery-independent surveys under the 

Southeast Area Monitoring and Assessment Program. Each type of sampling conducted underwent 

specifi c protocols for seafood safety sampling.

Any time samplers encountered oil in a grid, protocol required notation of the characteristics and 

extent of oiling. Oil encountered before a sampling 

operation began canceled sampling at that station; 

the vessel would move to another station within 

the grid. The Pascagoula lab received and further 

evaluated reports of oil. If the oiling was more 

than a transient sheen, then sampling in the grid terminated and 

the grid was not included in an 

area considered for reopening.

Observers received station locations to guide the vessel captains 

to randomly selected stations 

within assigned grids. NOAA 

provided a list containing all 

species required for collection 

for seafood safety analyses. 

Each day the observer or biologist provided a daily update to 

include the sampling location, 

the grid fi shed, and the type and 

number of fi sh caught. All specimens maintained market quality through commercial methods 

of ice packing. Sampling trips 

were typically three to four days 

in length to ensure specimens 

were in market quality condition. 

Market quality condition meant 

fish were suitable for human 

consumption.

NOAA followed specifi c preservation protocols for sensory analysis. These protocols 

required thorough wrapping of 

fi sh and invertebrates in foil, dull side to the specimen. Spines could not protrude through the foil, 

and each sample required an interior tag. After foiling, specimens were placed in plastic bags labeled 

with the vessel-cruise-station code. Chemical analyses also followed preservation protocols. Gallon bags with inside and outside labels stored the 

requested quantities of small fi sh or invertebrates, 

one species per bag. Larger fi sh were wrapped in 

foil. Alternatively, if the fi sh were very large, they 

were iced and then sub-sampled at the National 

Seafood Inspection Laboratory (NSIL).

All data collected throughout the Deepwater Horizon oil spill followed standard chain of custody 

protocols. The Field Party Chief initially fi lled out 

the chain of custody form. Any time samples were 

transferred to a new person or a new location, the 

chain of custody form was signed by the person 

GRAND ISLE, La. – Contract workers set a net into the 

water that is designed to test sediment for oil and other 

pollutants in shrimping areas near Grand Isle, La. Photo 

courtesy of U.S. Coast Guard 
4. Safety

85

releasing the samples and the person receiving 

the samples. If sub-sampling was required, a subsample chain of custody form was completed and 

remained with each sub-sample.

Continued Post Reopening Monitoring of 

Seafood

NOAA will continue post-reopening surveillance 

sampling. The current Pollution Removal Funding Authorization allows for seafood sampling of 

reopened areas within the federally closed area 

boundaries of the Gulf of Mexico.

The FDA already operates a mandatory safety program for all fi sh and fi shery products. As part of the 

program, the FDA issued a letter reminding fi sh and 

fi shery product processors of FDA’s regulations 

and policy concerning the food safety hazard of 

environmental chemical contaminants. The letter 

emphasized the importance of verifying the fi sh 

they were processing had not come from closed 

waters. FDA increased its inspections of Gulf Coast 

seafood processors to ensure compliance with their 

regulations. FDA also implemented a risk-based 

surveillance-sampling program to target oysters, 

crabs, and shrimp; these species retain contaminants longer than fi nfi sh. Sampling activities by 

FDA were designed to complement the dockside 

monitoring of fi nfi sh already in place by NOAA.

NOAA’s continued presence in the Gulf is designed 

to ensure the public that Gulf seafood is safe to 

eat. Several of the Gulf States have also requested 

funding from the RP to perform enhanced seafood 

surveillance and marketing campaigns to restore the 

public’s confi dence in the safety of Gulf seafood.

4.2 Response Personnel Health and 

Safety

Oil spill workers faced many risks and hazards 

during the response to the Deepwater Horizon oil 

spill. Depending on their jobs, these workers faced 

hazards from heat, falls, drowning, fatigue, loud 

noise, sharp objects, as well as bites from insects, 

snakes, and other wild species native to the Gulf 

Coast. Some workers were exposed to crude oil, 

oil constituents and byproducts, cleaning products, 

and other chemicals used in the cleanup process.

Indirect hazards faced by workers included food 

borne illness, food contamination, and human 

illnesses such as infl uenza and the common cold. 

Psychological and social threats to response workers included stress, anxiety, and tension caused by 

long deployments away from home and normal 

work, and the long hours.

Figure 4.3 on the next page outlines the number 

of injuries and illnesses documented by the UAC. 

The information is broken down by the number 

of reports, dates throughout the response period, 

and average work-hours recorded.

Heat and Safety

Heat stress caused the majority of worker casualties (less than 5 percent of deployed personnel) 

while non-heat related injuries resulted in the 

minority of casualties reported (less than one percent of deployed personnel). At the height of the 

summer, responders who wore protective clothing 

while working on the beach could only work ten 

minutes at a time and then had to rest for up to 

forty minutes in order to avoid heat related injuries. 

The Coast Guard required rest and rehydration 

periods in an effort to prevent these injuries. This 

gave the impression to those outside the response 

NEW ORLEANS – Cleanup 

crews don personal 

protective equipment 

before removing oil from 

marshes aff ected by the 

Deepwater Horizon oil 

spill near Venice, La. 

Photo courtesy of U.S. 

Coast Guard
86

4. Safety

and unfamiliar with the reasons for the rest and 

rehydration periods that the responders were not 

working diligently. Despite the negative publicity 

associated with enforced heat-related breaks, the 

FOSC refused to compromise on safety practices. 

They did, however, respond to concerns about 

the speed of cleanup actions. As it was too hot to 

work for extended periods during the day, under 

direction from the FOSC, large numbers of beach 

cleanup crews shifted to night work shifts, when 

heat was less of a problem. This carried its own set 

of challenges—it required infrastructure such as 

lighting, increased some safety hazards due to lack 

of light, and changed the nature of wildlife risks.

Safety Organization

Under the National Contingency Plan, worker 

health and safety are paramount concerns and 

the FOSC and RP are responsible for addressing 

these issues. Additionally, all response actions 

must comply with OSHA training and safety 

requirements.

Under the FOSC, safety and environmental health 

professionals ensured that the RP and the entire 

response organization properly addressed the 

safety of all responders. Coast Guard safety and 

environmental health staff served as a conduit 

between the RP, and the safety and health staff 

of other federal, state, and local agencies. Coast 

VENICE, La. – A U.S. Coast Guard safety observer measures 

the heat index on a pocket weather tracker to determine 

if it is safe to work in the severe heat along the Mississippi 

River Delta. Photo courtesy of U.S. Coast Guard 

Figure 4.3: Incident Data – Response-to-Date
4. Safety

87

VENICE, La. – A U.S. Coast 

Guard chief petty offi cer, 

assigned as a safety observer, 

inspects an anchored 

shrimping vessel near Venice, 

La. Photo courtesy of U.S. 

Coast Guard 

Guard safety and environmental staff fi lled UAC 

staff positions, Incident Command Post (ICP) staff 

positions, and deployed to fi eld operations.

In the Incident Command System (ICS), the Safety 

Offi cer works as a support offi cer for the Incident Commander (in this instance, the FOSC). The 

Safety Offi cer’s function is to develop and recommend measures for assuring personnel safety, and 

to monitor, and anticipate hazardous and unsafe 

situations. The Safety Offi cer’s major responsibilities were to identify hazardous situations associated with the incident, review and approve the 

Medical Plan, and develop the Site Safety Plan.

The RP hired safety and industrial health staff to 

support the needs of response workers, including 

Coast Guard responders. Experts in the fi elds of 

toxicology, public safety, drinking water quality, 

and environmental health were hired. RP industrial hygiene and safety personnel deployed to 

worksites to conduct site assessments including 

physical, chemical, and biological threats, and to 

act as safety fi eld observers.

The UAC employed other government agencies 

such as OSHA to monitor the health and safety 

hazards facing workers involved in the oil spill 

response. OSHA personnel were deployed to the 

Gulf the week of April 26, 2010, and deployed 

to 17 locations in Alabama, Florida, Louisiana, 

and Mississippi, and served as a critical component of the ICPs in Houma and Mobile. In coordination with the Coast Guard, OSHA staff also 

boarded near-shore vessels engaged in booming 

and skimming operations. Additionally OSHA 

staff observed offshore in situ burning operations 

and were stationed on offshore vessels for longer 

periods.

Monitoring Chemical Exposures

The potential health effects from inhaling chemicals such as oil, weathered oil, oil dispersants, 

cleaning agents, and other substances were an 

ongoing concern. Health and safety personnel continued monitoring chemical levels while assessing 

all materials and characterizing their health effects. 

Aside from workers on ships directly adjacent to 

the spill source who were exposed to fresh oil, 

most of the cleanup workers were exposed to 

weathered oil, where the more toxic volatile substances had evaporated.

To ensure that workers were not exposed to dangerous levels of toxic chemicals, real-time air 

monitoring, area air sampling, grab sampling, 

and personal air monitoring were conducted primarily with organic vapor monitoring badges 
88

4. Safety

and real-time air monitors, such as multi-gas and 

photo-ionization detectors. Professional safety and 

health personnel from both independent contractors and the RP reviewed all data.

Agencies involved in the response cooperated to 

reach practical solutions to safety concerns. For vessels working offshore in the proximity of dispersant 

application, safety staff characterized the area and 

the ambient air of workers closest to the dispersant operations. Through air and water monitoring, 

safety personnel determined the area was clear for 

workers to continue operations without respirators. Safety associated with the Volatile Organic 

Compounds (VOCs) at the surface in vicinity of the 

well as addressed by sub-sea and surface dispersant 

applications, as discussed in Chapter 3.

At the outset of the response, signifi cant attention 

was paid to potential respiratory hazards such as 

benzene, posed by the evaporation of the hydrocarbons on the surface of the water, and potential toxins 

released by the burning of natural gas and surface oil 

at the well site. From the beginning of the response, 

the RP utilized site safety plans for operations. As 

part of site safety plans, workers at the spill source 

used respiratory protection equipment. By May 7, 

2010, the UAC released the Mississippi Canyon 252

Offshore Air Monitoring Plan for Source Control 

and Skimming Operations, a detailed plan that outlined required monitoring equipment, frequency of 

measurements, and exposure limits for all response 

personnel. From the commencement of response 

operations, industrial hygienists and safety professionals were embedded with response personnel to 

ensure proper measurements and monitoring were 

being conducted. At no point during the skimming 

operations did gas readings exceed the Permissible 

Lower Exposure Limits for any of the identifi ed 

toxins. Nevertheless, the vapor coming from the top 

of the portable tanks, combined with the extreme 

heat, accelerated the fatigue of personnel during 

pumping and offl oading operations. On several 

occasions, personnel on top of the tanks had to be 

rotated early or moved to a cooling area because of 

the combined effects of the heat and fumes.

The principal hazards at work sites were slips, 

trips, falls, heat stress, sun exposure, fatigue, and 

motor vehicle accidents. Dermal exposure to the 

oil products and other chemicals also posed a threat 

throughout the spill recovery operation. Even minimal exposure to the oil products could result in an 

uncomfortable skin rash. The only way to prevent 

dermal exposure was through the consistent wearing of personal protective equipment (PPE) suited 

to the operations being conducted.

Safety personnel documented specifi c personal 

exposures in the post-deployment Deepwater 

Horizon Health-Related Inventory and Reporting 

Tool. This input was compiled and documented in 

Industrial Hygiene reports. Mishaps were captured 

by supervisors and reported to respective ICPs for 

investigation and documentation.

Protecting Workers from Exposures

Safety staff monitored worker safety and health 

protections, including providing required PPE, for 

all workers involved in the cleanup.

One of the responsibilities of Safety and Environmental Health personnel is to determine which type 

of PPE is needed, who has to wear it, and what 

GULF OF MEXICO – 

A contractor monitors 

the air quality at the 

Deepwater Horizon site 

to ensure safety of the 

workers. Photo courtesy of 

U.S. Coast Guard 

GRAND GOSIER ISLANDS, La. – An Environmental Protection Agency 

contractor conducts surface water sampling near Grand Gosier 

Islands, La. Photo courtesy of EPA 
4. Safety

89

training and medical qualifi cations are required 

to use the PPE. Safety and Environmental Health 

personnel must also ensure that PPE requirements 

are known and understood by workers, the correct 

number, sizes, and types of PPE are ordered, and 

the PPE is staged in areas where the workers can 

access it.

Early in response efforts, the RP ordered PPE and 

established numerous staging areas to deliver the 

material to the fi eld in a timely manner. Safety plans 

were drafted and included descriptions of what PPE 

personnel should wear when conducting specifi c 

operations. Personnel were instructed to pick up 

their PPE at the Staging Areas, and to inform their 

supervisors if the PPE they needed was not available. A majority of the PPE used was procured and 

staged by the RP. All responders accessed the PPE 

at the Staging Areas close to fi eld operations.

Aviation Safety

One of the most high-risk operations of the Deepwater Horizon response was air traffi c over the 

vicinity of the spill. There were a number of aviation safety issues that necessitated the FOSC’s 

attention and closer coordination of aviation safety 

and operations.

The Federal Aviation Administration (FAA) could 

provide a fl ight restriction, but no air traffi c radar 

was available offshore that could guarantee the 

effi cacy of a fl ight restriction. The FOSC was able 

to secure the services of the Customs and Border 

Protection Air Intercept Radar aircraft to provide 

the air traffi c control radar. The Air Force provided skilled controllers. Eventually, the size of the 

operation grew so large that centralized airspace 

management operations and airspace confl iction 

prevention services were consolidated to the 601st 

Air and Space Operations Center located at Tyndall 

Air Force Base in Panama City, Fla.

Aviation operations utilized numerous air assets 

from the Coast Guard, as well as federal, state, and 

local agencies, and private companies to support 

Deepwater Horizon response operations. To support the Deepwater Horizon response, the Coast 

Guard employed Coast Guard Air Station Flight 

Safety Offi cers, who were well versed in the safety 

needs of pilots and air crews. Flight surgeons were 

employed to ensure fl ight crews and pilots were 

medically qualifi ed to fl y. Pilots deployed from 

their home units to assist with the response. Aviation safety and operations are discussed in further 

depth in Chapter 6 of this report, Logistics.

PORT FOURCHON, La. – 

Workers contracted by BP, 

and under the direction 

of the U.S. Coast Guard, 

don personal protective 

gear before deploying to 

the beach to clean up oil. 

Photo courtesy of U.S. 

Coast Guard 
90

4. Safety

Coast Guard Cutter Safety

Coast Guard Sea Going Buoy Tenders were 

assigned to the oil spill to provide skimming 

resources using pre-established Spilled Oil Recovery Systems (SORS) and Vessel of Opportunity 

Skimming Systems (VOSS).

Crewmembers were provided just-in-time training 

in Emergency Response, First Responder Operations Level prior to deployment in the fi eld. In 

addition to training, safety personnel ensured 

crewmembers were outfi tted with PPE, which 

included hand-held real time multi-gas meters to 

evaluate the air for volatile organic compounds. 

When operations occurred, crews named a specifi c 

person as the safety observer on deck. Additionally, Coast Guard Safety personnel at ICP Houma 

worked with the RP to develop an air-monitoring 

plan for the cutters.

Temperatures on deck often reached 100 degrees 

Fahrenheit or higher. Tyvek suits were effective 

at preventing dermal exposure to oil, but they 

accelerated heat stress and fatigue. In addition to 

constant hydration and plenty of sunscreen, other 

solutions had to be found to reduce the effects 

of heat stress. Perspiration wicking clothing was 

ordered for personnel to wear under the Tyvek. In 

addition, water fans were set up under canopies on 

the buoy deck to provide a cool zone. Canopies 

were placed in various spots on the buoy deck, 

forecastle, and on the fl ying bridge to mitigate sun 

exposure.

Personnel working on deck were 

generally limited 

to one to two hours 

of work before a 

recovery period was 

required due to heat 

and fatigue. Guidance was provided 

for heat exposure 

limits, including the 

use of a log system 

to monitor times 

and ambient temperatures. Although 

it was possible to 

skim and pump oil 

from sunrise to sunset, the cumulative 

effects of the pace 

of operations were 

felt within a matter of days. Taking advantage of 

days when oil was not found or the weather was 

not conducive to skimming was critical to allowing 

the crew to rest and properly hydrate.

FOSC Key Points: Safety

The agencies charged with oversight of both worker 

and public safety, and those in command positions, 

from the federal and state governments, as well 

as the RP, made safety a priority. Considering the 

size of the response, the amount of oil released, the 

geographic scope of the area where response operations took place, and the time of year, the safety 

record of the entire response operation refl ected an 

effective and persistent safety program. The efforts 

and commitment to ensure the safety of those who 

worked on the spill, and that of the public, is one 

of the single most notable accomplishments of the 

Deepwater Horizon response. 

Given the immense geographic scope, maritime 

operations from the well site to 50 miles offshore 

skimming, to near-shore, aviation operations and 

land based cleanup, decontamination, and waste 

management—and the vast mixture of people 

thrown together ad hoc—the Deepwater Horizon 

response produced an exceptional safety record.

GULF OF MEXICO – 

A Coast Guard petty 

offi cer grabs hold of a 

shipmate to help him 

from slipping on the 

oil covered deck of 

the U.S. Coast Guard 

Cutter Harry Claiborne. 

The crew is preparing 

to remove a Vessel of 

Opportunity Skimming 

System following 

collection of oil from the 

Gulf. Photo courtesy of 

U.S. Coast Guard

GULF OF MEXICO – A Coast Guard seaman 

is covered in oil after bringing a Vessel of 

Opportunity Skimming System on board the 

U.S. Coast Guard Cutter Harry Claiborne. 

Photo courtesy of U.S. Coast Guard
5. Planning

91

During the Deepwater Horizon response, 

the Unifi ed Area Command (UAC) and 

the Incident Command Posts (ICPs) established robust Planning Sections in accordance with 

Incident Command System (ICS) doctrine. Each 

Planning Section collected, evaluated, and disseminated information about the situation, including 

developments during the incident and the status 

of resources. The UAC used this information to 

understand the current situation, predict the probable course of incident events, and prepare alternative strategies for the incident.

The UAC Planning Section prepared the Area Command Operating Guide to provide the ICPs with 

direction from the Federal On-Scene Coordinator 

(FOSC) and Area Command regarding response 

priorities and objectives. Using this guidance, the 

ICP Planning Sections prepared Incident Action 

Plans (IAP) for each operational period. The IAP 

contained objectives refl ecting the overall incident 

strategy and specifi c tactical actions for the next 

operational period of the incident. IAPs ensured 

the command staff and responders worked in concert toward the same goals set for that operational 

period. They did this by providing all incident supervisory personnel with specifi c tactical direction for 

actions regarding the operational period identifi ed 

in the plan. Additionally, IAPs supplied a coherent 

means of communicating the overall incident objectives for both operational and support activities.

Each Planning Section had access to established 

oil spill response contingency plans, such as Area 

Contingency Plans (ACP) and the One Gulf Plan. 

Responders also used established all-hazard compatible Marine Transportation System (MTS) recovery plans, tailored for each operating area. The MTS 

recovery plans were originally created in response to 

the September 11, 2001, attacks but, like much planning doctrine in the past decade, they represented 

an all-hazards approach to port recovery.

Planning Sections also developed incident-specifi c 

plans. The National Oceanographic and Atmospheric Administration (NOAA) members of the 

UAC Planning Section supported the FOSC by 

mapping the extent of the spill and developing oil 

trajectory forecasts. Planners at the UAC and ICPs 

developed severe weather (hurricane) plans and 

considered the implications of concurrent activation of the National Contingency Plan and the Stafford Act in the event of severe weather.

Beyond planning for the next operational period, 

incident planners also engaged in long-term, strategic planning. Finally, Planning Section leaders 

ensured the preservation of incident information.

5.1 Existing Plans: Area Contingency 

Plans

Under the National Oil and Hazardous Substances 

Pollution Contingency Plan, or NCP, the Coast 

Guard is responsible for developing procedures to 

address oil discharges and releases of hazardous 

substances, pollutants, or contaminants. The Coast 

Guard also coordinates planning, preparedness, 

and response activities with other agencies. The 

Oil Pollution Act of 1990 (OPA 90) established 

a contingency planning continuum that included 

local, regional, and national level planning for 

oil spills. The NCP created the national policy 

for oil spill response, followed by Regional Contingency Plans that align with standard federal 

regions, while local contingency plans provide for 

detailed planning at the Coast Guard Sector level.

For the Gulf Coast area, ACPs provided some identifi cation and prioritization of sensitive areas where 

boom would be deployed in the event of an oil spill 

and in some cases identifi ed the quantity of boom 

needed for these areas. Strategies for deploying 

boom under a variety of conditions were generally 

not developed in anticipation of this incident. The 

surface use of dispersants and in situ burning was 

pre-approved in the ACPs, but sub-sea application 

of dispersants was not anticipated in ACPs or part 

of the dispersant pre-approval.

ST. PETERSBURG, 

Fla. – A Coast Guard 

Deputy Incident 

Commander for the 

Deepwater Horizon 

oil spill response in St. 

Petersburg, addresses 

members of the public 

during a Hernando 

County Port Authority 

meeting in Hernando 

Beach, Fla. Photo 

courtesy of U.S. Coast 

Guard
92

5. Planning

In July 2009, Texas General Land Offi ce offered 

to assist all Gulf Coast FOSCs by developing a 

single compact disc (CD) that held Gulf-specifi c 

response guidance. The information contained on 

the CD became known as the One Gulf Plan. The 

One Gulf Plan was not a regional contingency 

plan—rather, it was a collection of ACPs. The 

One Gulf Plan detailed information about state 

organization structures and pre-approved zones 

for dispersant use, and contained checklists for use 

during an oil spill response. The One Gulf Plan 

CD linked Geographic Response Plans (GRPs), 

which were considered ACPs for each FOSC area 

of responsibility (AOR).

At the onset of the Deepwater Horizon response, 

Operations and Planning Sections personnel 

accessed the local sections of the ACPs, including 

the One Gulf Plan and Geographic Response Plans, 

for their assigned areas. In some cases, marshes, 

barrier islands, and land masses had eroded, 

moved, or geographically shifted to regions where 

endangered nesting or sturgeon transit areas were 

located. Often, up-to-date depictions of these land 

masses were no longer available. Planners, particularly for the Louisiana ACPs, therefore relied 

on input from local fi sh and game personnel and 

fi shermen who daily surveyed impacted areas to 

identify the actual resources at risk. This situation 

created a high demand for critical resources 

because the contingency plan required booming 

of Tier 1 areas (high priority protection locations), 

even though some high priority areas had shifted. 

This required adjudication as to which areas should 

be deemed high priority.

Due in part to geography, the ACP for the Sector 

Mobile AOR was prone to the same challenges as 

the Louisiana plans. It became the primary playbook 

guiding response actions in the ICP Mobile AOR, 

which was the same as the Sector Mobile AOR. 

The Sector Mobile ACP was effective, in that it 

was previously digitized for ease of reference and 

had a prioritized list of sensitive sites throughout 

the AOR. However, the plan did not detail booming 

strategies, response equipment requirements, and 

response protocols. A major complication was that 

none of the existing ACPs contemplated continuous 

coastal impacts from an uncontrolled well release 

offshore. The worst-case discharge scenarios presumed either the complete loss of product from a 

vessel or an on-shore facility.

The Sector Mobile ACP was a collaborative effort, 

developed with the consensus of the affected states 

and local communities; however, those who participated in its development were primarily those 

involved in pollution and emergency response. 

MOBILE, Ala. – 

Government and private 

sector assets come 

together at the Mobile 

Incident Command Post 

to plan and coordinate oil 

recovery eff orts from the 

Deepwater Horizon oil 

spill in the Gulf of Mexico. 

Photo courtesy of U.S. 

Navy 
5. Planning

93

The ACP did not have prior visibility with state or 

local elected leaders. Faced with a spill of this size 

these offi cials required re-examination of the plan 

and ICP Mobile negotiated the ACP 2.0 strategies 

with the states as the response evolved.

In addition to needing to rework the ACPs due to 

concerns regarding their delineation of sensitive 

areas and booming strategies, activating every contingency plan on the Gulf Coast at once created 

instant competition for limited resources, and set 

in motion many political challenges. Nevertheless, 

the UAC tried for weeks to execute that strategy. A 

UAC team produced a Unifi ed Command Contingency Plan (UCCP) that relied on the observed and 

projected behavior of the surface oil in combination with known stockpiles and delivery times of 

protection and removal resources for all near-shore 

and shoreline boundaries throughout the Gulf. The 

UAC was immediately able to execute this plan 

in Florida and Texas, states that had not yet fully 

activated their contingency plans. However, the plan 

was more diffi cult to implement in Alabama, Louisiana, and Mississippi. Nevertheless, elements of 

the plan such as the Critical Resources Unit (CRU), 

the large capacity staging sites, information sharing, 

and critical resource prioritization methodologies 

proved very helpful in meeting the concerns of the 

affected states and local communities.

In a sense, the UCCP was a regional plan for 

Louisiana negotiated in the midst of the response, 

and area plans were renegotiated at the ICPs 

and approved by UAC, area, and national commands. The UCCP addressed the decision not to 

designate sensitive areas in the existing ACPs; 

instead it designated all of the potentially impacted 

Louisiana shoreline as sensitive and called for 

shoreline protection measures in all those areas. 

ACP-Plus, or ACP 2.0 took the existing Sector 

Mobile ACPs and factored the size of the spill, 

economic impacts, social, and political concerns, 

and broadened the response strategies beyond 

environmental protection. ACP 2.0 included the 

booming of miles of sand beach and bays that were 

typically not boomed. These two revised plans 

placed a requirement on the Coast Guard CRU 

and the RP’s Procurement Supply Chain Management system to acquire fi ve million feet of boom 

from the worldwide market in order to provide the 

resources required to execute the modifi ed plans. 

This amount turned out to be signifi cantly less 

than what communities along the Gulf of Mexico 

expected. With the inexorable movement of oil 

toward the shore, state and local offi cials insisted 

that actions needed to be taken to protect shoreline, 

including both sensitive habitats and economically 

important shorelines. Offi cials wanted to use boom 

as a last line of defense for the shore, and cover as 

much of the shore as possible. Additionally, the 

need to demonstrate proactive efforts by placing 

boom became more important than the effectiveness of the boom itself as a tool in actually preventing oil from coming ashore. As a result, the 

limitations of boom as a response tool became 

secondary to the demand for any kind of barriers 

to stop the progress of the oil.

ACP 2.0 and the UCCP were constructed in an 

attempt to ensure the affected states would agree 

to a specifi c level of boom based on their input 

for booming strategies. In the normal boom strategy development process, amounts required are 

validated by actually fi eld testing the plans in the 

water during drills and other exercises. As plans 

were negotiated during the actual response, boom 

amounts and protection strategies could not be 

validated by responders before being deployed, 

resulting in operations receiving more boom than 

was needed. And thus not all boom was deployed. 

At the same time, unused boom was perceived by 

state and local offi cials as a wasted opportunity to 

protect shorelines, and was frequently judged as a 

sign of ineffi ciency in response operations.

GRAND ISLE, La. – Workers 

place absorbent boom 

around Mangrove Island 

which is a sensitive nesting 

area for Brown Pelicans. 

Photo courtesy of U.S. 

Coast Guard
94

5. Planning

5.2 Existing Plans: The Maritime 

Transportation System Recovery Plans

Marine Transportation System (MTS) recovery 

plans, tailored for port, have been promulgated by 

Coast Guard Sectors in consultation with stakeholders to address transportation disruptions. A 

Marine Transportation System Recovery Unit 

(MTSRU) is established for incidents in the Planning Section at each ICP that have the potential to 

signifi cantly disrupt the MTS.

The initial fi re and explosion aboard the Mobile 

Offshore Drilling Unit Deepwater Horizon, 42 

miles from Venice, La., had localized effects and 

no impacts to the MTS. However, the subsequent 

discharge of crude oil from the Macondo well created the potential for geographically widespread 

disruptive effects on the MTS along the Gulf Coast 

and its associated cargo fl ow routes.

Although the threat was persistent throughout the 

incident, the MTS recovery effort was primarily precautionary, as no signifi cant disruptions of 

marine transportation occurred. It is key to note 

there was a signifi cant concern within the shipping industry about surface and subsurface oil (i.e., 

seawater intake issues), and a number of vessels 

self-rerouted to avoid spill areas. In one instance, 

one company issued a precautionary divert order 

to its whole fl eet of tankers. Through Coast Guard 

MTSRU informational intervention, the company 

decided not to divert its ships before a disruption 

occurred.

5.3 Organizational Structure

UAC MTSRU

UAC MTSRU functioned from April 27, 2010, to 

August 4, 2010. Once the scale of the oil spill and 

the potential threat to shipping became apparent, 

the Coast Guard implemented of the MTS recovery 

function at the fi eld level.

The UAC MTSRU published Commercial Protocols, which detailed how they communicated 

with industry and the UAC’s key strategic points: 

keeping all ports open throughout the incident, 

tracking the status of decontamination stations, and 

cleaning and decontamination activities. Additionally, the UAC maintained direct contact with the 

Louisiana Offshore Oil Port (LOOP) to coordinate 

information about the status of the LOOP, and with 

port authorities throughout the incident area.

Figure 5.1:

E-GIS E-GIS 

Representation 

of Command 

Assessment of 

Readiness and 

Training (CART) 

Event Data
5. Planning

95

ICP Houma MTSRU

An MTSRU established at ICP Houma for the 

Marine Safety Unit (MSU) Morgan City AOR 

functioned from April 27, 2010, until June 11, 2010.

The unit maintained situational awareness of ICP 

booming activity, response strategies, and efforts 

to minimize marine traffi c and disruptions. It 

also coordinated the Southwest Pass contingency 

anchorage in the event vessels were required to 

wait for decontamination.

ICP Houma directed the RP to set up a decontamination station for inbound and outbound vessels 

in Southwest Pass and the Boothville Anchorage 

areas of the Lower Mississippi River. This was 

accomplished in cooperation with the Bar Pilots. 

Very little contamination was observed on vessels 

entering the river, and vessels leaving the Mississippi River were not required to utilize the Southwest Pass decontamination station.

This decontamination station moved as necessary 

to stay out of the oil, and the Coast Guard published its location with Marine Safety Information 

Bulletins (MSIBs).

ICP Mobile MTSRU

The MTSRU at ICP Mobile functioned from April 

28, 2010, through December 27, 2010. During the 

fi rst two days of operation, the MTSRU established 

and participated in daily industry, government, 

and Coast Guard Eighth District conference calls 

to gain situational awareness and to seek a unifi ed MTSRU strategy across impacted zones. The 

MTSRU also updated the Common Assessment 

Reporting Tool event data fi le twice daily for the 

ICP Mobile AOR. Data entries included booming 

activities, waterway restrictions, and location of 

decontamination sites.

Within the fi rst 24 hours after activation, MTSRU 

Mobile was tasked to develop a plan of action 

to assess and decontaminate vessels transiting 

through oiled waters. Within 72 hours of activation, 

the MTSRU developed a Vessel Self-Assessment

procedure and reporting sheet, a facility impacts 

data sheet, an initial draft decontamination plan, 

and a third-party review process.

The MTSRU coordinated with the Sector Mobile 

vessel arrivals desk and commercial vessel operations, Pensacola Harbor Master, Mobile Harbor 

Master, and Pascagoula Harbor Master to ensure 

that transiting vessels submitted comprehensive 

data, and to provide a common vessel transit picture.

The Coast Guard sent information to local industry 

on a daily basis by email. The emails provided the 

latest NOAA spill trajectories, the most recent vessel and facility reporting sheets, the latest Marine 

Safety Information Bulletin (MSIB), and the vessel 

decontamination processes. A contingency Vessel 

Traffi cking Management plan was also prepared, 

but was not required to be implemented.

National Level Support and Outreach

Coast Guard Headquarters and the Commander 

of the Atlantic Area monitored MTSRU recovery 

activities. On May 1, 2010, the NIC and Coast 

Guard Headquarters MTSRU prepared and disseminated an informational alert (via email) to 

Carrier and Trade Support Groups. These groups 

conducted a live test of the communications 

protocols and procedures and the Coast Guard’s 

Alert Warning System (AWS) on May 3, 2010. 

Stakeholders were apprised daily of MTS status 

and contingency arrangements for decontamination of shipping. Various organizations including 

Intertanko, World Chamber of Shipping (WCS) 

and BIMCO of the Carrier Support Group further 

distributed the executive summary information to 

their domestic and international members.

GULF OF MEXICO – 

Researchers monitor the 

eff ects of the Deepwater 

Horizon spill from NOAA 

aircraft overfl ying the 

impacted area . Photo 

courtesy of U.S. Coast 

Guard
96

5. Planning

MTS Recovery Data

Although an actual transportation disruption did 

not develop, there was signifi cant demand for 

MTS status information. The prototype CART 

was successfully used to support documentation 

and reporting of MTS status. CART was originally 

developed by Coast Guard Atlantic Area as a software application to support the identifi cation and 

documentation of Essential Elements of Information 

(EEI), and automated status reporting. EEI data and 

status information were entered at the fi eld level 

and were immediately accessible to the MTSRU 

staff at all levels. An automated report generation 

capability acted as the principal resource for sharing MTS recovery status information with the NIC 

Situation Unit, Homeland Infrastructure Threat and 

Risk Analysis, Maritime Administration, and the 

Northern Command. The report also informed 

strategic-level policy outreach with national-level 

stakeholders. Participating associations redistributed status reports to their constituents worldwide, 

which restored confi dence in general operating 

conditions in affected ports.

5.4 Plans Developed During the 

Response: Severe Weather Plan and 

Planning for Concurrent Activation of 

the National Contingency Plans and 

Staff ord Act

Each year, an average of eleven tropical storms 

develop over the Atlantic Ocean, Caribbean Sea, 

and Gulf of Mexico. Offi cial hurricane season 

begins June 1st and ends November 30th; however, 

a severe weather event can occur at any time.

During the 2010 hurricane season, NOAA projected 

an active to extremely active hurricane season for 

the Atlantic Basin. According to a seasonal outlook issued May 27, 2010, there was a 70 percent 

chance of 14 to 23 named storms (top winds of 39 

mph or higher) including eight to 14 hurricanes 

(top winds of 74 mph or higher). Three to seven 

were slated as major hurricanes (Category 3, 4 or 

5, with winds of at least 111 mph). As of September 

24, 2010, 12 named storms had occurred, three of 

which passed through the Gulf of Mexico. Five of 

the six storms that reached hurricane status became 

major hurricanes.

The Deepwater Horizon operating area was subject 

to both Atlantic tropical weather systems and locally 

generated storm systems that originated within the 

Gulf of Mexico. Storms from either source could 

impact the UAC AOR with high winds and seas, 

storm surge, and heavy rainfall.

The National Incident Commander and the UAC 

were concerned that severe weather would interrupt Deepwater Horizon spill response operations.

If this happened, the dynamically positioned reliefdrilling rig would need to suspend drilling, disengage, and move off station to prevent damage to 

the vessel, riser, and drill pipe. Relief well drilling efforts would cease until it was safe to resume 

drilling operations. All support vessels and equipment used in the surface and sub-sea intervention 

efforts would likely need to be withdrawn to evade 

severe weather, which would result in all response 

operations temporarily coming to a standstill. Even 

when the impact of a severe weather event did not 

cause additional damage to vessels and well-control 

equipment, the pre-storm and post-storm downtime, 

and resumption efforts could take a week or more. 

Further, severe weather could potentially push fl oating oil inland and deeply ashore into sensitive areas. 

When a storm surge retreated, the oil could remain, 

potentially contaminating wildlife habitat, as well 

as public and private property.

As the Deepwater Horizon response would likely 

extend through the entire 2010 hurricane season, 

the NIC directed the development of severe weather 

response plans.

Concurrent Activation of the National 

Contingency Plan and the Staff ord Act

The strength of the NCP is that it directs coordination among federal, state, local, and tribal stakeholders and the oil spill industry in oil spill preparedness 

and response. Responders are predominately drawn 

from federal, state, and local environmental management communities, the RPs’ contracted Oil Spill 

Removal Organizations (OSROs), other RP contractors, and RP personnel. Other state and local 

emergency response personnel are invited to provide support as needed or called upon by the FOSC. 

While the National Response Framework (NRF) 

also relies on federal, state, local, and tribal coordination, it is designed to support state and locally led 

emergency response to natural disasters and other 

catastrophic events. Pollution response under the 

NCP is a federally funded effort, while the Stafford 

Act is based on federal assistance to state and local 
5. Planning

97

governments. State and local governments did not 

understand the difference and had no idea about 

what an RP was or what its role should be. Although 

the NRF incorporates the NCP by reference under 

Emergency Support Function 10, the two governance structures are inherently different and the 

NRF does not explicitly address the role of the RP.

The role of the federal government is different in 

an NCP response compared to an NRF response. 

In the latter, the federal government supports state 

and local activities. In an NCP response, the federal 

government acts as the fi rst responder.

State and local government emergency response 

offi cials apply the bottom-up response constructs 

defi ned within the Stafford Act and the NRF. Under 

these constructs, the state and local governments 

direct the emergency response, and the federal government assumes a supporting role. Funding and 

resources are predominantly an intergovernmental 

responsibility—as opposed to those of a private 

sector responsible party under the NCP.

This response would have been even more complicated had a severe weather event resulted in a 

major emergency or disaster declaration under the 

Robert T. Stafford Disaster Relief and Emergency 

Assistance Act (the Stafford Act), discussed in detail 

below. When severe weather strikes, the primary 

event (wind, rain, fl ooding) leaves a path of destruction to public utilities and infrastructure, homes, 

businesses, and crops, and people suffer injuries 

or loss of life. Secondary impacts are related to the 

direct impacts, such as public utilities and infrastructure shutdowns (sewer, water, electricity, air quality, 

trash, and telecommunication), as well as longerterm impacts associated with economic and environmental impacts. In addition, the more severe the 

impacts sustained, the higher the recovery costs and 

the longer the recovery time. To combat these multiple-order impacts, the President of the United States 

may issue a disaster declaration under the Stafford 

Act. The Stafford Act authorizes federal agencies 

to provide assistance to states overwhelmed by a 

disaster. By order, the President delegates to the 

Federal Emergency Management Agency (FEMA) 

the responsibility for taking actions and assisting 

the affected communities.

The Planning Section at the UAC considered that if 

severe weather, such as a hurricane, were to hit the 

Gulf Coast, it could deposit oil or oily debris from 

the Deepwater Horizon well inland. The resulting response would have to include two individual 

COCODRIE, La. – 

Response workers 

assemble by their boats 

and wait to see in heavy 

weather results in the 

cancellation of oil 

cleanup operations for 

the day. Photo courtesy 

of U.S. Coast Guard
98

5. Planning

responses, depending on the size of the spill—one 

following the NCP and the other following the NRF. 

The Planning Section considered numerous issues, 

including who would be in charge of removing the 

debris, who would pay for its removal (RP or Disaster Relief Fund), how to determine if the oil was 

Deepwater Horizon oil, and how the Stafford Act 

and NRF response would be coordinated.

Funding for NCP related incidents is provided 

under the Oil Spill Liability Trust Fund (OSLTF) 

and the Comprehensive Environmental Response, 

Compensation, and Liability Act (CERCLA) Fund, 

and is sourced by an oil tax. Generally, the use of 

the OSLTF and CERCLA Fund should be avoided 

during Stafford Act declarations where the pollution event has been caused by the disaster or emergency. However, funding for pollution incidents 

commenced prior to a Stafford Act declaration, or 

from sources not potentially impacted by the disaster, is completed using the applicable pollution fund. 

This segregation of responsibilities and funding 

sources is signifi cant, and decision-makers need to 

be clearly advised to avoid substantial legal implications for both the RP and the federal government.

The UAC Severe Weather Contingency Plan 

(SWCP), discussed in detail below, kept those 

actions as separate as possible. The SWCP noted 

FEMA would administer the funding necessary 

for disaster response efforts, exclusive of Deepwater Horizon efforts, in accordance with the 

Stafford Act. FEMA could also establish a Joint 

Field Offi ce (JFO) to serve as a central coordination point for incident oversight, direction, and 

assistance regarding weather and disaster related 

response and recovery actions.

Continuous coordination among the UAC, ICPs, 

and the FEMA Regional Response Coordination 

Center (RRCC) would ensure that oil cleanup 

costs after a severe weather incident were properly 

charged to either the RP or the OSLTF, depending 

on whether the oil was determined to be from the 

Deepwater Horizon source. A Deepwater Horizon

liaison offi cer would be embedded in the RRCC to 

facilitate coordination at the regional level.

Development of Severe Weather 

Contingency Plans

The UAC developed a broad SWCP incorporating 

strategic, operational, and tactical planning for the 

Deepwater Horizon response. This comprehensive 

plan guided response operations and focused on 

the safety of all response personnel during the transition from, and return to, surface and shore based 

cleanup operations and subsurface source control 

operations. The UAC SWCP incorporated plans 

from each ICP. These independent plans aligned 

with other federal, state, and local government 

emergency plans, and were harmonized with the 

severe weather plans of Coast Guard Districts 

Seven and Eight.

The SWCP identifi ed key decision points based on 

NOAA National Weather Service storm behavior 

prediction models. These scientifi c models predicted storm behavior at approximately 120 hours 

prior to anticipated sustained gale force winds. 

This 120-hour warning initiated a series of decision points at 24-hour intervals for each affected 

area of operation that was forecast to be impacted, 

and began the potential demobilization of response 

operations.

As with many aspects of the Deepwater Horizon

response, developing an SWCP required many 

actions and policies to address the breadth and 

scope of this Spill of National Signifi cance.

Developing a Severe Weather Planning 

Capability

On May 28, 2010, the UAC created a separate Strategic Planning Team under the Planning Section at 

the UAC and at each ICP, to address issues identifi ed as ones that would stretch beyond the normal 

24-hour planning cycle. Several strategic issues 

were identifi ed, but most pressing was entry into 

the high-risk hurricane season for the region.

The fi rst Strategic Planning Teams consisted of 

one or two Coast Guard personnel who were soon 

augmented by contractor support at the ICP level, 

along with a team of Department of Defense (DOD) 

strategic planners at the UAC level. In order to write 

a comprehensive SWCP, especially at the ICP level, 

many more personnel were required. Signifi cant 

contractor support was needed, as was daily support by state and local planning personnel, to ensure 

alignment with state and local hurricane plans.

The DOD planning support element was dispatched 

directly by the NIC. Initially brought in to develop 

unconstrained strategic courses of action for the 

response effort, they focused on SWCP development. DOD expertise was used to validate early 

draft SWCPs and to visit fi eld operations sites to 

expose logistical gaps in the plans. Ultimately, 

DOD personnel observations were used to identify 
5. Planning

99

problem areas for severe weather response planning 

and areas where improvements could be made in 

the plans.

To build a plan of this nature would normally 

take two years, but with the oil spill organization 

(National Incident Management System (NIMS) 

and ICS) already in place under one unifi ed command, most stakeholders and planning processes 

were already participating in the response. It was 

straightforward under these circumstances to 

coordinate between the different levels of government. The stakeholders’ staffs had already been 

centrally located and committed to the response. 

The Strategic Planning Staff collaborated with the 

immediately available state and local emergency 

management agencies, FEMA, and DOD.

Existing SWCPs were reviewed and continuously 

improved. Normally, severe weather plans are 

reviewed and improved on an annual basis. However, because of hurricane season and exponential 

growth in the overall response organization, review 

and improvement of SWCP was done approximately every 10 days for the fi rst two months of 

hurricane season. These regular adjustments to the 

guiding UAC SWCP created some gaps between 

the UAC guidance plan and the ICP SWCPs.

Severe Weather Operations Center (SWOC)

For the same reasons a Strategic Weather Planning 

Team needed to be established to look beyond the 

daily 24-hour planning cycle, a strategic weather 

monitoring capability was needed to look beyond 

the next 24-hour operational period and focus 

attention to the 7 to 10 day (long-range) severe 

weather forecast. The Severe Weather Operations 

Center (SWOC) was set up as the primary clearinghouse for severe weather information throughout 

the Deepwater Horizon AOR. The SWOC’s four 

main responsibilities were:

• Production of a common weather picture,

• Decision logs and status regarding severe 

weather at each location,

• Continuity of operations even during periods 

of relocation, and

• Maintenance of links with key stakeholders 

through Liaison Offi cers and local Emergency 

Operation Centers (EOCs).

Residents of the Gulf Coast were well informed 

on hurricane procedures. They were familiar with 

the two hurricane conditions established by the 

National Weather Service (NWS): Hurricane 

Watch and Hurricane Warning. These offi cial 

notices serve the vast majority of residents, state 

and local governments, companies, and other 

agencies by providing advanced notifi cation of 

an approaching hurricane. However, the Severe 

Weather Planning Team had a vast operating area, 

unique local conditions, and complex water and 

land operations to consider. For the purposes of 

creating an actionable SWCP, the NWS Hurricane 

Conditions were insuffi cient to account for necessary severe weather planning and actions.

Accountability Requirements

The UAC envisioned that the response organization would maintain accountability of assigned 

personnel and critical resources. To appreciate the 

complexity of the Severe Weather Contingency 

Plan tasking from June 1 to August 1, 2010, the 

response organization grew as shown below:

Table 5.1: Growth in Response

Maintaining accountability of all Deepwater Horizon personnel and critical resources through the 

demobilizing of responders and response equipment would be a considerable challenge under 

hurricane conditions.

Different stakeholder communities (government, 

private sector, volunteer groups) working on the 

response ranged from having no heavy weather 

procedure in place to having well-established procedures, or something in between. To alter existing 

plans, particularly those of the private sector, was 

not desirable. Thus, the Deepwater Horizon plan 

allowed some fl exibility to accommodate the many 

stakeholders who had existing plans, and attempted 

to coordinate with those plans. In general, the 

existing plans established categories of personnel (government, contractors, volunteers, etc.), 

who would be released from the response or kept 

as essential, and a verifi cation process for tracking 

individuals. The tracking process was centralized 

Date People Off shore 

Vessels

Boom 

(feet) 

Vessels of 

Opportunity 

(VOO)

Aircraft

June 1, 2010 16,887 1,231 1,949,795 unknown 57

July 5, 2010 45,037 6,505 3,177,830 3,185 113

August 1, 2010 30,075 3,684 3,646,640 1,590 96
100

5. Planning

through a Houston call center (30 desks manned to 

receive and track responder tracking information). 

DOD personnel who specialized in tracking personnel signifi cantly contributed to this effort.

A revised UAC SWCP used categories of essential 

personnel and non-essential personnel. New terms 

were created to describe personnel status in the 

event of severe weather. The response organization would transport and account for all retained 

personnel. Released personnel would be returned 

to their point of origin and their parent agency, 

organization, or company in advance of severe 

weather. A designated representative of that agency 

or company would account for their personnel, and 

report that condition to the response organization.

Personnel Accountability Unit (PAU)

The Severe Weather Contingency Plan provided a 

Personnel Accountability Unit (PAU) at a BP facility in Houston, Texas, that was co-located with the 

Houston Call Center (HCC). When activated, the 

PAU was charged with tracking the status of Deepwater Horizon personnel during a severe weather 

incident. The PAU was capable of keeping track 

of retained personnel, as well as receiving reports 

from those representing released personnel. The 

PAU established a telephone number for response 

personnel to call and receive updated information if work forces needed to be reassembled in 

the event of a severe weather incident. The PAU 

also had a Standard Messaging Service (SMS) that 

could send text-to-voice messages to distribute 

information rapidly and accurately.

The UAC SWCP contained detailed scripted actions 

the PAU was to take 

for each change to 

severe weather conditions as a storm 

approached the operating area. Actions 

included augmenting the PAU with 

additional personnel, 

transmitting scripted 

text-to-voice messages, and preparing regular reports to 

account for both categories of personnel back to 

Alternate Command Posts. With the passage of 

a storm, the PAU accounted for released personnel by organizational contacts until the affected 

UAC or ICP could manage the re-entry of released 

personnel.

Accountability for Boom

At the onset of severe weather contingency planning, the UAC designated containment boom as 

a critical resource. Boom placement was one of 

the most important issues in early response. Prior 

to altering the boom confi guration or to retrieving boom in the event of severe weather, the 

Severe Weather Contingency Plan required the 

ICPs to institute a just-in-time approach to staging and deployment of boom. This philosophy 

was designed to minimize the quantity of staged 

boom requiring relocation in the event of pending 

severe weather. Each Incident Commander was 

also tasked with weighing several factors when 

considering the relocation of boom in preparation 

for a severe weather event. Those factors included 

but were not limited to:

• Safety risk to personnel retrieving boom,

• Type of boom,

• Oil contamination and time to decontaminate,

• Sensitivity of area protected,

• Personnel and equipment required for 

recovery,

• Personnel and equipment required for transport out of area,

LAFOURCHE PARISH, La. – High winds and 

storm tides caused a breach in the Hesco 

baskets in East Port Fourchon Beach, La. 

Photo courtesy of U.S. Coast Guard
5. Planning

101

• Potential environmental and commercial damage if left in place, and

• Potential impacts on safe navigation.

Assessing deployed boom against these criteria was situation-dependent and not completely 

achievable. As noted in Table 5.1, on June 1, 

there were 1.9 million feet of containment boom 

deployed throughout the response area. This grew 

to 3.2 million feet in July 2010, then to 3.6 million in August (not counting the 8 million feet 

of sorbent boom deployed by August). In reality, if the entire response organization focused 

only on retrieving boom, it was impossible to 

retrieve, decontaminate, and store three million 

feet of boom in the 120 hours allocated to prepare for approaching severe weather. The UAC 

acknowledged that the goal of boom removal was 

not achievable in advance of a tropical storm or 

hurricane, and allowed practical modifi cation of 

the SWCP. Under the new construct, fi re boom was 

classifi ed as a priority for retrieval. Of the remaining boom types, boom deployed in the vicinity 

of established shipping channels was required to 

be removed prior to any severe weather event to 

allow vessels to depart port, or alternatively, seek 

safe harbor.

Prevention of Confl ict with Local and State 

Governments Evacuation Plans

Southern Louisiana, and in particular Plaquemines 

Parish, is largely an isolated and low-lying area. 

For the purpose majority of vehicles must use 

a single two-lane road that is at, or just slightly 

above, sea level. Given the remoteness, limited 

surface egress, and tendency to fl ood, Plaquemines 

Parish has adopted a hurricane evacuation posture 

that far exceeds the NWS Hurricane Watch and 

Warning time lines. When a forecast hurricane 

storm path places Plaquemines Parish at a high 

certainty of landfall, the parish president orders a 

mandatory evacuation of local citizenry 72 hours 

prior to arrival of tropical force winds. As such, in 

the event of a hurricane landfall in Plaquemines 

Parish, all Deepwater Horizon response activities 

would have to stop; critical equipment secured 

for heavy weather or transported out of the area; 

small boats sailed or trailered to safe mooring or 

locations; and response personnel transported to 

safe areas (generally considered north of I-10) 

prior to the parish mandatory evacuation of locals 

citizenry, so as not to interfere with the evacuation 

of residents.

LAFOURCHE PARISH, La. – 

High winds and storm tides 

destroyed the tiger boom 

deployed by the Louisiana 

Army National Guard 527th 

Engineer Battalion. Photo 

courtesy of U.S. Coast Guard
102

5. Planning

Safe Shutdown of Off shore Recovery and Source 

Control Operations 

From June 1, 2010, through August 15, 2010, there 

were thousands of vessels operating offshore in the 

Gulf of Mexico and near the Macondo well site 

conducting sub-sea oil recovery, surface recovery, 

scientifi c monitoring, and well drilling operations. 

This vast operating area, under the direction of 

the Incident Commanders at ICP Houma, ICP 

Mobile, or Source Control in Houston, employed 

a wide range of vessels, ranging in size from 50- to 

100-foot fi shing vessels towing sea boom, operating skimmers, and conducting in situ burning, to 

larger vessels including 835-foot drill ships and 

drill platforms recovering oil from the Deepwater 

Horizon riser and blow-out preventer (BOP), conducting sub-sea dispersant operations, and drilling 

emergency relief wells. These operations extended 

from the near-coastal environment to over 50 

miles southwest of the Louisiana shore, and were 

at high risk in the event of severe weather. Given 

that severe weather could potentially impact any 

offshore surface cleanup operation or the Source 

Control area of operations, Incident Commanders and ship captains needed suffi cient lead time 

to stop drilling and recovery operations, recover 

drilling and other critical equipment, and move 

a 3,000 vessel fl eet (average number of vessels 

employed) to safe locations.

The time necessary for a coastal fi shing vessel 

to secure from skimming, burning, or booming 

operations and move to a safe harbor was not well 

established. However, it could be estimated, based 

on private sector data developed over the past 30 

years operating in the Gulf of Mexico. The history 

of offshore drilling and production operations in 

the Gulf of Mexico has created a tested series of 

Trigger Times (T-times). T-times are estimates of 

the time it takes to complete hurricane preparations, allowing 24 hours to physically escape the 

path of the storm and evacuate personnel from 

moored platforms.

The lengthiest of the offshore operational T-times 

were for vessels engaged in relief well drilling 

operations. These vessels would have to withdraw 

drilling equipment, secure the BOP and all ancillary equipment such as sub-sea Remotely Operated Vessels (ROVs), and be given enough time 

to evade the storm path 24 hours prior to onset of 

severe weather winds and seas. In most operational 

confi gurations, the T-time for the Development 

Driller II, Development Driller III, and Discoverer 

Enterprise were in excess of 100 hours and, in a 

few cases, exceeded 140 hours. Because T-times 

were dependent on each day’s operation, daily 

T-times were prepared by Source Control and 

passed to the SWOC for situational awareness by 

the UAC. On average, T-times for Source Control 

operations stayed between 50 and 120 hours. As 

120 hours was the most common high-end T-time 

for drilling operations, the 120-hour T-time time 

was selected based on historical norms as the outermost action point for severe weather contingency 

planning purposes.

Training

With the UACs and Section Chiefs briefed on 

the SWCP, all response workers had to receive 

substantial training to be accomplished at each 

ICP and outlying fi eld locations. Strategic Planning Teams were responsible for this training. The 

SWCP was worked into the training curriculum 

given to all newly reporting responders. As the 

manpower to support Deepwater Horizon response 

was very dynamic throughout the entire hurricane 

season, and given that most agency responders 

rotated on a 20-to-30-day cycle, including hurricane readiness training into the indoctrination 

training was necessary and effective.

GULF OF MEXICO – Crews 

aboard vessels around 

the drillship Discoverer 

Enterprise continue 

operations to minimize 

the impact from the 

Deepwater Horizon oil 

spill. Photo courtesy of 

U.S. Coast Guard
5. Planning

103

Safety First on Reconstitution of Deepwater 

Horizon Operations

Work conditions can change drastically after hurricanes and other natural disasters. In the wake of 

a hurricane, response and recovery workers would 

have faced additional challenges, such as downed 

power lines, downed trees, and high volumes of 

construction debris, all while performing more 

familiar tasks and operations. The Severe Weather 

Contingency Plan recognized this risk and outlined 

a plan for a staged reconstitution of response activity. In executing the SWCP, the health and safety 

of the workforce remained the primary focus.

In accordance with the UAC and ICP SWCPs, once 

local authorities had given clearance for access 

to areas of concern, post-storm assessment teams 

would be assembled to access the affected areas. 

The Post-Storm Assessment Teams could include 

Shoreline Cleanup and Assessment Technique 

teams, Rapid Assessment Teams, and Facility 

Damage Assessment Teams.

The primary role of the Post-Storm Assessment 

Teams was to determine if a facility or area 

was safe for reconstitution following a storm. 

Due to the hazards likely to be present, all PostStorm Assessment Teams were to be augmented 

with appropriate Health and Safety representation as deemed necessary by the UAC and ICP 

Safety Offi cer. Appropriate representation might 

include medical, industrial hygiene, and safety 

professionals.

During the assessment, the team would be required 

to identify and evaluate the hazards involved in the 

anticipated tasks and operations specifi c to each 

surveyed location. This information would allow 

those planning work to identify any additional 

engineering controls, work practices, and personal 

protective equipment necessary to minimize exposure risk. Teams were planned to be self-suffi cient 

while completing the assessments so as not to place 

additional burden on local resources.

Hurricane Alex, Tropical Depression No. 2, 

and Tropical Storm Bonnie

One tropical cyclone, Hurricane Alex, was 

observed during the month of June. Alex grew to 

a Category Two Hurricane with a strong westerly 

track forecast to impact the northern Mexico coast. 

The storm made landfall in the area of Soto La 

Marinna, Mexico and never threatened the Deepwater Horizon operational area.

Two tropical systems formed during July, Tropical Depression No. 2 and Tropical Storm Bonnie. 

Tropical Depression No. 2 followed a similar westerly path as Hurricane Alex, but did not strengthen 

into a tropical storm. Tropical Depression No. 2 

made landfall just north of where Hurricane Alex 

made landfall in the extreme southern tip of Texas 

and also never was forecast to impact the Deepwater Horizon operation area. In late July, Tropical 

Storm Bonnie formed in the eastern Caribbean. 

At various times during its track to the northwest, 

Tropical Storm Bonnie placed the southern tip 

of Florida and then the northern Gulf coast from 

Destin, Fla., to Morgan City, La., in the Tropical 

Storm Warning Area.

By this time, the SWOC was staffed and fully 

functional, maintaining a common weather picture, conducting conference calls, and advising 

the UAC and ICPs during 

its regularly scheduled 

morning and afternoon 

command briefs. Close 

coordination, including 

twice-daily briefings, 

with the National Hurricane Center, NWS, and 

multiple-meteorological 

support organizations 

provided a very accurate 

VENICE, La. – A U.S. Coast Guard Petty Offi cer uses 

a Pathfi nder phone to obtain the exact global 

position of boom damaged by harsh weather 

conditions. Photo courtesy of U.S. Coast Guard
104

5. Planning

picture of the threat imposed by Tropical Storm 

Bonnie. That weather picture showed Tropical 

Storm Bonnie was forecast to diminish in strength 

as it neared the northern Gulf and would diminish to an area of low pressure. As the SWCP was 

designed to be fl exible enough to order partial 

changes to operations without wholesale changes 

to severe weather readiness conditions across the 

operational area, the UAC was able to suspend 

operations at Source Control, as well as coastal and 

the near-shore skimming operations in advance of 

wind and wave impacts.

The ability to pick specifi c items from the detailed 

Action Item Checklists developed by each Incident 

Commander was highly benefi cial to command 

and control, and understanding of action to be 

taken at all levels of the organizations. Although 

the UAC did not order a change to the offi cial 

Severe Weather Readiness Condition, the partial 

implementation of action items from individual 

IC’s SWCPs, in anticipation of severe weather 

impact, proved effective. Fortunately, the temporary halting of Source Control activity occurred 

after the Macondo well was capped, and although 

it impacted the drilling of relief wells and support 

vessel activity, it did not result in further discharge 

of oil into the Gulf.

5.5 Plans Developed During the 

Response: Transition Planning

Under the ICS management structure, the primary 

management tool used to manage the event is the 

planning cycle. The duration of the planning cycle 

is determined by the particular requirements of the 

incident. For example, the cycle may be 12 hours, 

24 hours, 48 hours, or longer.

Strategic planning, or long-term planning, is not 

a normal element of the ICS. Due to the uncertain duration of Deepwater Horizon response 

efforts, Strategic Planning units were established 

at the NIC, at the UAC, and at the ICPs to plot 

the response organization’s long-term objectives.

Origins of Strategic Planning

The strategic planning concept was born of a need 

to address emerging issues: critical resources, the 

potential for oil in the Gulf of Mexico loop current, 

and development of the UAC Severe Weather Plan.

The nature of the response presented an immediate 

need for response equipment, particularly boom 

and skimmers. The CRU was created to anticipate and determine which response resources were 

required for the spill and once identifi ed, coordinate with the Logistics Section to acquire suffi cient 

supplies. Specifi cally, the CRU contacted boom 

supply sources and manufacturers, and located 

skimming equipment, not only in the United States 

but worldwide.

The other driver for strategic planning was the scenarios examining the possibility that oil would contact the loop current in the Gulf of Mexico. If oil hit 

the beaches of western Florida, the Coast Guard and 

the Responsible Parties (RP) would need to mobilize even more people and resources instantly. The 

UAC and ICP Houma began to examine requirements to build a response organization for the west 

coast of Florida. ICP Mobile independently began 

its own strategic planning process.

It became more essential to examine and plan for 

requirements to sustain the response when federal 

resources tripled. The Strategic Planning Team 

was created on May 28, 2010, the same day of the 

order to triple resources.

ST. PETERSBURG, Fla. 

– A U.S. Coast Guard 

offi cer reviews the latest 

storm tracking data 

at the St. Petersburg 

Branch Command Post in 

preparation for Tropical 

Storm Bonnie . Photo 

courtesy of U.S. Coast 

Guard
5. Planning

105

Severe Weather

The creation of the Strategic Planning Team nearly 

coincided with the June 1 start of hurricane season. As discussed in detail above, the fi rst major 

project for the UAC Strategic Planning Team was 

to develop the Severe Weather Plan. Strategic 

Planners at all levels of the organization engaged 

to establish detailed plans in the event of severe 

weather.

Transition Planning

The next major focus of Strategic Planning was 

transition planning. There were three major 

anticipated transitions: transition away from offshore to shoreline response and the corresponding release of response resources; consolidation 

of the response organization by collapsing ICPs 

to the Gulf Coast Incident Management Team 

(CG–IMT); and disestablishment the UAC by folding the remainder of the response organization into 

a single Incident Management Team, the GC–IMT.

Once the well-kill was achieved in August and after 

the permanent well-kill occurred in mid-September, when there was no recoverable oil offshore, 

it was necessary to scale the size of the response 

organization, particularly those parts dedicated 

to responding to oil before it came close to land. 

Part of that process was also shifting the focus of 

operations to near-shore and shoreline cleanup, 

with a phased transition including defi ned, conditions-based trigger points to scale the near-shore 

and shoreline cleanup operations over time as the 

cleanup progressed.

ICP Mobile began negotiations for this transition 

with Alabama, Mississippi, and Florida in late July 

2010, soon after the well was capped. Those states 

Response Trigger Status Activities (summary only) 

Level I All Zone Response Status: Well cap in place 

– no new product discharging. Recoverable oil 

on the water in the off shore and near-shore environment and impacting the shoreline . Off shore 

oil recoverable.

- Deploy full off shore, near-shore and onshore 

recovery operations and protect shorelines,

- Begin decontamination of off shore recovery 

vessels, and

- Maintain county Liaison Offi cers as required.

Level II Near-shore and Shoreline Assessment and 

Cleanup Status: No observations of skimmable 

concentrations of off shore (>3 nm) oil on 3 

consecutive days of full saturation over-fl ights. 

Remaining oil widely scattered and not available 

for burning or chemical dispersing.

- Place off shore recovery operations in standby 

and continue to decontaminate them,

- Redeploy off shore skimming equipment to nearshore where possible, 

- Recover near-shore fl oating oil and protect and 

clean shorelines, and

- Evaluate and implement appropriate boom 

strategy.

Level III Detailed Cleanup to Achieve Completion

Status: No aerial, vessel, or shoreline observations of skimmable concentrations of oil on 

three consecutive days of full saturation observations. Remaining oil widely scattered and not 

skimmable. Remobilization of oil episodic and 

intermittent. No substantial re-oiling of shorelines.

- Place on water skimming operations in standby 

and decontamination,

- Deploy onshore recovery operations to implement SCAT Shoreline Treatment Recommendations and address intermittent reoiling as 

required, and

- Rescale organization based on termination of 

on-water recovery operations.

Level IV Maintenance and Monitoring Status: All 

SCAT Shoreline Treatment Recommendations 

completed such that further treatment would 

not provide net environmental benefi t. Episodic 

impacts and discovery of oil continues.

- Deploy hot-shot teams to address episodic 

impacts and discovery of oil along shorelines or 

in near-shore environment,

- SCAT surveys based on triggers relative to beach 

and shoreline profi le (e.g., storm events), and

- Review all oil recovery resources.

Level V Re-evaluation of Level IV Shoreline Segments 

Status: Winter storm season has passed necessitating re-evaluating of no further treatment 

shoreline segments.

- Deploy hot-shot teams to address episodic impacts and discovery of oil along shorelines or in 

near-shore environment. Detailed SCAT surveys 

of impacted shoreline segments.

Level VI End State: Long-term Monitoring and Restoration Status: Restoration complete . Episodic 

impacts and discovery of oil continues.

- Ongoing monitoring, and

- Deploy hot shot teams as required.

Table 5.2: 

Zone Responses 

and Activities
106

5. Planning

hoped to salvage the summer and fall tourist season 

along their Gulf beaches and were interested in 

trying to conclude cleanup operations as quickly 

as possible. ICP Mobile reached an agreement 

with those three states for a transition plan, with 

trigger points, by the end of the month. The plan 

contained six levels with defi ned transition points. 

The plan was agreed to and signed by Mississippi 

on August 6, 2010, Alabama on August 3, and 

Florida on August 2.

Discussions with Louisiana over transition planning began with a meeting with the Governor 

and parish presidents from the eleven coastal 

parishes in New Orleans, La., on July 27, 2010. 

The National Incident Commander co-chaired the 

meeting with the FOSC and UAC and presented 

a plan based on the one developed for the ICP 

Mobile AOR. No agreement was reached at the 

July 27 meeting. Following the meeting several 

of the parishes developed their own version of a 

transition plan. The parish-developed plan would 

have required the FOSC to obtain parish approval 

for any change in equipment and personnel levels 

refl ected in the plan. As this raised concern over 

scope of FOSC authority, a second meeting with 

the Governor and parish presidents was held on 

August 13 in Houma, La. At this meeting the state 

made clear they would not agree to an overall state 

transition plan until the FOSC agreed to individual 

plans with each of the affected parishes.

Within Louisiana, ICP Houma and their Branch 

directors in the parishes, with RP representation, 

began to negotiate transition plans with each 

parish. St. Mary’s and Iberia parishes combined 

their plans, as did Orleans and St. Tammany parishes; only nine plans remained to be negotiated. 

The parishes’ major concern during negotiation 

was to ensure the draw down in the scope of the 

response and amount of response resources did 

not occur before all potential cleanup work was 

fi nished. Most particularly, the oil budget released 

by NOAA stated 24 percent of the oil spilled was 

unaccounted for.

Early reporting by some scientists while the well 

still fl owed indicated there was a plume of oil 

submerged below the surface. Uncertainty over 

what that meant, and the fact the plans were being 

negotiated during hurricane season, led parish 

and Louisiana offi cials to claim that a signifi cant 

amount of this oil that was unaccounted for could 

wash ashore in the event of a hurricane. Although 

NOAA personnel attempted to explain this was 

highly unlikely, state and parish offi cials insisted 

the transition plans retain signifi cant response 

materiel and personnel through the end of hurricane season.

Acquiring parish agreement to transition plans 

took enormous effort on the part of the Incident 

Commanders in Houma and the parish Branch 

Directors, and the UAC. There was suspicion 

among parish and state offi cials the federal government would allow the RP to reduce its response 

effort with the oil well capped. The communities 

feared they alone would have to deal with oiled 

shorelines and future re-oiling if a storm pushed 

submerged oil onto the shores of Louisiana. Coast 

Guard offi cials gained the confi dence of local leaders assuring them that while the resources were 

scaling to match the response, all remained committed to the fast and effective cleanup of oiled 

areas. In addition, the Coast Guard explained the 

specifi c activities associated with each level of the 

plan. (See discussion of Quick Reaction Forces 

in Chapter 3.) The outreach efforts and complex 

negotiations to complete the parish transition plans 

were fi nished in three weeks.

All nine parish transition plans were agreed to and 

the state signed an overarching state transition plan 

that included the nine parish plans. Following the 

agreements, the FOSC held a third parish president 

meeting in Houma, La., on September 1, 2010. 

The Louisiana plan differed from the ICP Mobile 

plan, not only in the inclusion of the nine parish 

plans with their specifi c personnel and equipment 

requirements, but also in that Levels V and VI of 

the Mobile plan were combined in the Louisiana 

plan as Level V.

Incident Command Post Consolidation

Once the state transition plans were signed, the 

FOSC began planning the consolidation of the 

incident command organization. With the source 

secured and the focus of the response operations 

on shoreline cleanup, there was no longer a need 

for the overhead of major command posts at ICP 

Houma and ICP Mobile, and small ICPs in Galveston, Texas, Houston, Texas, and Miami, Fla. In 

addition, with the source secured, the demand for 

aviation sorties dropped dramatically. As a result, 

the Aviation Coordination Center at Tyndall AFB 

could be consolidated into the overall incident 

management structure.
5. Planning

107

Beginning September 1, 2010, the Strategic Planning Team developed a plan to consolidate all of 

the ICPs into a single Gulf Coast Incident Management Team (GC-IMT). The actual implementation of the consolidation was mainly handled 

by the UAC Logistics Section. Working with the 

RP, the GC-IMT was placed in New Orleans, La., 

co-located with the UAC. In time, the UAC would 

dissolve and the CG–IMT would assume the role 

of FOSC.

Monitoring and Maintenance Plan and UAC 

Transition Plan

Consolidation of the ICPs took place on September 20, 2010. Over the next several weeks, operations focused on continued shoreline cleanup and 

completion of the Shoreline Cleanup Assessment 

Technique (SCAT) process. According to the transition plans negotiated in August, once SCAT teams 

determined that no further treatment was required 

across the entire AOR, the shoreline would be 

placed in a monitoring and maintenance phase. 

In this phase, active shoreline cleanup would only 

be undertaken when new signs of oiling were discovered. The plans provided for regular shoreline 

inspections to locate any new oiled areas, generally caused by previously buried oil becoming 

uncovered by wind or waves, or if submerged tar 

mats near-shore were pushed onto land by storms. 

The plans also spelled out resources that would be 

kept on call, and methods to respond to reports of 

recoverable oil.

The monitoring and maintenance plans were, like 

the overall transition plans, split between what had 

been the ICP Mobile AOR, and the ICP Houma 

AOR for Louisiana. A signifi cant part of the reason for the continued difference in plans was that 

most of the shoreline in the two areas differed. In 

Mississippi, Alabama, and Florida, much of the 

oiled shoreline consisted of sandy beaches. The 

federal government, through the National Park 

Service and U.S. Fish and Wildlife Service, was 

a signifi cant landowner. In Louisiana, most of the 

oiled shore was marsh, and the federal government 

was a far less signifi cant landowner. The cleanup 

techniques required for the two types of shoreline 

were very different. Each had separate monitoring 

and maintenance plans, which allowed them to be 

tailored to the predominant shoreline type.

In the eastern states, much of the negotiation about 

the contents of the monitoring and maintenance 

plan involved technical details concerning how 

to locate oil on the beaches. For example, there 

was considerable debate on the depth of the sand 

to clean. Some tar mats were buried well under 

the existing top layer of sand by September and 

October, 2010. Yet digging entire sandy beaches 

to any signifi cant depth and cleaning the sand 

had the potential to harm sensitive ecosystems, 

as well as potentially disturb historic and cultural 

resources. Once details as to the degree of search 

and response were settled, the eastern monitoring 

and maintenance plan was approved.

In Louisiana, the issues related to cleaning marsh 

were complex. In many instances, there was a 

scientifi c concern that attempts to clean marshes 

could actually do more harm than leaving the area 

undisturbed, and thus further eroding Louisiana’s 

marshes. On the other hand, local residents found it 

diffi cult to accept having oil left in the marsh. Moreover, there were two heavily oiled areas, Barataria 

Bay and Bay Jimmy, where response operations 

were ongoing into November 2010. Louisiana offi -

cials continued to be concerned about the threat of 

tropical storms pushing more oil into the marshes.

Over September and October 2010, the westernmost coastal parishes agreed with the FOSC to 

move their shoreline into the monitoring and maintenance phase. The eastern parishes, which had 

also been far more heavily oiled, did not wish to 

move to that phase until after hurricane season.

FORT MORGAN, Ala. – 

A layer of oil below the 

sand on the Fort Morgan 

Peninsula is revealed by 

a subsurface Shoreline 

Cleanup Assessment 

Technique Team. Photo 

courtesy of U.S. Coast 

Guard
108

5. Planning

As more and more of the shoreline across the entire 

UAC AOR moved to the monitoring and maintenance phase, the FOSC tasked the Strategic Planning Team with developing a plan to transition the 

UAC out of existence and return the supervision of 

the response to the CG–IMT. The plan called for 

the elimination of the UAC, and the shift from a 

fl ag offi cer as FOSC to the captain in charge of the 

GC-IMT. As drafted, this transition plan required 

two conditions to be met before the UAC would 

dissolve. The fi rst was for sub-sea monitoring 

program to report its preliminary results and fi nd 

no recoverable oil in the water column. The other 

condition was for the shoreline of the entire AOR, 

with the exception of limited defi ned locations such 

as Barataria Bay and Bay Jimmy, to transition to 

the monitoring and maintenance phase.

The FOSC briefed Coast Guard Headquarters and 

Atlantic Area on this plan on October 29, 2010, and 

received approval to proceed when the conditions 

in the plan were met. Over the next several weeks, 

these areas were transitioned to monitoring and 

maintenance. The preliminary results of the sub-sea 

monitoring program were reported on December 

16, showing no recoverable oil. Shortly thereafter, 

the UAC turned over the duties of directing the 

remaining response operation to the GC-IMT.

As much of the shoreline shifted to monitoring and maintenance, the operational period for 

IAPS developed by the GCIMT lengthened. With 

more time built into the ICS planning cycle as the 

operational period moved out to a week, and the 

extremely limited response operations, the continued need for a separate Strategic Planning Team 

was also eliminated.

5.6 Incident Documentation

The enormous scale of the Deepwater Horizon 

response caused a continuous fl ow of paper documents and electronic media during each hour of the 

response. By February 2011, an estimated 27 million pages of documents had been collected. After 

securing computers, laptops, mobile phones, external hard drives, and servers, it is estimated there will 

be approximately 15–20 terabytes of electronically 

stored information (ESI) created by the FOSC over 

the course of this response.

Under the NCP, the FOSC is required to document 

all phases of response and removal, actions taken, 

and the basis for cost recovery. When litigation is 

reasonably anticipated, parties to the litigation have 

an obligation to preserve relevant evidence, including all relevant tangible objects and documentation, 

including ESI. The Department of Justice ordered 

all federal agencies to preserve information generated by the response.

To promote document preservation, the FOSC 

issued three directives and Coast Guard Headquarters released a series of messages to its members 

(see ALCOAST 234/10). The memoranda and 

messages described the duty to preserve, what to 

preserve, and how to preserve both paper and electronic records.

Documentation specialists were assigned to oversee 

the collection and organization of all documentation 

generated by the response. Department of Justice 

and Coast Guard preservation orders mandated the 

preservation of all hard-copy documents generated, 

including multiple copies of the same document, 

misprinted documents, and even scrap paper. The 

Coast Guard’s documentation specialists established 

and managed documentation units at the UAC 

and each of the ICPs. These specialists traveled 

to Branches to collect documents and electronic 

devices on a regular basis.

As time went on and documentation staff increased, 

a challenge arose: a lack of space at the ICPs and 

UAC to store all of the documents. As a result, the 

Coast Guard established a Central Archive for documentation in Mandeville, La. The Central Archive 

is staffed with 25 personnel assigned on a rotational 

basis who cull and sort documents delivered from 

the UAC and ICPs.

Once the records have been collected, culled for 

trash and duplicates, and sorted, approximately 3.5 

million pages will be scanned. These pages will be 

scanned to searchable digital images and loaded to 

a server maintained at the Central Archive.

The Coast Guard also developed a protocol for the 

collection of electronic devices that contained Deepwater Horizon related ESI, specifi cally, laptop and 

desktop computers, servers, routers, switches, printers, copiers, external hard drives, cell phones, smart 

phones, and weekly back-up tapes. As electronic 

devices were no longer needed for the Deepwater 

Horizon response effort, the Coast Guard shipped 

them to the Central Archive. More than 1,000 laptops, 25 servers, hundreds of back-up tapes, hundreds of mobile phones, several desktop computer 

towers, external hard drives, and several cameras 
5. Planning

109

were shipped to the Central Archive. In addition, 

to try to ensure more thorough preservation of ESI 

generated by responders, Coast Guard Headquarters 

established servers dedicated solely to the response 

and transferred the user profi les of all Coast Guard 

personnel on the Coast Guard Data network to those 

servers upon check in.

There was no existing ESI preservation and collection policy, practice, and toolset at the start of 

the incident. Thus, an ESI collection preservation 

and organization strategy had to be created during 

the response. CG-6 and CG-094 issued ALCOAST 

234/10 to notify responders of their obligations. In 

the Department of Justice’s view, such a general 

directive partially covered their preservation concerns, but the Department of Justice wanted the 

Coast Guard to personally notify each responder 

of his or her preservation obligation and obtain a 

signed acknowledgement. With over 4,000 Coast 

Guard responders who had deployed by that time, 

constructing a mechanism to do this was a big challenge. The method chosen was the delivery of the 

existing preservation orders to all Coast Guard personnel upon check in to the response. At this time, 

arriving members would verify they had met all the 

specifi c terms of the preservation orders, to include 

preservation of personal email. Military and civilian members would sign the acknowledgement at 

check in and again upon departure.

An added complication to the preservation of ESI 

was the use of personal email accounts to conduct 

Coast Guard business. Personnel deployed to the 

fi eld often used commercial email accounts such 

as Google Mail or Yahoo Mail to conduct offi cial 

Coast Guard business, because in many areas there 

was, at least in the fi rst few months of the response, 

no means for responders to connect to the Coast 

Guard Data Network. Additionally, fi eld personnel also used personal laptops. As a result, fi eld 

personnel’s emails and computer hard drives were 

subject to the preservation order. Voice mail, both 

on land lines and cell phones—including personal 

cell phones—was also subject to the preservation 

order if the voice mails pertained to the response.

The process of developing the Central Archive, 

scanning documents, making electronic information searchable, and establishing an administrative 

record and meeting discovery requirements for 

ongoing litigation related to the response continues.

5.7 FOSC Key Points

Area Contingency Plans

This response exposed a number of issues about 

the Area Contingency Planning process that need 

to be re-examined.

Local Government Involvement

The plans currently assume any of the interests of 

local government are coordinated and represented 

through state involvement in the contingency planning process. While this may be true in many locations, it was not for all of the states impacted by the 

Deepwater Horizon oil spill. As any spill impacts 

the local government of the affected area, as well 

as the state government, it is advisable to create an 

explicit role for local government in the planning 

process. In the case of the Deepwater Horizon spill, 

it was a necessity. 

Other State Agency Involvement

States generally designate a specifi c agency as 

the one primarily responsible for carrying out the 

state’s responsibilities under the National Contingency Plan (NCP). For most spills, that works 

well. But the rest of state government is generally unaware of what happens in oil spills, until 

there is a major one and then, when a broader 

range of agencies and actors within state government become involved, lack of prior participation 

becomes problematic. Ensuring broader understanding of contingency plans by state governments would enable easier adaptation to wider 

participation for major events.

Area Committees need to meet regularly in order 

to make sure the Area Contingency Plans are accurate and useful. If these meetings are not regularly 

held, the plans and relationships may become outdated. Federal, state, tribal, and local government 

offi cials, as well as facility owners, become less 

familiar with one another without planning. This 

allows for a breakdown in the planning process 

and reduces the effi cacy of the plans themselves. 

Area Committees need to meet at a required level 

of frequency.

Detailed planning and testing of response strategies is necessary. When committees do not meet 

frequently, plans do not develop into detailed 

response strategies. Plans must be tested to be useful. Communication gaps can lead to a situation 
110

5. Planning

where details are negotiated in the midst of a 

response, with less than optimal results. In this 

instance, the limited effectiveness of protective 

booming in open seas and in fast currents would 

have been better understood through real deployment and exercises.

There exists no bridge between Area Contingency 

Plans to provide an overarching construct to deal 

with spills that cross Area Contingency Plan 

boundaries. Such a means to coordinate across 

areas is necessary. For example, if two adjoining 

areas list the same equipment to meet planning 

requirements and a spill impacts both areas, existing plans do not account for simultaneous demands 

for the same resources.

Worst Case Discharge amounts listed in Area Contingency Plans are focused on ship and shoreside 

facilities. In the context of Plans covering locations where offshore drilling is taking place, Area 

Contingency Plans need to be coordinated with 

BOEMRE and the worst case discharge assumptions need to include the potential for a well blow 

out.

It is to be hoped that lessons learned from the Deepwater Horizon response will result in more interaction between the Coast Guard, state, and local 

emergency management agencies, to bridge the 

gap between the NCP and the National Response 

Framework in the future.
6. Logistics

111

During the Deepwater Horizon response, 

most logistics requirements for response 

operations were provided by the Responsible Party (RP), BP, which had the necessary 

resources to identify, obtain, and deploy private 

Sector response capabilities. As the Federal OnScene Coordinator (FOSC), the Coast Guard 

secured resources from itself and other government 

agencies. RP logistics were overseen by Coast 

Guard personnel, but the RP used its own procurement, billing, and accounting practices. Much of 

the role of FOSC staff oversight was to ensure 

that the logistics needs of the response operation 

were met and suffi cient federal and state resources 

were provided and coordinated for the response.

The focus of this chapter is Coast Guard, federal, state, and local logistics. The response was 

a combined effort between the government and 

the RP. The RP made large-scale and signifi cant 

contributions to logistics, procuring much-needed 

resources, such as boom, skimmers, and decontamination equipment, and providing food, housing, and transportation for the more than 47,000 

response personnel. The RP also managed the 

logistics and fi nance of the Vessels of Opportunity (VOO) program.

6.1 Operational Logistics: Critical 

Resources (Boom, Skimmers, Beach 

Cleaning Equipment, Personnel)

Critical resources, specifi cally oil spill response 

skimmers and boom, were in high demand within the 

Deepwater Horizon area of operations. The Unifi ed 

Area Command (UAC) directed critical resources 

to respond to those areas most likely to experience 

an impact based on dynamic oil spill trajectories. 

The UAC aggressively pursued additional resource 

requests for skimmers from manufacturing sources, 

oil spill response organizations (OSROs), and potentially from international sources if the equipment and 

application was appropriate. The RP procurement 

system purchased skimmers from manufacturers and 

maintained ongoing research into skimmer purchasing. As of June 9, 2010, 592 skimmers remained 

within the Response Resource Inventory system 

(RRI) listed for Coast Guard District Eight (which 

includes New Orleans). Requests for additional protective measures outside those designated in the Area 

Contingency Plan (ACP) were considered against 

the regional demand for resources.

Nationally, the RRI captured response inventory 

held by OSROs. The movement of skimmers and 

boom held by OSROs throughout the nation could 

have impacted their ability to meet local contractual obligations with vessel and facility plan holders, and the regulatory requirements of both the 

federal and state governments. When examined 

to determine what inventory of response equipment was available, the inventory did not match 

reality. For example, some equipment listed was 

unserviceable, while other equipment was counted 

by more than one organization, and thus in places 

the same equipment appeared twice in inventories. 

Although the RRI is not intended as a real-time 

inventory, there was no other complete inventory tool available. This made determining what 

equipment was in fact available for deployment 

a challenge.

Nationally, 2,063 skimmers of various makes, 

models, and uses, approximately 431,574 feet of 

ocean boom, and over 3.1 million feet of nearcoastal boom are listed in the RRI and are, in part, 

supporting Vessel and Facility Response plan 

holder regulatory requirements for the remainder 

of the nation. The reallocation of these resources 

could impact the Marine Transportation System, 

commerce, and the donor region’s ability to comply with regulatory preparedness and response 

requirements.

This accumulation of data eventually led to the 

Resource Unit’s name change to the Critical 

Resource Unit (CRU). The CRU collaborated with 

LAFOURCHE PARISH, 

La. – Workers load “Dutch 

arms” onto an off shore 

supply vessel. The skimming 

system, purchased from 

Holland, includes infrared 

cameras that monitor 

the depth of the oil and a 

vacuum system to retrieve 

the oil. Photo courtesy of 

U.S. Coast Guard 
112

6. Logistics

an RP Vice President assigned to special projects, 

who reported directly to the RP Incident Command. The CRU’s primary function was to fi nd 

scarce resources and make them available to the 

response. Resources designated as critical included 

18-inch boom, ocean boom, specialized boom for 

use in in situ burn operations, dispersants, skimmers (both portable and vessel), and Coast Guard 

personnel.

The CRU was staffed by Coast Guard and 

Responsible Party personnel. The Logistics Section managed the two sections separately to allow 

the independent processes to run simultaneously 

without interfering or becoming interwoven.

Keeping in mind the large spill volumes and taking 

a long-term view, the RP 

contacted the company 

that produced one-half of 

the U.S. supply of snare 

boom on May 2, 2010. 

Working with company 

representatives and RP 

Purchasing Supply Chain 

Management, the RP 

procured $15 million of 

product within two hours 

of this call. The next call 

solidifi ed local oil boom 

production in Louisiana. 

Calls were placed to an oil 

spill equipment company, 

and again, the RP obtained 

production of 18-inch and 

42-inch boom.

The CRU then turned to 

beach oiling and modeled 12,000 miles of 

shoreline that was heavily oiled in fi ve states. In 

order to determine how 

much waste this would 

produce, The CRU contacted the creator of a 

waste calculator program for Emergency Prevention, Preparedness, and Response (EPPR), to create 

beach loading forecast models. These forecasts 

were used to obtain estimates and, on May 4, to 

assign waste management territories to Mobile 

and Houma Incident Command Posts (ICPs); the 

request for initiation was forwarded to the Florida operation. RP had master waste management 

contracts and the Florida request for initiation in 

place prior to the response effort.

During the procurement of critical resources, 

the CRU made compromises to ensure needed 

resources arrived in the fi eld with little delay. First, 

the CRU sourced and procured millions of feet 

of 18-inch spill boom. Boom fabric was in high 

demand and therefore scarce. The 18-inch boom 

is the largest boom that can be made with approximately 36-inch width raw material in stock. This 

allows for folding and welding in a width of material without waste. The fabrication of boom with a 

skirt longer than 18 inches required more material 

and added complexity to the process, increasing 

the overall production and order time. The larger 

booms, particularly the ocean boom, had longer 

manufacturing times and provided limited footage. 

Second, ocean-going Oil Spill Recovery Vessels 

(OSRVs) were also in high demand and scarce. 

Vessels with an extended range, which are stable 

in heavy weather, able to work the fresh oil at the 

spill locations, and follow weathered oil patches, 

were diffi cult to build within the time required 

to support the response. The CRU did pursue 

the procurement of smaller 28-foot OSRVs, and 

eventually 39 new-builds were supplied to the RP. 

These vessels were more limited operationally 

and used primarily for harbors or very sheltered 

weather areas.

To maximize use of available boom, ICP Mobile 

established a boom repair facility at Theodore, Ala. 

This facility was able to quickly repair thousands 

of feet of boom and return it to service, which 

reduced concerns about whether suffi cient boom 

was available, and reduced waste streams as well.

Another critical resource was beach cleanup equipment. The RP negotiated with local politicians 

regarding the footprint of the cleanup force and 

possible technological solutions. Over the course 

of a few weeks, several products were tested and 

a sand-sifting machine was found to be one of the 

best non-manual solutions to remove oil and tar 

mats from large areas of sandy beach. Excessive 

daytime heat, at around 100 degrees Fahrenheit, 

liquefi ed the oil and tar on the beach. To ensure the 

maximum effectiveness, operation of the machines 

were moved to night hours. The machines and 

manual beach cleaning methods, such as rakes 

and hand-sifting, required collaboration with area 

environmental specialists. The specialists helped 

ensure that sea turtle nesting and migrating patterns, 

VENICE, La. – A U.S. 

Coast Guard Petty Offi cer 

inspects snare boom on 

board a support barge. 

Photo courtesy of U.S. 

Coast Guard
6. Logistics

113

habitats for endangered species like the Alabama 

Beach Mouse, and protected sea oats and dunes 

were not damaged during cleanup operations.

The widespread mobilization of resources created a 

high demand signal for real-time resource information. The Coast Guard needed a common operating 

picture of available resources to understand and 

communicate the risks associated with strategic critical resource allocation decisions. The RRI system 

established and maintained the national resource 

picture through real-time tracking of domestic 

OSRO resources. The Coast Guard also used the 

RRI to identify critical and locate critical resources, 

evaluate OSRO cascade plans, and assess impacts 

to vessel and facility response plan holders.

At the time of the Deepwater Horizon spill, the 

RRI database recorded nearly 4.5 million feet of 

oil spill boom available. Slightly more than one 

million feet of this boom was located in the states 

that border the Gulf of Mexico. Oil Pollution Act 

of 1990 (OPA 90) OSRO requirements, private 

business interests, and the requirements of the 

One Gulf Plan identifi ed this level of boom as 

the proper amount.

During the Deepwater Horizon response, additional 

area-specifi c updates to the regional ACPs were put 

together by the ICPs in collaboration with local offi -

cials. The Unifi ed Area Command and the National 

Incident Command approved these updates, which 

increased the amount of boom utilized to protect 

environmentally and economically sensitive areas. 

These updates left RP Procurement Supply Chain 

Management and the Coast Guard CRU in need of 

approximately fi ve million feet of oil boom.

The CRU addressed the need for fi ve million feet 

of boom, required as a result of the mid-response 

re-evaluation of the ACPs through a calculated 

process that it later repeated for various items 

identifi ed as critical resources. The RP identifi ed, 

purchased, or rented, and relocated all the available 

large stockpiles of boom as necessary. Concurrently, the RP answered the boom production gap 

by contracting for new production with factories 

in the United States and China. The RP developed 

a boom specifi cation and sent technical experts to 

the fi eld to enforce it and to determine how companies could increase production. Additionally, the 

RP dealt with the shortage of boom components 

such as galvanized chain, fabric, and connectors. 

The CRU had the most diffi cultly obtaining heavyduty neoprene rubber ocean boom. This large 

ocean boom had long delivery times and, after 

sourcing the world’s supply, there was no back 

supply available in the quantity and time needed 

to support the response.

The CRU worked with the RP to fi ll the demand 

for equipment resources. The demand to source 

and procure equipment and resources was operationally, politically, and vendor-driven. Within 

the operations sections of the ICPs in Houma and 

Mobile, critical resources such as boom, skimmers, 

and dispersants were in high demand, and the CRU 

was responsible for sourcing and supplying staging 

sites to provide this equipment to the ICPs.

The second component of the Logistics CRU was 

comprised of members responsible for processing 

and ordering of all Coast Guard personnel for the 

response. In response to the Deepwater Horizon

oil spill, the Coast Guard deployed thousands of 

its members to the Gulf Coast to provide response 

support to the FOSC. This included the Coast 

Guard’s National Strike Force (NSF).

FOSC Key Points: Inventory of Response 

Equipment

The National Response Resources Inventory maintained by the National Strike Force Coordination 

Center, was not intended to function as real-time 

tracking tool spill response equipment nor was 

it particularly effective in performing this role. 

Rather, it was a source against which Oil Spill 

Removal Organization (OSRO) classifi cations 

can be validated. An inventory of available spill 

response resources, ready for deployment, should 

be available and accessible to FOSCs. This should 

extend beyond what is in a specifi c vessel or facility’s response plan and include trained personnel 

PANAMA CITY, Fla. – Workers load 12,000 feet of ocean boom onto a 

vessel. Photo courtesy of U.S. Coast Guard
114

6. Logistics

and physical equipment. If a measure of excess 

inventory for a long-term spill, or multiple spills, 

had been available, it would have been useful during the Deepwater Horizon response.

6.2 Operational Logistics: International 

Notifi cation, Cooperation, and the 

Jones Act

In The Federal Response to Hurricane Katrina: 

Lessons Learned, the Department of Homeland 

Security acknowledged that the United States lacks 

the capability and infrastructure to prioritize and 

integrate a large quantity of offers of international assistance into an ongoing response. The 

U.S. Coast Guard experienced the same shortfall 

following during Deepwater Horizon oil spill. 

Throughout the post-casualty response, the international community showed an outpouring of 

support to the United States. The hundreds of international offers of assistance spanned a large spectrum. Offers included high-capacity oil recovery 

equipment to specialized technology and experts 

in the fi eld of oil spill response mitigation. Countries made offers via several lines of communication—some offers came directly to the National 

Incident Commander through the U.S. Department 

of State, and others through personal connections 

within the international response community. The 

National Incident Command (NIC) staff and DOS 

held regular meetings with the Unifi ed Area Command Critical Resources Unit to evaluate the critical resource needs and determine if the offers of 

assistance could fulfi ll these needs. As the spill 

response effort progressed, critical resource needs 

were constantly re-evaluated based on factors such 

as changing weather conditions, updated response 

mitigation plans, and migration of the oil.

Despite the efforts to catalog, evaluate, and prioritize the foreign offers, the Coast Guard was 

not able to accept or decline offers of assistance 

with certainty. For example, during the response 

there was a perception that there was not enough 

oil containment boom deployed to protect the 

beaches and marshes, and keep oil from reaching 

the shore. That perception was incorrect. However, to overcome that perception and ensure there 

was ample boom available to responders, the RP 

purchased a large amount oil containment boom. 

Many expressed concern that there was an obvious 

need for boom, but the FOSC was not accepting 

all international offers. However, there are many 

different types of oil containment boom suited for 

use in different marine environments. Many of the 

international offers of boom were not the appropriate type or quantity needed to satisfy the needs of 

the response. This message to the public was lost, 

as the hunt for more containment boom drowned 

out the details of what was being offered compared 

to what the response requirements entailed.

During the initial response, neither the necessary 

infrastructure nor the chain of command existed 

to catalog offers, vet them for accuracy, and match 

offers with the lists of identifi ed critical needs. In 

addition to the spontaneous outpouring of offers, 

the NIC sought additional resources through a 

request to DOS to work with each country desk 

at DOS and each embassy to determine what, if 

any, international resources were available.

The NIC evaluated the current domestic supply 

of response equipment, identifi ed specifi c equipment gaps, such as high-capacity skimmers and 

fi re boom, and requested to have the gaps fi lled by 

the international community. However, the requests 

made through each country desk or embassy did not 

GRAND ISLE, La. – A group of international representatives 

from various agencies visited sites aff ected by the Deepwater 

Horizon spill. Representatives included members of the 

Canadian, Swedish, and Irish Coast Guards. Photo courtesy 

of U.S. Coast Guard
6. Logistics

115

clarify the format for offers or the information that 

countries offering equipment needed to provide to 

enable a successful transaction. Offers of assistance 

were received in various formats. These included 

emails and letters, which sometimes lacked the 

required information. As a result, the evaluation of 

offers took a signifi cant amount of time and numerous back-and-forth communications to obtain the 

necessary information to activate the movement of 

equipment, and to reimburse the offering country. 

DOS identifi ed two representatives through which 

the NIC could communicate to other countries, and 

these representatives contacted each country desk 

or embassy to clarify offers and to ask questions.

Offers came in through different channels, including 

DOS, congress members, the NIC or FOSC, and 

the RP. This resulted in governments and companies receiving confl icting and confusing responses 

regarding the status of their offers. It also created 

a public perception that the United States was not 

taking full advantage of the offers, even though the 

response effort considered and evaluated all offers.

A third challenge was the different criteria and 

data collection methods used by the FOSC and 

DOS to determine the type of offer. Offers could 

be government-to-government, government-facilitated, or private. The FOSC determined that a 

government-to-government offer meant the country 

offering the equipment also owned the equipment. 

A government-facilitated offer occurred when a 

country, usually via its embassy, facilitated an offer 

of a privately owned piece of equipment. A private offer came directly from a private vendor in 

a foreign country. It was necessary to determine if 

an offer was government-to-government because 

the NIC pledged to accept all international offers 

of assistance, allowing the UAC to purchase the 

equipment without jeopardizing existing domestic 

contracts or violating Jones Act requirements. The 

government-facilitated offers presented a signifi cant 

challenge, as sometimes these offers were actually 

government-to-government. The U.S. government 

had to determine the true originator of the offer, 

identify the product, and then properly classify it.

Some countries offered privately owned equipment 

through the conduit of government, which created 

some confusion and delay concerning documentation and prioritization. Once the UAC vetted international offers and determined the offer would fi ll 

a critical resource gap, the CRU worked with the 

RP’s purchasing offi cials to purchase and transport 

the items to the desired response area. The NIC 

and DOS worked jointly to provide administrative 

support by communicating to the embassy of the 

offering country and developing diplomatic notes 

on a case-by-case basis. This facilitated acceptance 

and delivery of desired resources to the FOSC.

The fi rst step in this process was the CRU receipt 

of international offers of assistance from DOS. 

Once received and vetted, the offer was classifi ed as a government-to-government, governmentfacilitated, or private offer, and then conveyed to 

the UAC. The UAC pursued each accepted offer 

through direct purchasing or through RP’s commercial procurement process. The NIC provided a 

letter to the DOS for distribution to each country 

desk or embassy to close the offer.

The NIC and DOS agreed that a database for tracking the offers would be owned and maintained 

by the NIC. DOS would provide daily feedback 

through a daily conference with members of the 

NIC CRU and DOS. This arrangement improved 

the accuracy of new international offers that were 

arriving daily until the oil well was capped.

The database did not clarify the status of existing 

offers with each country desk or embassy. This 

situation required meetings with points of contact 

from DOS to rectify. Once the database improved, 

the letters acknowledging the offers, accepting the 

offers, or referring the offers required attention.

The accuracy of the offers still proved burdensome during the letter generating process due to the 

political sensitivity of the verbiage contained in the 

letters. To resolve this diffi culty, each country desk 

NEW ORLEANS – The 

Icelandic Coast Guard 

contributed a Bombardier 

Dash 8 fi xed-wing aircraft 

to serve as command and 

control platform, and oil 

spotting resource as part 

of the Deepwater Horizon

response. Photo Courtesy 

of Icelandic Coast Guard 
116

6. Logistics

at DOS verifi ed points of contact and addresses 

to ensure the UAC acknowledged or notifi ed the 

proper individuals.

The fi nal step in this process was the acceptance 

and coordination of delivery of the equipment, 

which proved challenging due to tracking of offers, 

and understanding what equipment was physically 

available. An example of this diffi culty was the 

procurement of foreign fi re boom—the fi re boom 

was offered very early in the process, prior to NIC 

or DOS organizing the initial database. The UAC 

procured and utilized the boom before the acceptance letter process was instituted. This confused 

all parties as to understanding what equipment was 

still available. Overall, the process of tracking the 

offers, clarifying the offer content, and acknowledging offers in writing provided numerous opportunities to improve effi ciency and accuracy for 

future response evolutions.

Due to the magnitude and nature of the spill, all 

aspects of the response effort received signifi -

cant media attention. The process challenges in 

receiving international offers were not suffi ciently 

articulated to the media, which only noted delays 

in accepting the international offers of assistance.

Jones Act, Clarifi ed

Known as the Jones Act, the Merchant Marine 

Act of 1920 (46 U.S.C. 55102) provides that the 

transportation of merchandise (broadly interpreted) 

between U.S. points is reserved for U.S. built, 

owned, and documented vessels. Pursuant to section 55102, “A vessel may not provide any part 

of the transportation of merchandise by water, or 

by land and water, between points in the United 

States to which the coastwise laws apply, either 

directly or via a foreign port, unless the vessel (1) 

is wholly owned by citizens of the United States 

for purposes of engaging in the coastwise trade; 

and (2) has been issued a certifi cate of documentation with a coastwise endorsement under chapter 

121 of Title 46 or is exempt from documentation 

but would otherwise be eligible for such a certifi -

cate and endorsement.” Consequently, foreign-fl ag 

vessels are prohibited from engaging in the coastwise trade—transporting merchandise between 

U.S. coastwise points. In addition, the same prohibitions apply to U.S. fl ag vessels that do not have 

a coastwise endorsement on their document, i.e., 

those that are not coastwise qualifi ed.

Although there was signifi cant media and some 

congressional interest in the Jones Act during the 

Deepwater Horizon response, at no time did compliance with the Jones Act actually impede the 

response operations by the FOSC or the RP. This 

was due in large part to the fact that most of the 

foreign-fl agged vessels did not actually engage 

in Jones Act covered activities. The threshold 

determination of whether or not a vessel activity 

is covered by the Jones Act is made by Customs 

and Border Protection (CBP), which has direct 

responsibility for enforcing the Jones Act. The 

Coast Guard worked closely with CBP and the 

Maritime Administration (MARAD) to process 

requests for waivers of the Jones Act with the Secretary of the Department of Homeland Security, 

who granted seven limited waivers.

There were three primary activities where questions about applicability of the Jones Act came 

to the attention of the FOSC. The fi rst was with 

vessels transporting equipment and supplies to 

the response sites, and the movement of response 

equipment on the sea fl oor. Concerns over foreign 

fl agged vessel participation in those activities were 

resolved by consulting CBP. The second was with 

vessels collecting oil from the water utilizing skimming or other equipment. CBP’s position was that 

oil collected from the water beyond three nautical 

miles from the baseline did not constitute a Jones 

Act regulated activity. Therefore, a foreign-fl agged 

vessel engaged in skimming operations beyond 

three nautical miles could collect oil or oiled 

seaweed and then transit to a point in the United 

States and discharge without need of a waiver or 

exemption.

The third activity related to recovery of oil from 

the wellhead’s riser after installation of the containment dome. CBP considered the Deepwater 

Horizon wellhead to be a point or place in the 

United States. However, foreign-fl agged vessels 

were working to process and temporarily store 

the oil and gas from the containment dome on top 

of the well as efforts to plug the well continued. 

To comply with the Jones Act, the oil was then 

transferred from the storage tankers to coastwise 

eligible tank ships to carry it into the United States. 

Nevertheless, there was concern about the potential 

impact of severe weather on these transfer operations, which led to a request for a limited waiver 

of the Jones Act.
6. Logistics

117

In addition, 46 U.S.C. 55113 authorizes the use of 

foreign-fl agged Oil Spill Response Vessels if the 

Federal On-Scene Command fi nds that an adequate 

number and type of U.S. fl agged OSRVs cannot 

be engaged to recover oil in a timely manner, and 

the foreign vessel’s fl ag state extends U.S. fl agged 

vessels the same privilege under similar circumstances. The FOSC issued a fi nding that there was 

a need for additional dedicated skimming vessels 

for the response, and the Coast Guard, MARAD, 

the U.S. Department of State (DOS), and the 

Environmental Protection Agency entered into a 

memorandum of understanding (MOU) to implement this exemption statute. All federal agencies 

involved worked together to support the FOSC in 

making Jones Act determinations and facilitate the 

few granted Jones Act waivers.

The FOSC, National Incident Commander, and 

CBP received several inquiries from individuals 

interested in obtaining a Jones Act waiver in hopes 

of making their vessels more attractive to the RP 

as a contract option. However, only seven limited 

waivers were actually required for this response. 

Under 46 U.S.C. 50, the Secretary of DHS may 

grant a waiver from the Jones Act when necessary 

for national defense. As mentioned before, the 

Coast Guard, MARAD, and CBP have an MOU 

that addressed each agency’s responsibility to 

advise the Secretary on such a waiver request. 

Although any interested party inside or outside 

the government can initiate a waiver request, there 

must be a genuine operational need for the vessel 

as part of the response, in order to justify a favorable endorsement by the FOSC. The FOSC coordinated this endorsement with CBP and MARAD. 

In making that determination, the FOSC evaluated 

the unique characteristics and capabilities of the 

foreign fl agged vessel compared to what was available in the U.S fl eet and the potential impacts of 

a delay in operation caused by waiting for a U.S. 

vessel to become available.

On June 29, 2010, the Secretary of DHS granted 

six limited waivers for the MODU Discover 

Enterprise, Toises Pisces, FPSO Seillean, Loch 

Rannoch, Evi Knutsen Navion Fennia, and Helix 

Producer I. These vessels were engaged in recovery and temporary on-scene storage of oil from the 

Deepwater Horizon oil well via the containment 

dome while efforts to plug the well continued. 

These waivers enabled the vessels either to transfer the oil to a U.S. port themselves or to transfer 

the oil to a U.S. vessel that would then carry the 

oil to a U.S. port. Although there were coastwiseendorsed vessels that could receive recovered oil 

from the containment system, use of such vessels 

would have substantially reduced the recovery 

of discharged oil. Moreover, the vessels would 

have led to substantial increases of discharged oil 

entering the Gulf of Mexico—reducing operational 

safety and substantially increasing environmental 

and economic damages from this disaster. The U.S. 

cancelled the waivers after the well was plugged.

Input from MARAD and the DOS aided the determination for the waivers. MARAD provided the 

availability of U.S. fl agged vessels to perform the 

same mission, and DOS determined whether the 

vessel’s fl ag state permitted reciprocity under similar circumstances. Exemptions were temporary.

The FOSC, in coordination with other federal 

agencies, determined on June 16, that there was 

an insuffi cient number of specialized oil skimming vessels in the U.S. to keep pace with the 

unprecedented levels of oil discharges in the Gulf 

of Mexico. This satisfi ed the fi rst conditional statutory requirement in 46 U.S.C. 55113. Based upon 

this determination, foreign specialized skimming 

vessels could be deployed to response operations 

if the foreign country provided the same privileges to U.S. vessels. The use of such vessels under 

these circumstances did not violate the Jones Act 

or require a Jones Act waiver.

The FOSC makes the ultimate determination 

if an OSRV is exempt from the Jones Act. If 

the FOSC determines an exemption is needed, 

MARAD provides information on the availability of U.S.-fl agged vessels to perform this same 

GULF OF MEXICO – Gas 

from the Deepwater 

Horizon wellhead is 

burned by the drillship 

Discover Enterprise. 

Photo courtesy of U.S. 

Coast Guard 
118

6. Logistics

mission. Further, the DOS facilitates the determination of whether the vessel’s fl ag state accords 

U.S. vessels the same privileges under reciprocal 

circumstances.

Over the course of the Deepwater Horizon

response, the FOSC twice applied the OSRV 

exemption contained in 46 U.S.C. 55113. The 

fi rst instance occurred on June 19, 2010, when 

the FOSC approved the use of three classes of 

vessels manufactured by a French company. This 

approval was founded on the June 16, 2010, FOSC 

determination, the vessels’ special design and purpose for recovering fl oating oil, and confi rmation 

from DOS that France extends similar privileges 

to the United States.

The second application of the OSRV exemption 

took place on June 27, 2010, when the FOSC 

approved the use of the Burrard Cleaner No. 1, a 

Canadian vessel. As with the French vessels, the 

FOSC’s approval of the Burrard Cleaner No. 1

was based on the June 16determination, the special 

design of Burrard Cleaner No. 1 for recovering 

fl oating oil, and the reciprocal privilege Canada 

offers to U.S. vessels. Because these exemptions 

were granted contemporaneously with the development of the MOU, they were granted for a period 

longer than 90 days.

6.3 Operational Logistics: Vessels of 

Opportunity

The RP established the Vessels of Opportunity 

program to develop a core fl eet of local professional mariners who could best perform the diverse 

skill set required for the response. The requisite 

skills included: 

• On-water oil recovery and removal operations, 

• Boom deployment and tending, 

• Wildlife recovery, 

• Sub-sea surveillance and monitoring, 

• In situ burning, and 

• Logistical support while capitalizing on local 

knowledge and professional seamanship. 

The program also had the incidental benefi t of 

providing economic compensation for mariners 

whose livelihoods were impacted by the spill. 

The program applied the lessons learned from the 

Exxon Valdez oil spill and the many spills thereafter where commercial vessels were used to assist 

with the response.

Throughout the response, more than 9,000 vessels—a fl eet larger than the Allied landing force in 

D-Day during World War II and nearly three times 

the number of boats in the U.S. Coast Guard—were 

contracted by the RP as VOO. This overwhelming 

participation in the program created a diverse and 

complex landscape for VOO operational employment and oversight due to disparity in vessel size, 

sea-going abilities, communications capabilities, 

crew experience, and language barriers. Despite 

the RP serving as the contracting entity, the UAC, 

overseen by the Coast Guard, played a key role 

in the VOO employment. The FOSC and Coast 

Guard Incident Commanders (IC) were responsible 

for optimizing the employment of this diverse fl eet 

in concert with the RP.

In the fi rst weeks of the response, each ICP administered VOO employment. A number of factors 

presented a challenge to the establishment of the 

VOO program. First, there were no prior protocols 

for constructing a VOO program in the Gulf of 

Mexico. Initial decisions focused on the vessel 

types, the levels of crew capability and training, 

and the geographic assignment of each. As the ICP 

made these decisions, the VOO fl eets expanded to 

include fi shing vessels, charter boats, recreation 

BAYOU LA BATRE, Ala. – 

A line of shrimp boats 

serving as Vessels of 

Opportunity return to 

Bayou La Batre after 

a shift change. Photo 

courtesy of U.S. Coast 

Guard 
6. Logistics

119

boats, and other work boats. The UAC assigned 

VOO to support the full range of offshore, nearshore, and protected water task forces.

Next, many local boat owners were skeptical of 

the program and as such, did not immediately 

enroll. Some were concerned that the RP contract for hire would result in the waiver of rights 

of the boat owners to seek compensation for lost 

income or other economic damages. The owners 

also expressed concern they would be forced to 

indemnify the RP for damages caused by latter’s 

activities while operating within the scope of the 

VOO program. Public education and outreach, 

especially through angler and charter boat associations, eventually calmed these concerns.

As the program gained momentum, the inclusion 

of pleasure boats started to create tension. The 

public also raised concerns about the employment 

of out-of-state boats. The favorable rates for VOO 

service quickly became a magnet for boat owners, 

with the commercial operators seeking primacy for 

hire in view of lost revenue from their livelihoods. 

The use of pleasure boats was challenged because 

those boaters suffered no direct loss from the spill. 

Challengers viewed out-of-state boats as interlopers. Rotation between the VOO concerning onand off-hire status was equally acute, especially 

considering the prevailing economic conditions. 

The result was that the VOO program was slow to 

mature, but expanded greatly to the point where the 

ICPs had to cease additional enrollments. There 

was an odd consequence of the breadth of the VOO 

program and its opportunity to offset economic 

loss through the rates paid by the RP: the program 

created a disincentive for some VOO operators to 

return to their normal lines of business.

To address issues of pleasure boats, out-of-state 

boats, and rotations for hire, ICPs engaged local 

communities to assist in developing the program 

to ensure fairness and local ownership. A trusted 

community representative from the local commercial fi shing or charter boat community was 

essential to ensuring integrity, equity, and validity 

to the program. As the response progressed and 

enrollment and rotation processes were established, the ICPs transitioned tactical VOO command and control to the Branch level.

With the fi rst observations of oil making landfall in 

June 2010, media reports of VOO not being meaningfully employed (or not employed at all) created 

extensive external scrutiny of the program. While 

locally coordinated operations are a cornerstone 

of the Incident Command System, the decentralized oversight of the VOO program hampered the 

FOSC’s ability to provide a consistent, consolidated report of VOO operations to governmental 

offi cials. This was due primarily to ICPs Houma 

and Mobile using different defi nitions and criteria 

for daily VOO reporting. Additionally, on several 

occasions, the inability of a federal, state, or local 

offi cial to establish radio contact with a VOO while 

fl ying over an area fueled perceptions that there 

was inadequate federal command and control of 

the response efforts.

Coast Guard and RP personnel representing ICP 

Houma, ICP Mobile, and the UAC completed an 

extensive analysis of VOO operations. This analysis resulted in the FOSC and RP signing a VOO 

policy on July 2, 2010. In this policy, the FOSC 

and RP outlined the strategy for standardized 

concepts of VOO usage throughout the response, 

the appropriate organizational structure, required 

training and safety measures, and contractual and 

logistical requirements.

The VOO policy stated the number, or fl eet size, 

and type, or capability, of VOO based upon the 

operational requirements established by the Incident Commander and determined at the Branch 

level during daily tactics meetings. Each Branch 

maintained an inventory of available VOO and 

capabilities using a standard database to build 

an inventory of available vessels. Once the 

operational tasking was determined, the ICS-215 

PENSACOLA PASS, Fla. – 

Two Vessels of 

Opportunity work with 

sorbent boom to collect oil 

four miles off Pensacola 

Pass. Photo courtesy of 

U.S. Coast Guard
120

6. Logistics

requested daily VOO mobilization and assigned 

vessels from the Branch inventory. Once activated, 

the Branch assigned vessels to a standard VOO 

taskforces architecture model used throughout the 

response for duration of the vessel’s employment.

The fi rst step was standardization of the VOO Command and Control structure. In the fi eld, promulgation of the standard Branch, Task Force (TF), and 

Strike Team (ST) organization was the critical step 

to improving command and control of the VOO 

fl eet. Specifi cally, a Branch would have command 

of three to seven VOO TF; each TF would lead 

three to seven ST with a designated lead vessel; and 

each ST would direct three to seven vessels with a 

designated lead vessel (see Figure 6.1).

This structure provided an easily understood 

arrangement to inform vessel operators how they 

fi t into the organization and to whom to report. It 

formalized leadership roles and provided a clear 

path for tasking to be passed from the Branch command to each vessel in the organization via the 

TF and ST leaders. Additionally, as many VOO 

operators were non-military personnel, having a 

common lexicon and organization structure was 

critical to allowing personnel outside of the UAC 

organization to understand VOO employment.

In guiding the Branch in mobilizing VOO, the 

UAC policy provided several biases: 

1. A preference for local vessels, 

2. A preference for commercial and charter fi shing vessels (only using recreational vessels as 

an exception), 

3. A preference for operator owned vessels, 

4. Use of a vessel rotation, and 

5. Activation limited to one vessel per owner.

As an exception to this guidance, the UAC agreed 

to allow the parishes of Jefferson and Plaquemines 

to maintain a fl eet of vessels for cleanup. The parish 

presidents oversaw these fl eets for the duration of 

the response.

The UAC and ICPs encountered several problems 

related to the VOO program. The fi rst was command 

and control challenges regarding VOO employment. Specifi cally, many of the VOO operators were 

accustomed to operating independently, and not in 

a structured task force. Each ICP Branch addressed 

VOO command and control separately, which was 

necessary because of the varying demographics and 

areas of operation of the fl eets. For example, the 

VOO fl eet in Louisiana comprised primarily commercial fi shing vessels. In Mississippi, ICP Mobile 

established a separate VOO Branch, which was 

jointly managed by the ICP and the Mississippi 

National Guard. This arrangement coordinated tactical employment and integrated VOO operations 

with National Guard over fl ights.

Communications issues with the VOO also arose 

during the Deepwater Horizon response. The VOO 

Master Vessel Charter Agreement, which is the contract signed between the RP and the vessel owner, 

stated that the each VOO have at least one VHFFM marine radio. Additionally, each VOO could be 

required to conduct hourly communications with 

the assigned TF leader and designated dispatcher. 

However, the RP did not enforce this requirement.

Figure 6.1: VOO Command and Control Structure
6. Logistics

121

Language barriers with VOO operators also hampered communications. Many commercial vessel 

operators in the Gulf region are native Vietnamese, 

Spanish, and Khmer speakers; English is their second language, if spoken at all. The RP overcame 

the language barrier by ensuring all lead vessels 

had English and bilingual speakers.

The use of ICS communications plans was reinforced for each VOO organization and supporting 

aircraft. The RP emphasized that communication 

would occur between aircraft and TF and ST leaders, who in turn would pass relevant information 

to VOO.

The large and variable number of VOO under contract on a daily basis resulted in supervision and 

direction overhead. The breadth and scope of the 

VOO program, in terms of numbers and geographic 

dispersion, created serious logistical challenges to 

outfi t VOO, arrange waste disposal, and ensure integration of the VOO fl eet into the common operating 

picture. It was also diffi cult to track such a high 

number of VOO—the response used these resources 

before they contained fully employed technological 

tracking solutions for VOO.

The policy mandated that TF and ST lead vessels 

be equipped with a tracking device, preferably 

Automatic Identifi cation System (AIS), to support 

the communications fl ow. Additionally, the use of 

these devices allowed for the monitoring of VOO 

activities and employment locations through the 

provision of a common operating picture available 

to the public via the Internet. The Coast Guard 

considered requiring all VOO to be outfi tted with 

a Class A or B AIS device, but this was not implemented because it would have been impractical to 

install on some VOO and could have overloaded 

the National AIS infrastructure with thousands of 

devices in a small area.

For accountability purposes, many small VOO 

conducting daily voyages received Radio Frequency Identifi cation badges. Using a check-in 

and check-out process, shoreside personnel used 

laptops connected to a VOO database to log both 

vessels and personnel on-hire daily.

Despite these efforts, there was still a need for an 

on-water federal presence, particularly in the nearshore environment. The Coast Guard accomplished 

this using Coast Guard patrol boats, Coast Guard 

liaisons, and National Guard personnel, who rode 

on TF or ST leader vessels.

Table 6.1, promulgated in the UAC VOO policy, 

refl ects the expected employment based upon 

general vessel capabilities and operating environments. It was developed based upon the actual 

operational employment of VOO during the fi rst 

two months of the spill.

Oil Spill Removal Organizations are required by 

facility and vessel response plan regulations to 

maintain oil spill response equipment to address 

Table 6.1: 

Expected VOO 

Employment

<30

Vessel Size (ft)

30-45 45-65 >65

Zone

Well-Site - Within 5 nm of Deepwater Horizon - - Yes Yes

Off shore - Greater than 3 nm of the maritime baseline out to the 

well

- Yes Yes Yes

Near-shore - Within 3 nm of the maritime baseline Yes Yes Yes Yes

Inshore - Waters inside the maritime baseline (includes beaches, 

marshes, and estuaries.)

Yes Yes - -

Shallow - Less than 6 ft of water Yes - - -

Response 

Activity

Boom Deployment - - Yes Yes

Boom Tending and Maintenance Yes Yes - -

Skimming Operations (trawling containment boom) - - Yes Yes

Sheen, Light Oil Recovery, Tar Ball Recovery Yes Yes - -

Removal of Oily Waste (sorbent boom and pads) Yes Yes Yes Yes

Decontamination Support Yes Yes Yes -

Transportation and Supplies Yes Yes Yes Yes

Transportation and Personnel or Wildlife Yes Yes - -
122

6. Logistics

worst-case discharges from either source. The 

Deepwater Horizon oil spill was so large in scope 

and duration that it outgrew the capability built 

by these regulations, both locally and nationally. 

The VOO successfully complemented and sometimes supplemented OSRO capabilities. Offshore, 

OSROs provided all deep water skimming vessels. VOO did not have the offshore oil recovery 

effi ciency or capacity to be effective at the source. 

Some VOO towed fi re boom to facilitate in situ 

burning operations, which freed other OSRO vessels for more critical source skimming operations.

Closer to shore and within the bays and marshes, 

VOO chased and recovered streamers of oil, and 

tar balls and tar mats before they impacted the 

shoreline. Additionally, VOO transported shoreline 

cleanup workers, placed and tended boom, and 

provided general response support to keep operations moving. VOO offered the advantage of shallow water capacity and maneuverability in areas 

that were confi ned or diffi cult to access by larger 

OSRO vessels. Using VOO operators who had 

local knowledge helped pre-identify natural collection points where the oil was likely to impact, and 

where to place protection and collection measures.

The Master Charter Agreement between the RP 

and the vessel owner outlined general VOO logistical procedures such as oily waste removal and 

replenishment of oil removal supplies. Additionally, the agreement outlined minimum staffi ng and 

communications requirements. For every mission, 

operators were required to provide assurance that 

all personnel aboard the VOO were physically 

able to complete ordinary and emergency response 

shipboard functions such as movement on slippery 

decks, standing watch, fi refi ghting, and abandoning ship. The VOO operator was responsible for 

ensuring that all personnel on VOO duties while 

under contract with the RP were alcohol and drug 

free. Each VOO was also required to have passed a 

Coast Guard vessel safety examination at the dock.

VOO crewmembers were required to complete 

a spill-specifi c, Occupational Safety and Health 

Administration (OSHA) approved, four-hour 

Worker Safety Training Course titled RP MC 252, 

Module 3 Marine. If a VOO was to come in direct 

contact with oil, OSHA required at least one person 

on board to have completed the 40-hour Hazardous Waste Operations and Emergency Response 

(HAZWOPER) training.

All personnel aboard VOO were required to 

wear appropriate personal protective equipment 

provided by the RP, as prescribed by safety professionals based upon the operations conducted. 

VOO operators were required to adhere to UAC 

heat stress, fatigue management, and inclement 

weather policies.

As the need for VOO diminished when there was 

no recoverable oil, the rather generous daily reimbursement scheme provided by the RP served as 

a disincentive for VOO to return to their normal 

operations, i.e., commercial fi shing, even after 

fi sheries waters were reopened.

RIGOLETS, La. – A Vessels 

of Opportunity skimmer 

makes its way up and 

down the Rigolets to 

capture any stray tar balls. 

Photo courtesy of U.S. 

Coast Guard
6. Logistics

123

6.4 Operational Logistics: Aviation 

Operations and Airspace Safety

The Aviation Coordination Center (ACC) was a 

key component in the safety of the federal response 

to the Deepwater Horizon oil spill incident. It 

established immediate order among disparate 

aviation interests within the airspace of the Gulf 

of Mexico. It also increased the effectiveness and 

effi ciency of diverse aviation response operations. 

The ACC was unique in leveraging specialty skills 

and resources of the U.S. Air Force, and effectively 

aligning interagency representatives in a functional 

management process.

The ACC was an operational element of the Unifi ed Area Command, responsible for regional 

management of aviation operations. The ICPs in 

Houma and Mobile established the priorities and 

aircraft tasking through the aircraft branch of the 

Operations Sections and set out in the Incident 

Action Plans. The Aviation Coordination Center 

then used the prioritization set out in the IAPs to 

manage and deconfl ict the airspace. Coast Guard 

and Air Force personnel jointly staffed the ACC, 

along with a cadre of interagency representatives 

from participating response agencies. Establishing a centralized organization of experienced and 

appropriately equipped planners and decision 

makers was a natural evolution as air activities 

expanded beyond the span of control of individual 

Incident Commands.

The Air Boss in the Operations 

Section of the Incident Command in Houma, La., had the 

initial responsibility for managing aviation activities during the 

fi rst 5 weeks of the spill response. 

This included scheduling, support, 

post-fl ight information assimilation, and future aviation resource 

requests. ICP Mobile was satisfi ed with this arrangement, but 

safety concerns soon emerged 

as the number and frequency of 

fl ights across ICP borders quickly 

exceeded the capability to monitor them. Fixed and rotary winged 

aircraft were congested near the 

well site and a number of other areas outside of 

radar coverage and ICP control. At the same time, 

spotting and dispersant application fl ights were 

increasing in number. The FAA implemented a 

temporary fl ight restriction (TFR) near the well, 

and a P-3 aircraft from CBP was enlisted to monitor offshore fl ights and relay track data to the Federal Aviation Administration (FAA).

Near-shore fl ights, in contrast, remained a safety 

concern. CBP also contributed a remote terminal 

for radar information from its Air and Marine Center (AMOC) that enhanced situational awareness 

for the Air Boss at Houma. However, increasing 

mission challenges persisted, and the migration of 

air operations toward the shorelines quickly warranted a more robust organization. Daily missions 

exceeded 200, often involving numerous individual 

sorties, and there were nine near mid-air collisions 

reported. Incident Commanders also needed better, 

faster, and more effi cient imagery fusion.

The ACC was established to remove confl ict among 

all air traffi c in the northern Gulf of Mexico during activities associated with Deepwater Horizon

operations and private interests. The ACC Charter 

clearly outlined its goal of providing safe, effective, 

and timely control of airspace. The ACC managed 

a wide range of aviation support missions. Command and Control, oil detection, skimmer spotting, 

dispersant sprayers, boom placement, beach patrols, 

environmental impact assessment, transportation, 

and public affairs were common categories of 

aviation sorties in support of response operations. 

These missions had to be executed safely across two 

ICP boundaries, and integrated with commercial 

ST. PETERSBURG, Fla. – A U.S. Coast Guard Petty Offi cer 

observes the Gulf waters from a C-130 out of Coast Guard Air 

Station Clearwater, Fla. Photo courtesy of U.S. Coast Guard
124

6. Logistics

carriers, fi sheries fl ights, military operations, media 

sorties, private aircraft, and other non-participants 

with access to the airspace.

Airspace management, offshore and along the 

coasts, was a paramount challenge. It required 

a governance process for territorial airspace that 

was partially served by radar coverage, and uncontrolled international airspace in which separation 

was dependent on a pilot’s ability to see and avoid 

other aircraft. It also involved a wide variety of 

competing interests between government, commercial, and private operators, and each ICP.

Large numbers of disparate air assets exacerbated 

these challenges. For example, small single engine 

helicopters used for spotting oil and vectoring 

skimming vessels were very diffi cult to detect 

from larger and faster fi xed wing aircraft, using 

sensors to collect imagery in the same airspace. 

These aircraft were also typically using different radio frequencies and unaware of each other. 

Therefore coordination instructions had to be 

generally applicable to all federal, state, and local 

responders. This involved accommodating different sizes, speeds, endurances, operational altitudes, 

communications capabilities, fuel requirements, 

and utilization standards, as well as runway and 

hangar requirements. Other management challenges included differences between military and 

civilian aviation cultures, unique priorities of 

individual states, differing authorities, business 

cultures and priorities, measures of effectiveness, 

curious media, and members of the public.

Effectiveness and effi ciency were also important 

objectives. Aviation support is inherently expensive, and a successful federal effort mandated 

thoughtful stewardship of response aircraft and 

aircrews. The ACC provided ready aircraft and 

sensor expertise to match resources and missions. 

Aircraft and sensor specialists were especially 

skilled at employing large fi xed wing assets with 

infrared capabilities in the pre-dawn hours, to aid 

effi cient placement of aircraft spotters at sunrise.

The ACC also ensured alignment of air tasking 

with surface operations. Information gathered by 

aircraft at night was the basis for pre-dawn tasking 

for surface assets and shore teams. Imagery collection was extremely important in fi nding actionable 

oil for skimming and in situ burning, and maximizing the capabilities of on-scene assets, which 

were key priorities of the Unifi ed Area Command. 

Air support was continuously adapted to support 

large skimmers near the source, collecting as much 

crude oil as possible, or task forces of smaller 

skimmers keeping oil away from barrier islands, 

beaches, and entrances to bays, rivers, and harbors.

Aviation management began with a Temporary 

Flight Restriction (TFR) for the offshore airspace 

in which surveillance and response operations were 

being conducted. Notices to Airmen (NOTAMs) 

were also issued with compulsory instructions for 

all, participating and non-participating aircraft 

operating along the Gulf Coast and close inshore. 

The ACC reached out to state, commercial, and 

other public operators to garner support and negotiate special arrangements. They then employed a 

common grid system and integrated fl ight operations into a master fl ight schedule. All of the requisite airspace and fl ight information was published 

on a single, easily accessible website.

The ACC was operational within a week of inception. Additional specialists augmented the surge 

of forces within another 10 days. At full strength, 

there were nearly 120 military and interagency 

personnel assigned. This investment provided 

seven key functions:

1. Information Analysis and Awareness (IAA). 

The ACC established a daily schedule for 

gathering imagery and sensor data to inform 

spotter and skimmer assignments and operational planning at each ICP.

2. Area Asset Management. A regional approach 

ensured safe operations, particularly for cross 

PORT FOURCHON, La. – 

An Army National Guard 

helicopter hoists sandbags 

that will be dropped in one 

of fi ve key locations along 

the Louisiana coast. Photo 

courtesy of U.S. Coast 

Guard
6. Logistics

125

border fl ight activity between Incident Commands and in congested areas. Publishing a 

Regional Asset Management Plan (RAMP), 

Special Instructions (SPINS), TFR-Notams, 

and Communications Plans, aligned the 

air support available with mission demand 

priorities.

3. Flight Schedule Confl ict Prevention. An 

integrated master schedule provided aircraft separation by timing, altitude, route of 

fl ight, or with coordinated safeguards. Active 

outreach and a public awareness campaign 

enhanced safety.

4. Flight Following. Pilots were given advisories, mission numbers, real time tasking 

adjustments, and partial monitoring. Watchstanders also inserted real-time data from the 

on-scene P-3 aircraft and mission reports to 

update the common operating picture. A live 

watch of over 50 experienced air operations 

specialists provided situational awareness, 

centralized information, standardized reporting, and unity of command.

5. Mission Resource Matching. Aircraft and 

sensor employment decisions and investment 

choices benefi ted from informed recommendations and advocacy. Subject matter experts 

at the ACC evaluated the airship, Unmanned 

Aircraft System (UAS), and multi-spectral 

sensors packages for utility in Deepwater 

Horizon operations.

6. Contingency Planning. Forward-looking 

strategies were developed for mishaps, hurricanes, and evacuations. Planners also pursued 

effi ciencies in boom placement and pick-up, 

decontamination, and other essential functions.

7. Performance Measurement. Mission reports 

and analysis provided essential decision support in the UAC and each ICP.

The Special TFR airspace model used in the 

Deepwater Horizon Response was a signifi cant, 

if not the largest known governance construct ever 

implemented in international and domestic airspace. Exercising special FAA authority to control 

air activities in the airspace adjacent to fi ve states 

was a critical aspect in achieving a safe environment for aircrews.

Another signifi cant aspect of the ACC involved the 

decision to leverage Aviation Operations Center 

(AOC) personnel and facilities of the 601st AOC 

at Tyndall AFB. These specialized U.S. Department of Defense (DOD) forces provided skills 

and assets to set up the initial command structure 

and sustain operations. Initial staffi ng included 52 

permanent party watch-standers. However, with 

augmentation forces that followed, total staffi ng 

peaked at 97 military members. Interagency representatives, including FAA, NOAA, FWS, DOI, 

and CBP represented an additional 23 workers. 

Coast Guard staffi ng included one Captain, one 

Commander, and two Lieutenants.

Facilities at Tyndall, including connectivity, security, and media support, could not be duplicated 

elsewhere. Investing in these resources contributed 

to a number of successful features of the ACC, 

including:

• Integrated IAA. Co-locating Coast Guard, 

USAF, NGA, and other agencies in a secure 

facility at Tyndall, adjacent to the ACC Operations Center, linked information analysts with 

mission planners and watch-standers. Imagery 

fi les, trend data, weather reports, and other 

decision aides were quickly developed and 

delivered up and down the user chain. The IAA 

staff also matched surveillance resources with 

tasking requirements and helped evaluate specialized equipment and mission performance.

• Strategic Planning. An area-wide perspective 

was essential to safety, effectiveness, and effi -

ciency. Air support is as inherently dynamic 

as it is expensive, and often restricted in availability. The ACC provided a level of dedicated 

management that far exceeded the capacity of 

an individual Incident Command.

• Mission Support Liaisons. The cadre of interagency representatives and platform experts 

assembled at ACC met daily to assess scheduled missions and negotiate priorities derived 

from the UAC or the ICs. Communications 

problems, alignment with goals, performance 

measures, asset evaluations, aircrew training, 

and job aids were among the common issues 

discussed. Strong relationships developed, 

allowing fair negotiations, rapid decisionmaking, and sound recommendations. All 

interagency priorities were ultimately reconciled. Similarly, liaisons dispatched to the 

UAC and ICPs accelerated the fl ow of information for decision makers and helped foster 

teamwork.
126

6. Logistics

• Seamless Transportation Missions. Establishing a single point of contact to source 

logistics requirements and reliably coordinate 

short-fuse, complicated passenger and cargo 

missions had immediate advantages. Missions 

were bundled, alternatives were considered, 

and suitable providers were assigned to lower 

costs and prevent abuse.

• Web-based Governance. Having the RAMP, 

fl ight schedules, special instructions, mission 

reports, operational stats, and performance 

measures published in the public domain provided transparency and invited full participation from commercial and military aircrews 

alike. The ready availability of current information also increased mission accountability 

and feedback.

The ACC was unique in enlisting the specialized 

skills of the USAF largely in a domestic environment. The effectiveness of resources at Tyndall 

AFB were demonstrated in the recent Haiti earthquake response, and in the aftermath of Hurricane 

Katrina. However, this mission was a new experience in that the DOD component directly supported a UAC involving a Coast Guard Flag offi cer 

and a commercial entity or RP. The challenges 

of adapting cultures and interpreting processes 

and language to ICS standards were anticipated 

and resolved with an assigned ICS coach. Yet the 

restrictions imposed by requesting forces, answering questions about affordability, and awaiting 

funding approval were sources of frustration. 

Ultimately, the functionality at ACC was scaled 

to the level of approved resources, which proved 

to be adequate and functional for the tasking and 

mission of the ACC. Pre-determined surge levels 

for participating response agencies may alleviate 

some delays and confusion in future missions.

The other initial challenge for the ACC was gaining early buy-in from Incident Commands and 

aviation activities alike. There was reluctance 

to relinquish control of information or resources 

during the initial ACC implementation. However, 

the exchange of liaisons and timely delivery of 

aviation services helped engender strong partnerships with each of the requisite stakeholders. The 

ACC was also privileged to have the original Air 

Boss from Houma assigned as the Deputy Director. This offi cer brought both Deepwater Horizon

response experience, and personal relationships 

with many of the local air operators. This enhanced 

ACC credibility. The key also was allowing the 

ICPs to continue to fl y aircraft, with the ACC in 

a supporting role to the FCs.

The ACC met a critical safety need and signifi -

cantly improved the oil spill response mission. It 

was a bright spot in organizing the unifi ed response 

to this incident. Airspace governance was timely 

and effective with the dividend of effi cient aviation services. The success of the ACC was directly 

related to the skill-sets and resources provided by 

each agency, and particularly by the host, the U.S. 

Air Force.

FOSC Key Points: Aviation Coordination 

Center

Initial aviation control efforts worked well, but 

as the number of sorties of widely varying types 

directly affi liated with the response grew, more formal means of control with sophisticated tracking 

and traffi c management capability became necessary. Tyndall Air Force Base performed well. The 

FAA’s assistance with TFR, combined with Tyndall 

Air Force Base’s ability to fuse information to 

help enforce the airspace, brought the response 

activities under control and ensured operations 

were safe.

MOBILE, Ala. – The 

Southeast Region 

Commander of the 

Civil Air Patrol (CAP), 

CAP Chaplain, and CAP 

National Commander 

discuss the Incident 

Command Post Mobile’s 

area of responsibility. The 

CAP provided three daily 

surveillance fl ights to ICP 

Mobile to check on boom 

deployed in sensitive 

areas. Photo courtesy of 

U.S. Coast Guard
6. Logistics

127

6.5 Operational Logistics: Vessel 

Decontamination

The Deepwater Horizon response arguably produced the largest, most complex, and diverse vessel 

decontamination effort encountered in a U.S. oil 

spill. A massive fl eet of response vessels performed 

a wide variety of tasks including oil containment, 

ferrying, oil recovery skimming, burning, logistics, relief well drilling, fl aring, and surveillance. 

The vessels ranged in size from small trailerable 

vessels to 800-foot drill ships located at the spill’s 

source. Depending on each vessel’s assignment 

and role, oiling ranged from none or very little to 

considerable contamination. The decontamination 

process that followed involved thousands of vessels being comprehensively cleaned of oil.

Decontamination was required to ensure that vessels were adequately free of oil to prevent the reintroduction of oil into the environment outside of 

the theater of operations. Decontamination became 

a time-consuming process, particularly on more 

sophisticated vessels such as Offshore Supply 

Vessels (OSV), large drill ships, and other large 

commercial vessels.

In many cases, recoverable oil was removed from 

sea chests and other fi ttings. An extensive situation 

involved hundreds of gallons of oily water removal 

from the ballast tanks of Discoverer Enterprise

which was among the most heavily impacted vessels because it remained at the site of the spill and 

was exposed to some of the most severe oiling. 

Other vessels such as trailerable VOOs were very 

simple to clean and examine. Worker safety was a 

top priority. Consistency in applying decontamination processes and policy was also a priority 

to ensure compliance with the Clean Water Act 

and protecting the environment from secondary 

pollution.

At its height of operations from August to October 

2010, the decontamination system involved 17 

individual sites across the fi ve Gulf Coast states, 

employing 4,000 RP, Coast Guard, contracted, or 

sub-contracted individuals.

Further discussion on worker safety is located in 

Chapter 4 of this report.

Establishment of Decontamination Branch

A FOSC representative and an RP representative 

developed the priorities, processes, and policies 

of the decontamination program. The program 

was initially managed at the ICP level, and then 

consolidated and managed by the Vessel Decontamination Branch as part of the UAC, with east 

and west regions divided by the Mississippi River. 

In mid-October, the scale of the decontamination 

program grew beyond the designed Branch capacity and an independent Vessel Decontamination 

Section was formed, reporting directly to the UAC.

Vessel Decontamination sites ranged from established shipyards to vacant lots, leased for the 

purposes of hosting temporary decontamination 

operations. Among the most productive sites for 

large commercial vessels were existing shipyards 

and facilities in Tampa Fla., Mobile, Ala., Port 

Fourchon, La., Lake Charles, La., Galveston and 

Texas City, Texas. The other facilities included 

major decontamination hubs that were located in 

Theodore, Ala., Pascagoula, Miss., Venice, La., 

and sites in Port Fourchon, La. The remaining sites 

were typically managed under the Operations Section Branches and handled smaller vessels such as 

trailered VOOs and fi shing vessels. These sites 

often had no pre-existing infrastructure.

Captains of the Port controlled potentially oiled 

vessels and required decontamination surveys 

offshore. As the spill cleanup progressed, vessel 

traffi c was reasonably effective at avoiding oil. 

The UAC Consolidated Decontamination Plan was 

signed and promulgated on September 13, 2010, 

TAMPA Fla. – Rear 

Admiral Roy Nash, 

Deputy Federal OnScene Coordinator 

for the Deepwater 

Horizon Response, 

speaks with the 

Commanding Offi cer of 

the Coast Guard Cutter 

Elm while touring a 

dry dock facility that 

decontaminated Coast 

Guard cutters involved 

with the Deepwater 

Horizon cleanup. 

Photo courtesy of the 

U.S. Coast Guard 
128

6. Logistics

and signifi cantly formalized the decontamination 

process. The decontamination process can be analyzed using six main guiding elements that aid effi -

cient operations and reduce risks across the UAC’s 

decontamination operations. The fi rst element was 

site establishment. This encompassed the planning 

and execution of all the activities associated with 

starting new decontamination sites to a common 

standard. The second element was assessment. 

Assessment provided centrally deployed vessel 

assessment teams (marine surveyors or subject 

matter experts) to evaluate the condition of large 

vessels via on board assessment as vessels entered 

the demobilization queue. This phase determined 

the level of contamination and required decontamination including the necessity of dry-docking.

The third element included work planning. This 

element built consistent work planning packages 

that specifi ed the required decontamination task 

and repairs required to certify the vessel as clean. 

Additionally in work planning, the vessel would 

be returned to the owner in the condition specifi ed 

in the charter contract. The fourth element incorporated decontamination scheduling to provide 

a central scheduling function for large vessels to 

optimize throughput.

In the fi fth element, integration, decontamination 

operations incorporated into a single process to 

ensure vessel off-hire activities were scheduled in 

coordination and in parallel with decontamination 

tasks to accelerate off hire status. The sixth and 

fi nal element included optimization. This element 

advised fi eld sites on process optimization or 

improvements, measured metrics, and deployed 

teams of optimization experts to improve site 

throughput.

As illustrated in Figure 6.3, the decontamination 

process involved several steps: 

1. Assess the vessel and equipment to be 

decontaminated;

2. Schedule the work; and

3. Enter a decontamination site, complete the 

work, re-examine the task for completeness, 

exit the decontamination facility, and take the 

vessel off-hire.

Figure 6.2: Vessel Decontamination Locations

Figure 6.3: Decontamination Process
6. Logistics

129

Figure 6.4

Figure 6.5
130

6. Logistics

Cleaning

Decontamination methods and tools varied with 

the type of vessel and what it was exposed to. In 

general, cleaning proved to be simple but laborious, and required several days of intensive cleaning was normally required for a typical large 

vessel. Small vessels, such as fi shing vessels or 

other small VOOs could complete decontamination in one or two days. Decontamination included:

• Complete hull and deck cleaning,

• Anchor and ground tackle cleaning,

• Cleaning of mooring gear,

• Sea chest and sea bay cleaning,

• System fl ushing (as necessary), and

• Equipment cleaning (as necessary).

In most cases, hot water with a fl oating cleaning 

agent proved an effective external cleaning method. 

Sorbent pads, brushes, and other simple cleaning 

tools aided workers through the painstaking effort 

to locate and clean all visible oil from the vessels’ 

hulls, decks, equipment, and systems (see Figures 

6.4 and 6.5). Workers, managers, and Coast Guard 

decontamination examiners required job specifi c 

training including Hazardous Waste Operations and 

Emergency Response (HAZWOPER), site-specifi c 

safety instruction, decontamination process and 

techniques, as well as UAC Decontamination Plan 

contents, goals, and policy. 

Standards and Certifi cation

The UAC applied the Clean Water Act as the 

threshold of decontamination, which was the goal 

for all vessels entering the decontamination process. In order to be considered decontaminated, a 

vessel had to be free of oil or oil residue that may, 

through the normal course of operations, pose a 

risk of sheening or polluting the environment as 

described in the Clean Water Act. Vessels seeking 

demobilization were required to fi rst attain a certifi cation of decontamination from the Coast Guard. 

The Coast Guard created three tiered decontamination stages to control pollution threats based on 

risk and operational need.

Stage I, or the gross stage, involved removing light 

or heavy oil from the hull of a vessel that was contaminated during the response effort. The objective 

of Stage I decontamination was to ensure that the 

vessel would not emit a sheen during operations, 

although a stain may still exist.

Stage II, or the secondary stage, involved removing light or heavy oil and oily residue from a vessel 

hull, ancillaries, appurtenances, and equipment that 

a Stage I decontamination could not accomplish. 

The Stage II decontamination process was more 

detailed. The Stage II standard was that the vessel 

would not likely emit a sheen, sludge, or emulsion 

from its deck spaces or engineering piping systems 

into waterways during transit in all anticipated 

sea conditions and weather (e.g., rain). Stage II 

could apply temporary methods such as plugging 

scuppers, placing additional sorbent material on 

deck or in way of deck drains and freeing ports, 

or sheltering contaminated equipment from wash, 

spray, and rain, in order to move a vessel to a suitable location for Stage III decontamination.

Stage III, or the fi nal stage, involved removing 

all oil contamination from the vessel, equipment, 

and materials. An objective of this decontamination process was to ensure that all liquid and solid 

waste generated by the decontamination process 

was also removed from the vessel. Upon fi nal verifi cation, the Coast Guard examiners could issue 

a fi nal Stage III letter as evidence of compliance 

with Stage III decontamination protocol.

Decontamination was a prerequisite to demobilization. In some locations, fi eld workers developed 

their own economy of effort by integrating decontamination examinations with other demobilization surveys including damage surveys, equipment 

GULF OF MEXICO – A 

crewmember aboard a 

tug uses a high-pressure 

fi re hose to wash oil from 

the hull of a barge as 

part of a gross-vessel 

decontamination process. 

Photo courtesy of U.S. 

Coast Guard 
6. Logistics

131

removal verifi cation, and associated documentation of taking vessels off hire. Due to the very large 

number of vessels hired for this response, normal 

systems for tracking vessels (requiring decontamination) in the fl eet were initially overwhelmed. 

Out of necessity, several innovative data collection 

systems were created to track and manage the fl eet 

of vessels in the decontamination queue.

Nautilus is a purpose-built information technology 

system created by an RP contractor. The system 

tracked vessels through the decontamination process and provided administrators and users with 

real-time data regarding specifi c milestones in the 

decontamination and demobilization process, and 

was invaluable in documenting each vessel’s status. Additionally, hand-held personal data assistant 

(PDA) devices with decontamination checklists 

and certifi cation forms were utilized by Coast 

Guard examiners in the fi eld. The PDAs updated 

the Web-based database upon examiner entry of 

data and featured cameras for digital imagery, for 

inclusion in vessel case fi les. The PDA was also 

capable of electronic signature and delivery of 

paper copies of Stage II or Stage III letters, which 

could be produced for vessel personnel to complete the documentation process. Furthermore, the 

system electronically captured all electronic signatures and automatically fed the Nautilus database.

Resources Committed

The massive endeavor of assessment and decontamination of thousands of vessels across fi ve 

states demanded a considerable array of resources 

and infrastructure. The RP estimated the commercial value of the entire decontamination program 

at $1.5 billion.

People were the most critical resource. The decontamination process was a very tedious, time consuming, and labor-intensive task. The physical 

labor required many entry-level laborers for the 

bulk of the work. More technically qualifi ed labor 

was required for complex vessels and engineering 

systems. At the height of operations (mid-August 

through October 2010) there were more than 4,000 

personnel solely committed to the decontamination 

program. From an examination perspective, the 

Coast Guard employed approximately 112 personnel to ensure compliance with decontamination standards. Pollution Investigators and FOSC 

representatives possessed suffi cient skill sets to 

examine and verify smaller vessels, such as VOOs 

and workboats. Marine inspectors were employed 

to examine ships and more complex engineering 

systems.

The decontamination process was exclusively 

funded by the RP, which involved a considerable 

process, infrastructure, equipment, and training. 

A signifi cant contributor to the prioritization of 

vessel decontamination and demobilization were 

vessel day rates which ranged by vessel from hundreds of dollars to hundreds of thousands of dollars per day. At the height of operations between 

September 1 and November 15, 2010, the daily 

cost (burn-rate) for on-hire resources, whether they 

were actively responding or waiting in a queue, 

signifi cantly exceeded $20 million.

Responders maintained a strong bias toward natural surface cleaning agents. There was a continual 

evaluation of agents to minimize environmental effects. All cleaning agents met a stringent 

approval process. In order for consideration for the 

decontamination program, each cleaner required 

listing on the EPA’s National Contingency Plan 

Product Schedule. Additionally, the RRT VI vetted 

cleaners and each state consulted on concurrence 

before a cleaning agent received authorization. 

Authorized cleaning agents for use over the water 

(offshore or dock side) were required to be fl oating 

agents to assure rapid recovery from the water’s 

surface using sorbent material. The decontamination program prohibited any agent that might have 

acted to disperse or otherwise scatter oil into the 

water column.

GRAND ISLE, La. – A U.S. 

Navy salvage vessel is 

cleaned at the vessel 

decontamination 

station. The station also 

decontaminated boom 

and vehicles. Photo 

courtesy of U.S. Coast 

Guard
132

6. Logistics

Most decontamination sites were outfi tted with an 

extensive capacity for portable liquid storage in the 

form of Frac Tanks. Typical Frac Tanks provided a 

holding capacity of 21,000 gallons and were used 

to retain oil, oily waste, cleaning residue, or other 

waste water to prevent secondary oil pollution. 

Frac Tank contents were contained and properly 

disposed per local and state hazardous waste disposal laws. Additionally, mobile traditional tanker 

trucks were employed to move oily waste water to 

disposal sites over the road in varying capacities 

up to 9,500 gallons.

Dock side decontamination sites required extensive use of durable workboats to maintain protective containment boom and provide platforms to 

perform hull cleaning and examination. Extensive use of 12-inch to 18-inch hard harbor 

containment boom was common. Vessels 

undergoing dock side decontamination 

were boomed with hard harbor boom and 

typically lined with sorbent boom. The 

boom was placed around contaminated 

vessels to contain any oil or oily residue 

that may have become waterborne during the decontamination process. The 

protective booming strategy ensured 

any oil was recovered and removed.

Most sites were equipped with large containment 

berms more commonly referred to as pools. Typical uses for pools included decontamination of 

small vessels and equipment by simply placing 

the entire contaminated asset in the pool for cleaning. Pools were valuable in preserving shoreside 

habitat, soil, and ground water from oil or chemical 

damage by containing all runoff. Vacuum trucks 

were used at most sites to collect oily waste water 

from vessels and collection pools. The trucks were 

important components in completing the decontamination cycle in an environmentally sensitive 

manner. Vacuum trucks were commercially available and most capable of handling the waste water 

produced by the decontamination process. Trucks 

ranged in size from 1,000- to 3,000-gallon capacity, and assured that waste was properly stored 

and disposed of.

Other resources used at decontamination facilities 

were underwater examination assets, including 

divers, and remotely operated vehicle (ROV) technology. General purpose rags, brushes, approved 

cleaning supplies, and safety equipment, such as 

Tyvek suits, hard hats, eye and ear protection, and 

gloves were also used.

Decontamination Challenges

The absence of a pre-existing decontamination plan 

presented a challenge to responders as resources 

needed to be diverted to address the precedent setting decontamination situation. The UAC Decontamination Section then wrote and fi eld tested a 

comprehensive plan describing processes to ensure 

GRAND ISLE, La. – Workers toss bags of 

oiled waste products into a compactor 

at a decontamination station. Photo 

courtesy of the U.S. Coast Guard

VENICE, La. – A response 

worker cleans a skimming 

vessel at the Deepwater 

Horizon response 

Plaquemines Branch 

decontamination unit. 

Photo courtesy of the U.S. 

Coast Guard
6. Logistics

133

vessels and equipment were free of oil before being 

released from the Deepwater Horizon response.

During the response, the RP, as overseen by the 

UAC staff, established numerous vessel decontamination sites throughout the spill AOR. As a 

by-product, large amounts of oily waste water were 

produced and required transfer from the vessels 

in the cleaning process to storage containers or 

appropriate disposal sites.

Some decontamination sites handling quantities of 

oily waste were treated as temporary bulk liquid 

facilities for the purposes of 33 CFR 154, and 

permitted as such by the local Captain of the Port. 

UAC Decontamination staff worked with the sector and RP site supervisors to assure safety and 

environmental stewardship.

During the decontamination process, it became 

apparent that some vessels were simple to clean 

and others were very diffi cult. Offshore Supply 

Vessels, MODUs, and commercial vessels with 

sophisticated salt water cooling systems posed 

decontamination and examination challenges. A 

principal challenge was determining oil contamination in sea-chests, sea bays, and other underwater openings where oil might escape detection. 

Baffl es divided some sea-chest confi gurations, 

which made detection even more diffi cult. In some 

cases, several of gallons of oily mixture were 

removed from sea chests. Other systems posing 

challenges were anchor chains and chain lockers. While the process of cleaning was simple, 

the effort was time consuming and labor intensive. In a few rare cases, oil migrated into ballast 

tanks and moon pools, which again, proved to be 

a simple but a time-consuming process to remove. 

Through fi eld innovation, internal system fl ushing 

was employed using a mild cleaning agent in a 

closed loop for contaminated raw water systems. 

In some extreme cases, certain system components 

required removal and specifi c cleaning before verifi cation as decontaminated.

Continuity and Training

The Coast Guard developed a training program 

for decontamination and PQS system that Coast 

Guard FORCECOM and Training Center Yorktown adopted. To gain qualifi cation as an examiner, 

each Coast Guard examiner completed this training, which included pre-requisite qualifi cations, 

completion of a formal classroom style course, 

on-the-job training, and issuance of a qualifi cation 

letter. Further, the Coast Guard applied a traveling 

inspector strategy that employed a subject matter expert to visit sites to promote consistency in 

cleaning practices, as well as examination standards and documentation.

Off shore Vessels

Among the challenges of the Decontamination 

Section was the in situ decontamination of the 

three large vessels that prominently supported the 

well capping operation at the spill’s source. The 

Coast Guard consulted with the National Oceanographic and Atmospheric Administration, and the 

State of Louisiana Department of Environmental 

Quality to develop decontamination alternatives 

at the spill’s source, which provided the maximum 

protection to the environment. Separate and distinct plans were tailored to each vessel as each had 

unique challenges and systems. Careful coordination was required to maintain the vessels’ positions 

within areas that remained closed to fi shing until 

decontamination of these vessels was completed.

Pre-assessment Surveys

As vessels were demobilized, their vessel condition was naturally an area of focus. Pre-assessment 

surveys or pre-hire surveys were not adequate to 

reconcile perceived discrepancies between preand post-spill service condition. Without documented pre-assessment surveys, it was sometimes 

diffi cult to judge if damage was pre-existing or if 

it was response related. While response-related 

damage was more easily handled through the 

claims process it was sometimes a challenge to 

explain to vessel owners the nuanced difference 

between a hull stain that posed a pollution threat 

(Coast Guard compliance issue) and one that was 

simply a matter of aesthetics (RP claims issue).

Decontamination exams required specifi c photography that captured certain vessel angles, the 

name, distinctive identifying numbers, and any 

areas of concern. Further, documentation was electronically captured in the Nautilus Database. The 

detailed exit-survey captured the decontamination 

condition of vessels at demobilization.
134

6. Logistics

6.6 Operational Logistics: Waste 

Management

The decontamination process produced large quantities of waste including oiled boom, sorbents, 

clothing, protective suits, oiled gear, and oily 

waste. Oiled waste was required to follow strict 

hazardous waste disposal methods in accordance 

with federal, state, and local law as outlined in the 

ICP waste management plans, and later in a consolidated UAC waste plan. After extensive consultation with appropriate state and local authorities, it 

was determined that the best method for managing 

the waste water was relocating the waste via truck 

to approved land-based waste disposal sites.

As a result of the response 

effort, miles of used boom and 

other debris required disposal. 

To ensure that wastes were 

handled properly, ICP Houma 

and ICP Mobile prepared separate waste management plans, 

which were subsequently 

reviewed and approved by the 

Coast Guard, the EPA, and 

the involved states regionally. 

Later, the EPA and the Coast 

Guard stated their intention to implement a single 

waste management plans through two directives. 

The directives were intended to both create one 

unifi ed plan that could provide direction across the 

Deepwater Horizon response theater, and to implement accountability that would go beyond some 

state requirements. Developing the one Unifi ed 

Waste Disposal Plan required some negotiation 

regarding sampling requirements and classifi cation of waste. The critical aspects of recycling and 

reuse were not incorporated in the plan. In general, 

the waste management plan was intended to be a 

consistent document that could be applied to each 

affected state while also allowing adaptability to 

the needs of the spill response.

The One Gulf Plan includes an outline of the 

Disposal Group Supervisor’s responsibilities, 

with Waste Management and Temporary Storage options to ensure that federal, state, and local 

disposal laws and regulations are followed, necessary permits are obtained, and the RP submits a 

disposal plan for approval. The applicable Sector 

New Orleans Geographic Response Plan provides a 

list of area disposal companies and a supplemental 

Removal and Disposal Checklist, which provides 

guidance to ensure appropriate waste characterization, classifi cation, and disposal are implemented.

In May 2010, the CRU began to develop various 

worst-case-scenario models to estimate waste estimates. The unit modeled 12,000 miles of beach 

being heavily oiled in fi ve states. Using a waste 

calculator program, the CRU calculated potential 

waste totals. The CRU contacted the largest waste 

handlers in the United States to garner insights and 

request assistance. Next, waste management company executives met with CRU staff, RP, and key 

members of the UAC. The CRU indicated there was 

a potential for oiling in fi ve states and provided the 

companies with the numbers from the waste calculator. The companies provided verbal proposals 

that included beach receptacles, waste sites, land 

farms, and other disposal options. Within days, the 

CRU assigned one waste management company to 

ICP Mobile, one to ICP Houma, and another to the 

Florida operation. The RP executed master contracts 

and released news of the arrangements to the ICPs.

The fi rst formal waste management plan for the 

spill was issued on May 8, 2010. On June 14, 2010, 

version 3 of the Recovered Oil and Waste Management Plan for the Houma ICP was approved to 

cover waste issues in Louisiana. This over-arching 

plan covered a broad range of waste management 

issues including: 

• Oil skimmed off the water, 

• Oil collected from absorbents, 

• Decontamination, shoreline impact cleanup, 

• Wildlife rehabilitation waste disposal, and

• Other cleanup related issues.

A similar Solid Waste Management Plan for the 

Mobile ICP was issued on May 9, 2010, and later 

revised on July 2, August 5, and August 25, 2010. 

This plan covered the states of Mississippi, Alabama, and Florida.

On June 29, 2010, the Coast Guard and EPA issued 

their fi rst directive requiring the RP to test its waste 

for hazardous elements, publicize the results, and 

consult with communities about where the waste 

was to be stored. Due to the nature of the waste, 

including oil exploration and production (EP) waste, 

the oil and oily water were technically exempt from 

classifi cation as hazardous waste. The RP initially 

sampled waste intended for disposal as a matter of 

voluntary due diligence.

GRAND ISLE, La. – Contract 

workers offl oad soiled 

sorbent boom, oily debris, 

and trash from a Vessel of 

Opportunity at the Grand 

Isle decontamination 

station. Photo courtesy of 

the U.S. Coast Guard
6. Logistics

135

There was also discussion over how often this waste 

should be sampled, e.g., each load transported, random samples once per week, once per month, etc. 

In fact, the frequency of sampling varied, though 

the EPA conducted twice-monthly testing of debris 

and posted the results on the Internet. As of November 17, 2010, EPA’s tests had not shown any of 

the waste to be hazardous. In addition to EPA and 

RP, and some counties also sampled the waste to 

ensure it was non-hazardous. For example, Harrison 

County, Miss., tested waste before its disposal at the 

Pecan Grove landfi ll.

The fi nal version of the Gulf-Wide Recovered Oil 

and Waste Management Plan was signed on October 4, 2010, and superseded the previous waste 

management plans for both the ICPs Mobile and 

Houma. To avoid duplication and confusion, this 

single plan was used for all waste generated from 

the Deepwater Horizon response, including the 

decontamination program. 

Cooperation among representatives of the oil and 

gas industry, commercial waste management facilities, and state governments resulted in development 

of guidelines for third party commercial fi rms handling and managing EP waste. These guidelines 

refl ected a continuing commitment to environmental protection and to assurance that the wastes from 

oil and gas EP waste were properly managed.

The EP Waste Workgroup created these guidelines to help identify design, construction, and 

operational options that could be used, depending 

on site-specifi c conditions, at facilities to protect 

human health and the environment. The EP Waste 

Workgroup sought to provide fl exible guidance to 

waste management facility owners and operators 

while protecting human health and the environment. 

Although these guidelines were intended to be useful to a varied audience, three audiences found the 

information particularly useful—EP waste facility owners and operators, customers of the waste 

management facility (i.e., EP companies), and state 

regulatory personnel.

Oil EP wastes are classifi ed as non-hazardous by 

law and do not require specialized disposal. Oil contaminated debris and oily waste generated from the 

cleanup of this oil spill were considered solid waste.

The waste was classifi ed into three categories: 

recyclables, municipal trash, and crude oil-contaminated (oiled) waste. The recyclables and municipal trash primarily came from offi ce buildings 

where RP, UAC, and ICPs were located, supply 

distribution warehouses, response equipment, and 

personnel fi eld mobilization sites.

Crude oil-contaminated waste was generated 

by shoreline cleanup, skimming, booming, and 

decontamination of vessels or equipment. The 

oiled waste was both solids and liquid. Oil contaminated items included shoreline cleanup equipment, tar balls, vegetation, oiled sand, oiled debris, 

used personal protective equipment, and disposal 

equipment.

The decontamination process produced large quantities of waste including oiled boom, sorbents, 

clothing, and protective suits, and other oiled gear. 

Large quantities of waste water were also produced 

from high pressure hull cleaning, hand cleaning, 

and engineering system fl ushing.

In some cases, decanting of oily waste water was 

studied to increase effi ciency, as was processing 

waste water through municipal Publicly Owned 

Treatment Works (POTW). After extensive consultation with appropriate state and local authorities, 

the Coast Guard, EPA, and the EP Waste Workgroup determined the best method for managing 

waste water was to relocate waste via truck to 

approved land-based waste 

disposal sites. The large 

volume of waste water produced in the decontamination process was too great 

for the intended design 

of the POTWs that were 

considered (specifi cally in 

Port Fourchon and Lake 

Charles).

Although trucking waste 

water added some risk and 

cost, it avoided unnecessary direct environmental 

risk of either decanting oily 

water into the waterway or 

overwhelming POTWs. 

The group also studied the 

responsibility of the waste 

originator and the separation of a decontamination 

contractor from the parameters of the UAC Waste 

Management Plan. It was 

determined that individual 

VENICE, La. – Workers at 

a decontamination site 

clean oil containment 

boom, which will then be 

transferred to a staging 

area and eventually put 

back into service. Photo 

courtesy of U.S. Coast 

Guard
136

6. Logistics

contractors should not be authorized to originate 

their own waste because this would make tracking, 

oversight, and enforcement of waste management 

too challenging and create gaps and improper or 

inadequate waste disposal.

To the extent possible, water was separated from 

the oil, treated, and reused, or disposed of at 

permitted disposal facilities. The recovered oil 

was sent to facilities that recycle or reprocess the 

oil. Recovered oil that was not suitable for recycling or reprocessing was disposed of at permitted facilities. Waste was sent to municipal waste 

landfi lls with the appropriate permits. The designated sites were Chastang, Ala., Spring Hill, Fla., 

Pecan Grove, Miss., and various sites in Louisiana. 

Used boom was placed in watertight, covered rolloff boxes at a decontamination station. Then it 

was taken to a staging pad where the boom was 

pressure-washed with hot water and a cleaning 

solution if needed. Recovered oil was collected for 

treatment, reuse, or disposal. The wash water was 

treated on-site, and recycled or sent to a permitted 

disposal facility.

As mandated in the Coast Guard and EPA directive, a percentage of materials, such as boom, 

needed to be recycled or reused. Decontaminated 

boom that could be reused was redeployed to the 

response or returned to the owner. A small percentage of boom was used as a fuel source in electrical 

generation. Some boom was recycled into plastic 

materials used for benches or other objects. If the 

boom could not be reused or recycled, it was disposed of in a landfi ll.

Oiled sorbent materials and other oily debris were 

bagged and placed in watertight containers for 

transport to permitted solid waste landfi lls.

6.7 Operational Logistics: The Severe 

Weather Contingency Plan

The Severe Weather Contingency Plan (SWCP) 

addressed how spill response activities and waste 

management would be conducted if severe weather 

impacted ongoing Deepwater Horizon response 

efforts. The SWCP established severe weather 

preparedness and response guidelines for the 

personnel, equipment, and resources assigned to 

support the Deepwater Horizon oil spill response. 

The primary function of the SWCP was to serve 

as the FOSC mechanism to direct the timely and 

effective suspension of response operations, potential relocation of Deepwater Horizon response 

assets, and the reconstitution of those assets after 

a severe weather threat or event passed through 

the region.

The complicating factor was that the oversight and 

funding mechanism for the response to a severe 

weather event (under the Stafford Act) is fundamentally different from the oversight and funding 

mechanism used to respond to typical oil spills 

under the Clean Water Act and OPA 90.

The SWCP delineated the components of oil 

cleanup operations that would be conducted and 

funded under the Stafford Act with FEMA’s oversight, and which would continue to be conducted 

under the Deepwater Horizon FOSC’s direction, 

following the NCP in the case of severe weather. 

Resumption of oil spill response operations after a 

severe weather event would be initiated in a phased 

manner as soon as the affected areas were deemed 

safe for reentry and support services were adequately restored to support an effective response

Due to the possibility that non-Deepwater Horizon point-source oil spills could occur from storm 

surge, fl ood, or infrastructure damage from a 

severe weather incident, potentially mixing with 

Deepwater Horizon oil, the cleanup process after 

a storm would require a comprehensive post-storm 

assessment and a spill-sampling plan to ensure 

accountability and chain of custody were maintained. FEMA and EPA policy does not authorize 

Stafford Act funds for the cleanup of a pre-existing 

oil or hazardous materials spill.

The SWCP therefore outlined procedures to identify oil matching the Deepwater Horizon Macondo 

well for removal funding purposes, and noted that 

the cleanup, transport, storage, and fi nal disposal of 

the oil associated with the Deepwater Horizon spill 

would be conducted under the FOSC’s existing 

protocols. Meanwhile, oil or contaminated debris 

associated with other sources compromised by the 

severe weather event would be handled separately 

under Stafford Act procedures. For more information on the SWCP, see Chapter 5 of this report.
6. Logistics

137

6.8 Support Logistics: Command, 

Control, Communications, Computing 

and Information Technology (C4IT)

At the beginning of May 2010, the Unified 

Area Command (UAC) Logistics Section, then 

located in Robert, La., comprised fi ve persons, 

plus a detached Personnel Resources Unit (PRU) 

located at the Coast Guard District Eight offi ces 

in New Orleans, La. The Communications Unit, 

under the Logistics Section in accordance with 

the Incident Command System (ICS) construct, 

operated independently. There was also an Information Technology (IT) support Branch operated 

by Electronics Support Unit (ESU) New Orleans 

(NOLA). This Branch operated independently of 

the Communications Unit to provide IT support 

services, much like an Electronics Support Detachment at a Coast Guard unit.

The Coast Guard Command, Control, Communications, Computers, and Information Technology 

Service Center (C4IT SC), Field Service Division created an ESU structure within the UAC 

to provide effective around-the-clock IT support, 

and to manage the myriad requests for additional 

IT infrastructure for response personnel. New 

ESU commanding offi cers were cycled in every 

four weeks for a 30-day period to provide leadership for the ESU Logistics Cell inside the UAC. 

Essentially, the C4IT logistics component of the 

response could be accurately described as an ESU 

operating within the current ESU NOLA to support 

the UAC and all Coast Guard responders.

To streamline property accountability and delivery, 

the ESU New Orleans was the inventory control 

point for all Deepwater Horizon C4IT equipment. 

In addition, ESU NOLA established an IT Boot 

Camp as a two-day program designed for incoming IT personnel to bring the personnel current 

regarding specifi c issues related to the Deepwater 

Horizon response, and to provide refresher training 

on the most common IT support tasks.

To assist with tracking C4IT resources, IT support 

personnel developed a C4IT common operational 

picture (COP) through ArcGIS, a data management system. User-friendly spreadsheets were 

developed for C4IT logistics personnel to identify 

and enter deployed personnel and equipment. The 

spreadsheet data was imported daily into ArcGIS, 

which permitted the display of all deployed C4IT 

assets and resources in a visual format. This greatly 

aided the Field Service Division (FSD) in keeping C4IT SC leadership and the Assistant Commandant for C4&IT (CG-6) apprised of the C4IT 

force lay-down.

The increasing size of the response operation 

affected multiple ESUs beyond ESU NOLA alone. 

ESU Miami supported the ICP in St. Petersburg, 

Fla., which transitioned to ICP Miami and the Florida Peninsula Branch operating under ICP Mobile. 

ESU Portsmouth, Va., supported the Atlantic Area 

Integrated Management Team (LANTAREA IMT), 

and the Coast Guard Headquarters Support Facility supported response elements in the National 

Capitol Region such as the National Incident Command (NIC) staff.

As the incident quickly escalated from a regional 

to a national event, the C4IT SC Field Service 

Division assumed coordination of all C4IT service 

and resources. Operational C4IT resources were 

managed by the Coast Guard Atlantic Area Staff 

Operational Communications and Safety Division (LANT-36). The diagram below shows the 

relationship between operational communications 

and C4IT support entities. This structure between 

the operational communication and C4IT support 

community and was a key element to successful C4IT management for the Coast Guard in the 

Deepwater Horizon response.

Figure 6.6: C4IT Support Resources and 

Capabilities
138

6. Logistics

Within the response structure, the UAC Communications Unit oversaw the ICP Communications 

Units. The UAC Communications Unit monitored 

fi eld detachment activities, coordinated rapid installation of commercial communication lines whenever needed, provided around-the-clock technical 

support, managed key personnel requests, and 

assignments at the enterprise level while routing 

ICS-213s request forms through the UAC for appropriate accounting.

Almost immediately, the Coast Guard released 105 

Coast Guard laptops stored in Baltimore, Md., to 

the response. The Coast Guard also dispatched 

C4IT personnel to assess C4IT equipment and 

infrastructure needs, which enabled the entire C4IT 

organization to accommodate the needs of Coast 

Guard responders through the duration of response 

operations. In anticipation of the rapid depletion 

the Coast Guard stores of standard laptops, C4IT 

SC procured, imaged, and installed an additional 

1,200 Coast Guard Standard workstation computers 

and associated infrastructure to support deployed 

personnel. In anticipation of the rapid depletion of 

the Coast Guard stores of standard laptops, C4IT 

SC procured, ‘imaged’ and installed an additional 

1,200 Coast Guard Standard workstation computers 

and associated infrastructure to support deployed 

personnel. ‘Imaging’ of a workstation computer is 

the loading of the standard Coast Guard operating 

system, attached security systems, and authorized 

enterprise applications onto the machine. Because 

the imaging process is time-consuming, the Coast 

Guard Telecommunication and Information Systems 

Command (TISCOM) increased its imaging capacity to an around-the-clock operation. In addition, the 

rapid deployment of laptops proved a signifi cant 

property management and accountability concern.

Coast Guard cutters with legacy connectivity could 

not effectively coordinate with command and 

control entities on shore. Working with TISCOM, 

medium endurance cutters working the Deepwater 

Horizon response effort were outfi tted with satellite connectivity solutions. With higher bandwidth 

satellite connectivity and the updated version of 

Internet browser software, cutters and other communications assets were able to access the incident 

COP software ERMA. The cutters could also then 

use the Homeland Security Information Network 

and the Jabber Chat client via commercial satellite 

providers to coordinate with the UAC and ICPs 

ashore.

The C4IT organization helped Coast Guard Surface 

Forces Logistics Center (SFLC) personnel establish 

and support shoreside Vessel Support Units. Each 

Vessel Support Unit provided vital maintenance 

support to the cutters and small boats involved in 

the response effort. Coast Guard ITs provided connectivity to the cutters and assisted with computer 

casualties while Coast Guard Electronics Technicians (ETs) provided casualty and preventive maintenance assistance to the crews.

The RP provided phone lines to the command centers, ICPs, and Branches. Additionally, cell phones 

were issued to Coast Guard command staff, and the 

cell phone resource requests were handled through a 

special request requiring section leader approval for 

accountability purposes. Cell phones were in near 

constant demand as staff levels continued to surge 

through June 2010. Cell phones generally fell into 

three categories—heavy-duty phones for fi eld use, 

regular phones for those in staff assignments, and 

smart phones for liaisons and senior staff. (Smart 

phones were set up with Goodlink for email receipt.)

C4IT SC also implemented the Electronically 

Stored Information capture process in accordance 

with U.S. Department of Homeland Security (DHS), 

U.S. Department of Justice, and Coast Guard Legal 

guidelines. Using the DHS approved Symantec 

Enterprise Collector E-Vault data collection tool, 

electronically stored information from standard and 

non-standard laptops are in the process of being 

archived. When complete, the data will be stored at 

the DHS collection facility at NASA’s Stennis Space 

Center in Mississippi. The result will yield a searchable data archive to meet Freedom of Information 

Act and other information requests for Deepwater 

Horizon response related data.

The RP provided internet access at the UAC, ICPs, 

Branches, and other locations. Other agencies 

largely relied on these commercial internet avenues 

to access their computer networks, and relied largely 

on their own cell phones for communication. Where 

necessary, they used Coast Guard, and at times, the 

RP provided communications.

Tactical Communications: Organization and 

Personnel

ICPs Houma, Mobile, and Miami had a Communications Unit Leader (COML) assigned and responsible for all C4IT issues within that ICP area of 

responsibility. There also was an assigned COML 

at the UAC to manage C4IT issues within the UAC 
6. Logistics

139

due to its size. The Branches were concerned with 

tactical communications. There the IT staff implemented the use of Incident Communication Center 

Managers (INCMs) and Radio Operators for the 

fi rst time on a Coast Guard response. Many of the 

Radio Operators were contracted by the RP, but they 

reported to a Coast Guard INCM. At each ICP and 

working for the COML was a variety of support 

personnel including Operations Specialists, supply 

personnel, and a number of Information System 

Technicians under the supervision of a senior IT 

or C4IT person. This person provided IT support 

throughout the ICP area of responsibility.

C4IT leaders decided early in the response to select 

personnel to fi ll the COML positions from the small 

group of personnel who had graduated from the 

recently implemented ICS-358 COML class. This 

limited the pool of candidates to 142 personnel who 

had graduated ICS-358 at that time. The requirement that COMLs be graduates of the ICS-358 

course created a baseline skill set that could then 

be built on through on-the-job experience.

Several of the Branches became so large and dispersed that it was necessary to assign COMLs at the 

Branch level to coordinate operational communications in smaller geographic areas. COMLs assigned 

at the Branch level reported to the ICP COML.

Due to the scope and complexity of this response, 

another ICS position at the UAC was used for 

the fi rst time on a Coast Guard response, that of 

the Communications Coordinator. The Communications Coordinator was a senior communicator from a district or area staff, a graduate of the 

ICS-358 COML class, and someone with extensive operational communications experience. The 

Communications Coordinator was responsible for 

coordinating all C4IT issues between the various 

response organizations and supporting agencies and 

organizations. The responsibilities of the coordinator included: 

• Spectrum and frequency management, 

• Communications plan review, 

• Critical communications resources (computers 

and radios) ordering and allocation, and 

• The personnel ordering process for critical communications personnel.

The Coast Guard identifi ed the insuffi cient number 

of frequencies to provide effective communications 

to all responder aircraft and vessels as an organizational communications challenge early in the 

response. ICPs were competing with one another for 

frequency assignments. The solution was to bring all 

key communications leaders together from the various ICPs and with the RP identify key integration 

points and common frequency plans and strategies. 

Once the meeting was held, the situation rapidly 

resolved through agreed allocation and effective 

communications resumed.

Vessel Communication

Vessel communications proved to be the most 

challenging issue faced by the communications 

organization. A total of more than 9,000 VOO and 

response vessels were assigned to the incident, 

ranging in size and capability from 16-foot Jon 

boats with little or no communications equipment, 

to 270-foot Coast Guard cutters with a full suite 

of military communications systems, and major 

commercial vessels with state of the art commercial communication systems. Responders needed 

to communicate from remote marsh areas and the 

well site 50 miles offshore. Developing an effective, comprehensive communications plan, which 

accounted for language barriers and provided the 

appropriate level of communications to all vessels, 

was a major undertaking.

In the early stages of the operation, vessel communications were limited to available marine band 

channels. Using non-traditional marine band channels with Federal Communication Commission 

permission, and permission from coastal operators 

with licenses to use specifi c marine band channels, 

C4IT responders were able to develop a solution 

based on VHF-FM marine band with frequency 

reuse occurring based on geographical separation. 

The RP assisted by installing radios on vessels not 

already equipped.

Communication with responders on or near the 

shore was primarily a concern in the Louisiana 

coastal region, as that was where oil impact fi rst 

occurred. The Louisiana Governor’s Offi ce of 

Homeland Security and Emergency Preparedness 

was engaged to utilize their statewide 700 and 

800MHz radio system. Within four days of the 

beginning of the response, they provided radio 

coverage on shore throughout the Louisiana area 

of operations.

The State of Louisiana continued to implement a 

project it was working on called the Gulf Coast 

Wireless Interoperability Network (GWIN). By 

mid-May, Louisiana radios could communicate 
140

6. Logistics

in the coastal region from 

Orange Beach, Ala., to the 

Texas border; this system also 

provided limited GWIN coverage in the Houston, Texas—

connectivity that proved 

important later as heavy 

weather plans involved relocating parts of the response 

organization to Houston, 

Texas.

Beginning in mid-May 2010, 

the RP also began utilizing Louisiana’s existing 

radio network. The network was a repeater-based 

system operating primarily in the VHF-FM business 

band throughout the Gulf region. Ultimately totaling 

17 repeater or gap-fi ller sites, this network provided 

repeater based radio coverage throughout the fi vestate theater of operations. Most repeat locations 

also included one or more VHF-FM marine band 

channels and a VHF-AM air-ground frequency. All 

radios were connected using Motorola Motobridge 

equipment, and were controlled from Incident Communication Centers (ICCs) throughout the region. 

With radio operators, communication technicians 

(COMTs) and INCMs at each ICC (more than 10 

ICCs at one point), this network was the largest, 

most complex radio system deployed for a single 

emergency response, and it continues to work well.

The RP provided VHF radios, which operated on 

the RP’s network, to VOO squadron leads. The RP 

managed the VOO program, which is discussed 

in more detail earlier in this report. Communications with offshore cutters equipped with satellite 

capability was facilitated by the mobile ICP from 

Communications Area Master Station Atlantic.

In addition to utilizing state and RP communications equipment when available, the Coast Guard 

used large Coast Guard vessels or personnel aboard 

commercial vessels, such as the Seacor Lee, to coordinate communications as vessels ranged further 

offshore.

Aviation Communications

With more than 200 missions per day at the height 

of the response, establishing a communications plan 

for aircraft assets was critical. Complicating the 

aviation communications-planning task was the 

many commercial aircraft contracted to provide 

operations capability which only had one or two 

aviation band radios, which limited their communications capability.

Customs and Border Protection P-3 aircraft were 

used for both communications coordination as 

well as airspace de-confl iction. The P-3 aircraft 

personnel obtained commercially available headsets suitable for aircraft operations, allowing the 

use of the RP handheld radios and the RP radio 

network. This arrangement signifi cantly improved 

air-to-ground communications. All frequencies 

were added to the RP radio network on several 

tower locations, providing additional coverage. 

Finally, the establishment of the Aircraft Operations Center at ICP Houma improved fl ight planning and frequency management.

The ESU and C4IT team worked with the U. S. 

Department of Defense (DOD) and other governmental agencies to establish the Aviation 

Coordination Center at Tyndall Air Force Base in 

Panama City, Fla. There were numerous network 

security and authorization challenges to support 

Coast Guard personnel in the Air Force command 

and control environment. C4IT personnel successfully installed Coast Guard Secret Internet Protocol 

Router Network (SIPRNET) terminals and provided Coast Guard network connectivity to Coast 

Guard response members.

Rescue 21 Utilization

Early in the response, the Coast Guard decided not 

to use Rescue 21 (R21) capability as the primary 

communications system for the event. There were 

several reasons for this. The Sectors involved did 

not have the physical space to add watch standers and workstations to coordinate the Deepwater 

Horizon response and there was uncertainty as to 

whether the Coast Guard Data Network or R21 

could handle the additional voice and data traffi c 

generated by the Deepwater Horizon response.

All Deepwater Horizon communications ultimately used the Louisiana and RP networks to 

the maximum extent, with emergencies reported 

via Channel 16 VHF as would normally occur.

Information Management: Network 

connectivity and infrastructure

Bandwidth during the initial stages of the response 

was strained. Both the UAC, when located in Robert, La., and ICP Houma experienced signifi cant 

problems with Remote Access Solution (RAS) 

and terminal server connectivity, primarily due 

to constraints of available bandwidth.

MOBILE, Ala. – A U.S. 

Coast Guard Petty 

Offi cer disseminates 

the coordinates of oil 

sheens provided by 

personnel in aircraft to 

off shore vessels in the 

Gulf of Mexico. The large 

screen being monitored 

displays real time vessel 

tracking in the Gulf. 

Photo courtesy of U.S. 

Coast Guard
6. Logistics

141

The use of local domain controllers, fi le, and print 

servers, in conjunction with moving response personnel profi les, proved effective in resolving most 

connectivity issues for users. The RP deployed 

much of their bandwidth over wireless connections, making it very diffi cult to connect and use 

Coast Guard standard workstation laptops until the 

Coast Guard Data Network was available.

TISCOM and the C4IT SC were very responsive 

to operational requirements. Multiple high capacity, DS-3 and T-1 cables in various confi gurations 

were ordered and provisioned in very short order. 

Integration of Coast Guard and RP IT support 

was effective even during the early stages of the 

response and helped prevent duplication of efforts. 

The use of different colored cables made it easy 

to identify Coast Guard versus RP networks when 

connecting computers.

As it became apparent that the spill response would 

continue, TISCOM invoked National Security or 

Emergency Preparedness Telecommunications 

(NS/EP) policy to provision the UAC and ICPs 

with Coast GuardOne T1 broadband circuits. This 

provided each location with the same connectivity 

as most other Coast Guard units.

Electronically Stored Information

As discussed in Chapter 5, prior to the beginning of 

the response there was no existing process to collect response data for the purposes of administrative record maintenance required by the NCP and 

needed for electronic discovery related to possible 

litigation. Protocols to ensure capture of Electronically Stored Information (ESI) were developed 

with the assistance of the Department of Justice 

over the course of the response.

Imposition of a uniform nomenclature for the event 

(Deepwater Horizon) helped the process of fi nding and collecting ESI, as did the order to fi le 

response related ESI separately from Coast Guard 

user’s other electronic data. Creation of on-site 

servers and transfer of Coast Guard user profi les 

to the response servers upon arrival, once set up, 

made the process of segregating response ESI 

much easier. The process of locating and archiving 

all response related information was complex, 

because local servers were not running until well 

into the response and support to the response was 

provided from throughout the Coast Guard.

6.9 Support Logistics: Federal On-Scene 

Coordinator Logistics Policies

From an organizational construct, it became apparent in May 2010 that the Coast Guard would have a 

large number of its personnel involved in the Deepwater Horizon response for an unknown time. Consequently, the Coast Guard saw the need to create 

a support structure at the UAC similar to a large 

VENICE, La. – A geologist, who volunteered his time to fi nd birds aff ected by the 

Deepwater Horizon oil spill, conducts an hourly radio operations check along 

the Gulf of Mexico shoreline. Photo courtesy of U.S. Air Force
142

6. Logistics

Coast Guard Sector, with the ICPs and Branches 

as the operational fi eld units. The goal was to bring 

structure to the burgeoning organization, similar to 

starting a new unit. The UAC would set policies and 

provide services that would extend to the ICP and 

Branch. These included: 

• Providing Coast Guard Services and policies 

related to the administration and discipline of 

personnel; 

• Setting work hours, watch rotations, and schedule expectations;

• Implementing a performance evaluation system to capture members’ performance while 

assigned to the Deepwater Horizon response; 

• Implementing Commandant polices, providing guidance and assistance with travel claims 

and Joint Federal Travel Regulations related 

entitlements; and 

• Establishing check-in, orientation, and checkout procedures for Coast Guard members.

The Logistics Section also arranged for services for 

members similar to any Coast Guard unit, including 

• Providing accessible medical and dental care 

and guidance; 

• Establishing a motor pool with policy guidance;

• Providing adequate Employee Assistance 

Program; 

• Providing access to chaplains and religious 

services; 

• Providing Incident Command System (ICS) and 

job-specifi c training for members by bringing 

in contractors to teach ICS classes; and

• Establishing the Pollution Investigator and Federal On-Scene Coordinator’s Representative 

(FOSCR) training at Coast Guard Base Support 

Unit New Orleans.

While all policies and associated information were 

posted on the Homeland Security Information 

System Network per DHS guidelines, there was 

still some confusion with the implementation and 

enforcement of common policies. This resulted from 

the constant turnover of Coast Guard personnel as 

the response continued over the course of many 

months. With the turnover of personnel, institutional 

knowledge became lost, requiring the constant retraining of new personnel on some policies and 

processes.

6.10 Support Logistics: Area Command 

Critical Resources Unit

Located within the Planning Section at the UAC, 

the Area Command Critical Resources Unit Leader 

(AC CRESL) processed all critical resource 

requests. The AC CRESL received the requests, 

fi lled the orders, and tracked all of the critical 

resources for the Deepwater Horizon response.

Per Chapter 13 of the Incident Management Handbook, COMDTPUB P3120.17A, the AC CRESL is 

responsible for submitting critical resource needs 

to the AC Logistics Section Chief, and the AC 

Logistics Section Chief is responsible for obtaining the requested critical resources; however, 

this construct was modifi ed for the Deepwater 

Horizon response in that the AC CRESL actually 

obtained all of the needed critical resources for the 

response. After the AC CRESL had received the 

critical resources, Resource Request Forms ICS213RR were submitted to the Logistics Section 

for documentation.

There were only two designated critical resources 

at the beginning of the response, hard boom and 

high-capacity skimmers. The RP directly procured boom and provided high-capacity skimmers 

beyond federally controlled resources. Boom was 

so critical that the RP appointed a specially designated point of contact from its corporate offi ces 

to implement a comprehensive boom acquisition 

and distribution strategy from the Area Command 

Critical Resources Unit. Boom and skimming 

resources are discussed in further depth in Chapter 3 of this report, Operations.

MOBILE, Ala. – The Coast 

Guard enhanced mobile 

incident command 

post is parked just 

outside the Mobile, Ala. 

Incident Command Post 

to provide additional 

communications for 

operations in the Gulf of 

Mexico. Photo courtesy 

of U.S. Coast Guard
6. Logistics

143

6.11 Support Logistics: Resource 

Request Process

In addition to structure, policy, and critical resources 

(i.e., boom and skimmers), the FOSC needed many 

other resources, and followed the ICS pre-established policies for requesting those resources. The 

standard Resource Request Form, ICS-213RR, was 

used for all resource requests. All resource requests 

at the UAC were tracked in an Excel spreadsheet 

called the Mississippi Canyon 252 log, using an 

assigned, sequential number for each request.

Each ICS-213RR had to be signed by the requestor, 

the applicable incident command section chief, and 

the Resource Unit Leader (RESL) prior to being 

signed by the Logistics Section Chief. The RESL 

confi rmed whether the requested resource was 

already assigned to the response and currently 

available for disposition. After the Logistics Section Chief signed the form, it was routed to the 

Finance Section Chief for procurement, or travel 

order number assignment (TONO) for personnel 

orders if necessary, and signature. All original documentation was turned into the Documentation Unit 

Leader, and copies were retained in the fi les.

Each resource request recorded in the Mississippi 

Canyon 252 log at UAC was cross-referenced with 

the applicable Mobilization Readiness Tracking 

Tool (MRTT) number for Coast Guard personnel 

requests, and the applicable Request for Assistance 

(RFA) number with the corresponding Military 

Interdepartmental Purchase Request (MIPR) number for DOD and State National Guard requests 

(discussed in more detail below). Requests for 

critical resources were specially annotated in the 

Mississippi Canyon 252 log.

Each ICP utilized a unique numbering system 

to track its specifi c resource requests. Resource 

requests at the UAC and ICP were also entered 

into Homeland Security Information Network to 

create a permanent record.

6.12 Support Logistics: Requests for 

Assistance (RFA) from the Department of 

Defense (DOD) and State National Guards

RFAs were available for DOD and state National 

Guard resources. DOD resources utilized included 

aircraft, vessels, spill equipment, and skimming 

equipment. DOD, the National Guard Bureau, and 

each of the four state National Guards involved 

with the response had liaison staff at the UAC. The 

Coast Guard worked with these individuals at the 

UAC to process the RFAs and resulting MIPRs for 

the response.

The RFA staff at the UAC had a unique position 

within the ICS construct. Chapter 13 of the Incident Management Handbook does not specifi cally 

address RFAs, DOD, or National Guard resources. 

At the outset of the response, the RFA staff was a 

command staff element that reported directly to the 

Coast Guard Area Commander and Deputy Area 

Commander; however, this was quickly modifi ed 

in early May 2010 when a decision was made to 

incorporate the RFA staff under the Logistics Section. This provided better management and oversight of the personnel who performed this very high 

profi le task. Moreover, it ensured that the processing 

of these requests was standardized and consistent 

with the processing of all other resource requests 

for the response.

For the DOD resources, the Coast Guard needed an 

ICS 213RR form to start the RFA process. Additionally, the National Guard required a Fragmentary 

Assistance Assignment (FAA) document to proceed with the RFA process. A memo was created 

for the FOSC’s review and signature. While the 

RP was given the opportunity to approve all RFAs 

via signature on the ICS-213RR, the RFA was still 

processed even if the RP refused to sign it, as long 

as the FOSC approved it.

Once the FOSC signed the documents, DOD or 

the respective state National Guard were notifi ed. 

Working concurrently with the contracting offi cer in 

the Finance Section, a MIPR number was assigned 

to fund the RFA. Once the CRU had all signatures 

on the paperwork and a MIPR number to ensure 

funding, everything was scanned into Homeland 

Security Information Network to create a permanent 

record. An entry was also made into a sequential 

RFA log for tracking purposes.

ICPs used their established resource ordering processes approved by the UAC. The only exceptions 

were requests for critical resources, RFAs, and Pollution Removal Funding Authorizations (PRFAs), 

which had to be approved by the FOSC at the UAC. 

In addition, requests for Coast Guard assets that 

could not be fi lled through the local Sector or Air 

Station, and all requests for Coast Guard personnel, 

were routed through the UAC.
144

6. Logistics

The RFA staff developed a report for the tracking 

of the personnel, equipment levels, and funding 

that was authorized for each of the state National 

Guards, RFAs and MIPRs. The report tracked the 

expiration of any RFA and prompted the RFA staff 

to initiate renewal or allow the expiration of each 

RFA in the form of a notifi cation reminder 10 days 

prior to the RFA expiration date.

When the services or period outlined in the RFA 

and MIPR were complete, the RFA and MIPR were 

either amended to extend the period of performance, 

if the resources were still required, or the RFAs and 

MIPRs were allowed to expire and closed out. RFAs 

and MIPRs were frequently amended to adjust the 

amount of funding or the period of performance of 

the resources involved.

The closeout process for an RFA required coordination with the DOD or respective state National 

Guard staff, as well as the contracting offi cer in 

the Finance Section. This coordination ensured the 

MIPR funding was accurate for the RFA.

6.13 Support Logistics: Organization and 

Facilities

The UAC was initially located in Robert, La., and 

managed four ICPs, each with numerous Branches, 

and Staging Areas. The UAC was organized per 

Chapter 13 of the Incident Management Handbook 

(COMDTPUB P3120.17A).

At the start of the response, the three ICPs were ICP 

Houma, La., ICP Mobile, Ala., and ICP St. Petersburg, Fla. There was also a contingent of Coast 

Guard technical specialists assigned to source control with the RP in Houston, Texas, which evolved 

into an ICP. ICP Miami, Fla., was organized at the 

end of May 2010.

The RP provided the facilities for the UAC, ICP, 

Branches, and Staging Areas. Within Robert, La., 

the UAC was located at the Shell Company Training Facility. This created a unique situation because 

Shell initially had students and staff at the facility in 

addition to the RP, Coast Guard, and other agencies 

personnel associated with the Deepwater Horizon

response.

As the number of Deepwater Horizon personnel 

at the UAC grew, the RP constructed additional 

offi ce trailers in the parking lot. In June, the Coast 

Guard worked with the RP on a cohesive plan to 

move to a location that could accommodate all 

personnel, including computers, phones, and associated equipment.

The Coast Guard used a badge system provided by 

the RP to identify all Deepwater Horizon personnel 

on site. The badge system and accompanying software enabled the UAC to obtain daily manpower 

summary reports of the total number of Deepwater 

Horizon personnel located at the UAC. This same 

badge system and software were used at the ICPs, 

and to some extent at the Branches and Staging 

Areas, enabling the report of manpower data for 

the entire response. While this system did capture 

the number of personnel at the location on a daily 

basis, it was not designed to capture the number of 

hours worked.

By way of example, from May 31, 2010, to June 

1, 2010, there were a total of 382 Deepwater Horizon response personnel at the UAC, including 202 

federal government personnel (e.g., Coast Guard, 

DOD, and other federal agencies), as tracked by the 

RP badge system and software.

The UAC ultimately became too large for the Robert, La., facility, and the decision was made to relocate the UAC to New Orleans, La.

The RP directly procured and leased all facilities for 

the Deepwater Horizon response at its own expense. 

Thus, the facility role of the Coast Guard’s Logistics Section coordinated with the RP to ensure the 

UAC and the government responder requirements 

were met.

The Coast Guard executed a small number of leases 

for evidence storage and preservation locations following extensive discussion with Coast Guard, the 

RP, and Department of Justice. It was decided that 

the government would execute and fund separate 

leases for evidence storage.

The Coast Guard also executed MIPRs with the 

Air Force and Navy to provide aircraft and mooring facilities at Tyndall Air Force Base and Naval 

Station Pensacola.

For UAC logistics, the only facility obtained separate from the facilities procured by the RP was the 

Readiness and Assessment Team (RATT) at Coast 

Guard Base Support Unit (BSU) New Orleans.

Staging areas for boom and other resources were 

established by the individual ICPs logistics and 

resources personnel. In early June 2010, logistics 

experts from Coast Guard Headquarters and DOD 

were brought to the UAC to assist in creating an 

effective property staging and distribution system.
6. Logistics

145

The Logistics Sections at the respective ICPs 

ensured the Coast Guard staff at each staging area 

had the communications, IT, and safety equipment 

needed to oversee RP logistics with the ordering of 

critical resources. Staffi ng at Staging Areas fell to 

the Operations Section. All major equipment held at 

Staging Areas was the responsibility of the Logistics 

Section.

6.14 Support Logistics: Vehicles and 

Transportation

The Coast Guard created a Ground Support Unit 

(GSU) at the UAC in the end of May 2010. For the 

most part, the RP contracted for extensive transportation capabilities throughout the impacted area, and 

thus the need for separate government transportation was not pressing until the size of the organization began to expand. The RP provided shuttle van 

transportation for all UAC members to and from 

the UAC to the contracted accommodations and 

the airport. Rental cars were authorized for certain 

members of the UAC because the nature of their 

work required extensive travel around the region.

The Ground Support Unit Leader at the UAC established a motor pool operation in May with General 

Service Administration (GSA) and Navy vehicles. 

The Ground Support Unit Leader acquired 71 vehicles for use by government personnel assigned to 

the Deepwater Horizon response. These vehicles 

provided low cost transportation services for members to and from airports and assigned locations, 

as well as for trips through the region for readiness and response related activities. The Finance 

Section secured payment for all vehicles from the 

Navy using the OSLTF accounting string. This was 

after the NPFC confi rmed that the vehicles were 

an acceptable expense to be charged against the 

OSLTF.

A majority of the GSA leased vehicles were forward 

deployed to fi eld personnel, with a few remaining 

on hand at the UAC for daily check-out through the 

Ground Support Unit Leader.

6.15 Support Logistics: Lodging and 

Feeding

Lodging for UAC personnel was provided using 

RP concierge services. The RP provided rooms 

at hotels in cities located near the Shell Training 

Facility in Robert, La., and later the UAC in New 

Orleans, La. The Coast Guard decided to require use 

of this lodging, both in Robert and New Orleans, 

as it greatly assisted in personnel accountability, 

particularly in the event of severe weather evacuation. It also eliminated the need for Coast Guard 

members to pay for rooms, and simplifi ed travel 

claims because no reimbursement for this expense 

was required. Other government agencies made 

their own decisions regarding use of 

RP procured lodging, but they were 

offered this option.

The RP also provided meals at 

the UAC, ICPs, and some larger 

Branches. This eliminated the need 

for a Food Services Unit under the 

Logistics Section within the ICS 

organization at the UAC and ICPs

Personnel assigned to the ICPs 

located in Houma and Mobile, Ala., 

were also provided accommodation 

and meals. Overall, ICP Mobile had 

few problems with lodging. However, 

as a result of the surge in Coast Guard 

personnel in late May and June 2010, 

there was inadequate housing available in the Houma area. Responders 

were provided accommodations in 

New Orleans hotels, and traveled the 116-mile 

round-trip to ICP Houma. The scarcity of lodging 

was a theater-wide problem, not limited to Houma.

6.16 Support Logistics: Personnel

The majority of the resource requests processed 

were for Coast Guard personnel. The PRU was relocated from Coast Guard District Eight offi ces in 

New Orleans, La., to the UAC, under the Logistics 

Section in May 2010. A detachment was established 

at Base Support Unit New Orleans, to facilitate a 

central staging of all Deepwater Horizon personnel, 

including training, medical, and all items necessary 

to ensure members were ready to be deployed into 

the fi eld. At the end of May, this responsibility transitioned to the CRU working within the Logistics 

section at the UAC.

An important step in trying to structure the Deepwater Horizon response operation was the establishment of a personnel allowance list similar to any 

Coast Guard unit. This personnel allowance list 

GRAND ISLE, La. – A tug 

is moored to a fl oating 

hotel (fl otel) which 

houses approximately 

80 contract workers for 

the Deepwater Horizon

response. The fl otel 

provides a galley, laundry 

facilities, television, 

rooms, and wireless 

internet. Photo courtesy 

of U.S. Coast Guard
146

6. Logistics

would specify all needed Coast Guard positions by 

number at the UAC, ICPs, Branches, and other locations, and the persons who would fi ll each of those 

positions. The system had to be fl exible to account 

for increases, decreases, and changes of positions 

on the list, and had to track the dynamic rotation of 

personnel assigned at all locations of the response.

By the end of May 2010, the process had matured. 

The FOSCs and FOSCRs identifi ed and forwarded 

personnel needs to the Resource Unit Leader. The 

Resource Unit Leader would then canvass internal 

to the response for potential personnel resources to 

fi ll the request. If not available, the UAC Logistics 

Section attempted to source the request from within 

the local Coast Guard district through the PRU.

If the Resource Unit Leader could not locate a personnel resource, the UAC or ICP forwarded a signed 

standard Resource Request Form (ICS 213RR) to 

the UAC CRU. The requirement was entered into 

MRTT and the resource request was processed. To 

process an ICS 213 RR request for personnel, the 

UAC Logistics Section sent a Request for Forces 

(RFF) message to Atlantic Area Command and 

transmitted the request in MRTT for nationwide 

sourcing, as discussed in Chapter 9. TONOs and 

accounting data were provided by UAC Finance 

Section, and funded by the OSLTF.

Coast Guard civilian personnel were used at the 

UAC and ICPs, but it quickly became apparent that 

a mechanism was needed to provide overtime relief 

for these personnel. From a cost perspective, civilian 

personnel were an expensive resource due to paid 

overtime requirements.

Coast Guard auxiliarists also worked on the Deepwater Horizon response at various locations, providing 

expertise and service at the cost of only travel and 

per diem. There were 147 auxiliarists deployed to the 

response, and these personnel were a valuable asset.

6.17 Support Logistics: Personnel 

Demobilization

The demobilization process evolved over the course 

of the response. At fi rst, all personnel were required 

to complete a check-out process when they departed 

the UAC, and the forms were collected in a folder 

by the Coast Guard Logistics Section.

Improvements to this system continued as time went 

on, and the UAC Planning Section developed a 

more viable Demobilization Unit to better demobilize departing personnel. This involved the creation 

of a check-in recorder process under the Planning 

Section for incoming personnel. Both the check-in 

and check-out processes were functioning smoothly 

by the end of May 2010.

There was close coordination among the Logistics 

Section, Finance Section, and the Planning Section’s Resources Demobilization Unit to ensure 

all incoming and outgoing Coast Guard personnel 

were properly recorded.

The response established three locations for demobilization of personnel: 

1. ICP Mobile, Ala.; 

2. The RATT located at the BSU in New Orleans, 

La.; and 

3. The UAC, later the Coast Guard Incident Management Team (CG–IMT) in New Orleans, La.

It was important for each demobilization site to 

have the medical staff to conduct physicals and 

ensure the readiness status for Coast Guard members, especially Reservists who were demobilizing 

from the response.

The mobilization (check-in) and demobilization 

(check-out) processes were eventually integrated at 

the CG–IMT, consolidated data entry into one database to track and account for personnel in theatre.

The biggest personnel demobilization challenge 

involved Reserve members. All Deepwater Horizon

deployed Reserve forces underwent a medical readiness review when reporting in, and a demobilization 

review when departing the response. The Deepwater Horizon Event Health-Related Inventory and 

Reporting Tool was used to process both. In order to 

screen Reservists for medical readiness, processing 

points staffed with medical and dental staff were 

established at Coast Guard Base New Orleans and 

Aviation Training Center (ATC) Mobile. Accounting for care, orders, and unique medical issues of 

mobilized Reserves required signifi cant effort and 

the establishment of an infrastructure suffi cient to 

handle those issues.

6.18 Support Logistics: Property and 

Equipment

Property disposal was largely run through the 

Finance Section. With the concurrence of Coast 

Guard Headquarters, the signature authority for 

property surveys was delegated to the Coast Guard 

Logistics Section Chiefs.
6. Logistics

147

Proper demobilization helped ensure the items that 

were no longer needed were properly disposed or 

removed from contract if leased. This saved time 

and money for the Finance Section and provided 

accountability of equipment and personnel.

In preparation for demobilization efforts, the UAC 

Logistics Section tasked a member to travel the area 

to locate as much Coast Guard Marine Environmental Response equipment as possible. This member 

visited 72 staging areas and decontamination stations in four states, locating more than $2 million 

in equipment. This resulted in the effi cient reconstitution of the Coast Guard’s response capability 

equipment at the Central Maintenance facility in 

Prichard, Ala., for critical deployment elsewhere.

Electronic items, such as computers, phones, and 

data storage devices have particular requirements 

for disposition and archiving of data; please see 

Chapter 5 of this report for additional details. The 

removal of data from the units must be conducted by 

qualifi ed and knowledgeable personnel. A location 

was created for this task and the process required 

the equipment to be transported to the documentation warehouse in Mandeville, La., for information 

retrieval. The equipment was then sent to a warehouse in Harahan, La., for accounting consolidation and fi nal disposition. This processed crossed 

many organizational boundaries—Legal, Finance, 

Command, Control, Communications, Computing, Information Technology, Civil Engineering, 

and Security.

Demobilization, decontamination, and disposition 

of critical resources, such as boom, VOSS, SORS, 

and cutters, became logistically challenging. It was 

critical to have a documented process for accounting for equipment from deployment to recovery.

The table below outlines the Coast Guard Deepwater Horizon response inventory as of March 2011. 

It does not capture the inventory assigned at the 

peak of the response.

The RP consolidated facilities as response requirements changed. The Coast Guard supervised these 

efforts to ensure the response was the right size, 

and that facilities were adequate to enable current 

response operations. When closure of a facility 

occurred, the personnel employed were demobilized or relocated to other parts of the response 

organization.

Table 6.2: 

Total Response 

Inventory

Item Type Quantity Value

Computers - Each 1,551 $2,030,915.99

Electronics Equipment and Supplies - Each 2,772 $346,801.78

PPE - Each 521 $118,962.43

Electrical Equipment – Each 144 $6,836.96

BOOM - Feet 3,131,107 $680,000.00

Cleaning Equipment – Each 38 $0.00

Dispersant - Gallon Drum 142 $0.00

Facilities - Each 60 $0.00

Portable Storage - Each 415 $0.00

Pumps - Each 94 $1,043,055.00

Skimmers - Each 57 $997,150.00

General Support Resources - Each 107,399 $1,456,201.22

Trailer - Each 54 $996,538.95

Vehicle - Each 43 $635,649.00

Vessels - Each 18 $0.00

Barge - Each 4 $236,484.00

Total Warehouse Inventory 3,244,419 $8,548,595.33
148

6. Logistics

6.19 FOSC Key Point

Vessels of Opportunity Protocols

There were valuable lessons learned about how to 

employ Vessels of Opportunity during the Deepwater Horizon response. For instance, pre-scripted 

requirements for safe operating of VOO platforms 

would be helpful if outlined in Area Contingency 

Plans. These could inform a FOSC, who could then 

more knowledgeably assess VOO operators and 

platforms. A pre-scripted format or set of requirements for VOOs is important to safety and effectiveness. An example of a minimum prerequisite safety 

level for evaluating suitability of a fi shing vessel 

or VOO would be a current Coast Guard courtesy 

vessel exam and sticker carried on board the vessel
7. Finance

149

7.1 Response Funding

The Deepwater Horizon response required 

an unprecedented level of activity, not only 

from the Responsible Party (RP), but from 

government agencies at the federal, state, and local 

level, including Department of Defense assets.

These elements could not be mobilized without 

substantial fi nancial resources. Although the RP 

was willing to pay for the response, it is not possible for agencies to receive direct funding from 

any RP. This funding comes from the Oil Spill 

Liability Trust Fund (OSLTF) and is administered 

by the Coast Guard’s National Pollution Funds 

Center (NPFC).

The OSLTF, established in the Department of Treasury, was created in the Oil Pollution Act of 1990 

(OPA 90) and is available to pay the expenses of a 

federal response to oil pollution under the Federal 

Water Pollution Control Act, 33 U.S.C. 1321(c), 

and to compensate claimants for oil removal 

costs and certain damages caused by oil pollution, as authorized by OPA 90 (33 U.S.C. 2701). 

The OSLTF expenditures are generally recovered 

from the RP, liable under OPA 90, when there is 

a discharge of oil to navigable waters, adjoining 

shorelines, or the Exclusive Economic Zone.

The OSLTF is established under Internal Revenue Code section 9509 (26 U.S.C. 9509), which 

describes the authorized revenue streams and certain 

broad limits on its use. The principal revenue stream 

is an eight cent per barrel tax on oil produced or 

brought into the United States (26 U.S.C. 4611). 

The tax expires at the end of 2017. Other revenue 

streams include oil pollution related penalties under 

33 U.S.C. 1319 and 33 U.S.C. 1321, interest earned 

through Treasury investments, and recoveries from 

liable responsible parties under OPA 90. At the onset 

of the Deepwater Horizon response the OSLTF 

balance was approximately $1.6 billion. There is 

no cap on the fund balance, but there are limits on 

its use per oil pollution incident.

OPA 90 further provides that the OSLTF is available to the President for certain purposes (33 

U.S.C. 2712(a)). The fi rst purpose includes payment of federal removal costs consistent with the 

National Contingency Plan (NCP). This use is 

subject to further appropriation, except that the 

President of the United States may make available 

up to $50 million annually to carry out 33 U.S.C. 

1321(c), removal actions, to initiate the assessment 

of natural resource damages. This initial funding 

is considered the OSLTF 

Emergency Fund (EF), and 

is available until expended. 

An additional $100 million may be advanced from 

the OSLTF when the EF 

is inadequate, subject to 

notification of Congress 

no later than 30 days after 

the advance (33 U.S.C. 

2752(b)). Additional amounts from the OSLTF for 

federal removal are subject to further appropriation.

The payment of claims for uncompensated removal 

costs and damages are not subject to further appropriation from the OSLTF (33 U.S.C. 2752(b)). 

The advancement authority and appropriation 

process was used for the fi rst time during this 

response. Congressional action to acquire additional advancements was also required on multiple occasions as the scope of government activity 

expanded with the ongoing release of oil.

The second purpose of the OSLTF includes payment for natural resource damages in an amount no 

more than $500 million, as mandated by 26 U.S.C. 

9509(c)(2). The maximum amount available from 

the OSLTF for any one incident is $1 billion.

The third purpose includes payment of federal 

administrative, operating, and personnel costs 

to implement and enforce the broad range of oil 

pollution prevention regulations. Response and 

compensation provisions are addressed by OPA 90 

and are subject to further appropriation to various 

federal agencies. For Fiscal Year (FY) 2010 this 

amount was $92 million.

As the response progressed, OSLTF costs were 

documented in the fi eld and provided to NPFC for 

reconciliation and eventual cost recovery against 

the RP. Federal trustees also requested funds to 

initiate an assessment of natural resource damages, 

which the NPFC provided from the EF.

On April 22, 2010, the Federal On-Scene Coordinator (FOSC) requested an initial monetary ceiling 

for the Deepwater Horizon incident. At that time, 

the balance of the EF was $40 million. As the 

scope of the incident grew, it consumed a growing portion of the available EF balance. It quickly 

became apparent that the response was going to 

exhaust both the balance of the EF and the pending 

GULF SHORES, Ala. 

– A National Oceanic 

and Atmospheric 

Administration employee 

diligently takes notes 

and makes use of a GPS 

to gather exact locations 

and record data. The 

data is passed daily to 

the Deepwater Horizon

response Unifi ed Area 

Command in New Orleans, 

La. Photo courtesy of U.S. 

Coast Guard
150

7. Finance

Table 7.1: Federal 

Project Number 

N10036 for OSLTF 

funds tracking 

purposes. 

Date

Amount Available 

For All Other 

Federal Responses

FPN N10036

Federal Project 

Ceiling

FPN N10036 

Unobligate 

Balance

Remarks

4/20/2010 $107,000,000.00 $0.00 $0.00

Explosion occurs on the Deepwater Horizon on 

station and latched up at Mississippi Canyon 

252.

4/21/2010 $106,675,000.00 $25,000.00 $25,000.00 The Oil Spill Liability Trust Fund (OSLTF) 

Federal Project No. 10036 Ceiling (Ceiling) 

is assigned, and opened by the Federal OnScene Coordinator (FOSC).

4/22/2010 $105,675,000.00 $1,000,000.00 $1,000,000.00 First Ceiling increase.

4/26/2010 $95,675,000.00 $10,000,000.00 $10,000,000.00 Second Ceiling increase.

4/30/2010 $75,675,000.00 $30,000,000.00 $30,000,000.00 Third Ceiling increase.

5/5/2010 $62,000,000.00 $45,000,000.00 $15,826,929.24

Fourth Ceiling increase. Initiation of Natural 

Resource Damage Assessment (NRDA) 

Interagency Agreement (IAG) between 

Federal Natural Resource Trustees and the 

National Pollution Funds Center (NPFC) set at 

$4,182,704.00.

5/10/2010 $42,000,000.00 $65,000,000.00 $19,905,507.55 Fifth Ceiling increase.

5/16/2010 $37,211,834.16 $85,000,000.00 $14,797,952.14 Sixth Ceiling increase.

5/21/2010 $37,211,834.16 $100,000,000.00 $33,827,058.80 Seventh Ceiling increase.

5/26/2010 $18,622,348.00 $120,000,000.00 $37,247,179.13 Eighth Ceiling increase.

5/28/2010 $4,564,676.00 $135,000,000.00 $33,674,992.70 Ninth Ceiling increase.

6/8/2010 $40,283,825.27 $150,000,000.00 $35,856,725.93 Tenth Ceiling increase.

6/12/2010 $29,135,171.28 $160,000,000.00 $22,229,606.88 Eleventh Ceiling increase.

6/17/2010 $29,849,213.91 $260,000,000.00 $69,899,102.75

Twelfth Ceiling increase. $100 million request 

for appropriation funds to the Emergency 

Fund from the Principal Fund of the OSLTF 

per P.L. 111-91 approved by the Offi ce of 

Management and Budget (OMB). 

6/23/2010 $29,367,435.48 $259,500,000.00 $61,339,236.85

NRDA IAG increased by $500,000.00 to 

$4,682,704.00. Ceiling lowered by $500,000 to 

fund this increase.

7/2/2010 $31,543,260.69 $359,500,000.00 $117,382,256.65

Thirteenth ceiling increase. $100 million 

apportionment from the Principal Fund 

received per P.L. 111-191.

7/27/2010 $26,943,058.90 $442,500,000.00 $96,931,832.10

Fourteenth Ceiling increase. $100 million 

apportionment from the Principal Fund 

received per P.L. 111-191. $83 million is 

applied to the FOSC’s Federal Project Ceiling. 

The NRDA IAG is increased by $17,732,421 to 

a new total of $22,415,125.00.

8/5/2010 $26,775,308.71 $441,767,579.00 $71,403,367.88 The Ceiling is lowered by $732,421 to provide 

funding for the NRDA IAG.

8/6/2010 $21,328,992.39 $541,767,579.00 $106,524,514.67

Fifteenth Ceiling increase. $100 million 

apportionment from the Principal Fund 

received per P.L. 111-191.

9/1/2010 $16,430,233.02 $641,767,579.00 $117,676,985.61

Sixteenth Ceiling increase. $100 million 

apportionment from the Principal Fund 

received per P.L. 111-191.

10/19/2010 $55,686,780.52 $741,767,579.00 $133,728,169.33

Seventeenth Ceiling increase. $100 million 

apportionment from the Principal Fund 

received per P.L. 111-191. Also, OMB executes 

the regular $50 million annual Emergency 

Fund apportionment for FY 2011.

10/21/2010 $55,419,232.65 $714,178,588.00 $105,999,042.63

The Ceiling was lowered by $27,588,991.00 

to provided additional funding for the NRDA 

IAG. Total funding for the NRDA IAG is now 

$50,004,116.00.

 
7. Finance

151

one-time $100 million advancement provision of 

OPA 90. The fund was in extremis.

The Coast Guard proposed legislation extending 

advance authority beyond $100 million. While 

waiting for the expanded advancement authority, 

the Coast Guard received the $100 million advance 

from the OSLTF principal fund prescribed in OPA 

90. The Coast Guard also requested and received 

an apportionment of $50 million from FY 2006. 

(The FY 2006 apportionment had not been provided previously due to a substantial carry over balance in the EF that year.) The expanded response 

consumed this infusion of funding. In order to 

sustain its response while waiting for additional 

funding, the Coast Guard transferred 

its response obligations and expenditures to the Coast Guard Operating 

Expense appropriation. Additionally, 

the period of performance of existing 

Military Interdepartmental Purchase 

Requests (MIPRs) with Department 

of Defense was reduced to two 

weeks from a month. These actions 

sustained the response until Public 

Law 111-191 was enacted and signed 

authorizing additional advancements from the Principal Fund for 

the Deepwater Horizon response 

subject to the $1 billion cap on the 

overall incident. If the incident had 

happened later in the fi scal year, the 

EF would have reached extremis

sooner. If that had been the case, 

the Coast Guard would not have had 

the capacity in the operating expense 

appropriation to extend the response.

As of February 2011, the Coast Guard received 

$700 million in advances from the Principal 

Fund—$100 million in accordance with the 

advance provisions in OPA 90 and $600 million 

as authorized in Public Law111-191. Table 7.1 outlines the overall OSLTF balance and the specifi c 

advances made to the Deepwater Horizon response 

effort regarding Federal Project Number (FPN) 

N10036 for OSLTF funds tracking purposes.

The unprecedented nature of this response—an 

uncontrolled, substantial release for 87 days—

required funding unlike any other response in the 

history of the OSLTF. Even though the RP was 

willing to fund government activities, it was diffi -

cult for them to provide funding in a way agencies 

could accept. As such, the OSLTF performed a 

valuable function in distributing funds to these 

agencies and in seeking reimbursement by the RP.

Even though the OSLTF was reimbursed by the RP, 

reimbursements did not count as credit against the 

$1 billion statutory cap on spending for any one 

incident. Accordingly, the balance of the OSLTF 

became less important than the incident cap of $1 

billion, which made possible a scenario whereby 

the OSLTF was fully viable, but could not be used 

for any further response actions or the payment of 

claims. The OSLTF is not like a checking account 

that is rebalanced when the RP pays an NPFC 

invoice.

At its inception, a $1 billion OSLTF seemed 

suffi cient to provide for potential government 

involvement in a spill response. The passage of 

time combined with an ongoing and uncontrolled 

release, provided compelling evidence that such 

a limitation could prevent the government from 

protecting the nation. Additionally, an incident of 

this size and character involving an RP without 

the extensive resources of a major oil company 

would stress the OSLTF beyond its ability to 

fi nance response operations.

GONZALES, La. –

Approximately one 

million feet of readyto-deploy sorbent 

boom was stored 

at the Lamar-Dixon 

Staging Area. Photo 

courtesy of U.S. 

Coast Guard
152

7. Finance

7.2 Responsible Party Liability, Role, 

and Funding

Liability for the Deepwater Horizon oil pollution 

incident is governed in part by OPA 90. OPA 90 

provides that a designated RP or RPs are strictly 

liable for oil removal costs and certain damages 

that result from a discharge or a substantial threat 

of discharge of oil from a vessel or facility into 

or upon the navigable waters, adjoining shorelines, or exclusive economic zone of the United 

States subject to the limits of the RP’s liability. 

Damages include natural resource injuries, loss or 

injury to real or personal property, loss of profi ts 

and earning capacity, loss of subsistence use of 

natural resources, loss of government revenues, 

and increased public services expenses of a state 

or political subdivision. Any person may present a claim to the RP for uncompensated removal 

costs or damages. Generally, the RP for an offshore 

facility is the lessee or permittee of the area where 

the facility is located. When a Mobile Offshore 

Drilling Unit (MODU) is operating as an offshore 

facility and a discharge occurs on or above the 

water surface, the MODU is treated fi rst as a tank 

vessel for purposes of liability for that discharge. 

The RP for the tank vessel is any owner, operator, or demise charterer. For removal costs and 

damages in excess of the vessel liability limit, the 

MODU is treated as an offshore facility and the 

RP is the lessee of the area.

RP liability for removal costs and damages under 

OPA 90 may be limited to certain amounts. For an 

offshore facility, OPA 90 may allow for liability 

to be limited to all removal costs plus $75 million 

for OPA 90 damages. Liability for any RP may be 

unlimited if the incident was proximately caused 

by gross negligence, willful misconduct, or violation of a federal regulation. OPA 90 provides for 

three defenses to liability. These defenses may 

apply when the incident is solely caused by an 

act of God, an act of war, or the act or omission 

of a third party.

7.3 Payment of Claims and Billing

On April 28, 2010, the NPFC, under its authorities and responsibilities delegated from 33 U.S.C. 

2714, designated BP as the RP for the Deepwater 

Horizon oil spill incident. BP accepted the designation. The NPFC further tasked BP to develop, 

implement, and advertise a claims process by 

which people could be made aware of their potential damages and how to submit claims under OPA 

90. Additionally, the RP was required to advertise 

that if a claimant was denied or not satisfi ed within 

90 days the claimant could submit that claim to 

NPFC for consideration. The NPFC provided regular updates to the FOSC regarding developments 

in the claims process and the FOSC then informed 

affected and concerned parties within the spill’s 

impacted area.

The RP worked quickly to comply with the requirements, and to establish a procedure for processing 

claims. The RP opened more than 30 claims centers throughout the Gulf Coast, and advertised its 

process in 35 newspapers, as well as local television and radio stations across the region. The RP 

also began a database for capturing information on 

the claims submitted through the local offi ces and 

the claims call center. Through the 2010 summer, 

its public notice included information relating to 

denied claims, the NPFC process, and NPFC contact information. This notice was also disseminated 

in Spanish and Vietnamese in media. Information 

on claims data was collected and passed through 

the NPFC to the FOSC.

To assist in handling claims, the RP contracted 

with one or more claims adjusting fi rms. Subsequently, on June 16, 2010, the White House issued 

a press release announcing that the RP would 

establish an independent claims facility and $20 

billion escrow fund to fulfi ll these and other legal 

GONZALES, La. – 

Approximately 300,000 

feet of ready-to-deploy 

containment boom is stored 

at this Staging Area for 

the Deepwater Horizon

response. Photo courtesy of 

U.S. Coast Guard
7. Finance

153

obligations. The claims facility is responsible for 

developing and publishing standards for recoverable 

claims, under the authority of Ken Feinberg, who 

would serve as an independent administrator. The 

RP announced that, effective August 23, 2010, the 

Gulf Coast Claims Facility (GCCF) would replace 

the original claims process and fulfi ll their obligations under OPA 90 with respect to private economic 

loss claims. On that day, the Gulf Coast Claims 

Facility (GCCF) began accepting and adjudicating 

claims for the RP. Like the RP, the GCCF advertised its process through a campaign that included 

more than 500 advertisements in approximately 

277 newspapers around the Gulf Coast. In addition, notifi cation posters were mounted in more than 

5,000 physical locations. Finally, all RP claimants 

received a letter from the GCCF notifying them that 

the GCCF was taking over the RP claims process 

and explainingt the requirements to maintain a claim 

before the GCCF. These letters included the tollfree number to the GCCF hotline and redirected 

those dissatisfi ed to the NPFC. Even as the FOSC 

downsized the response footprint, the claims process 

continues as required under OPA 90.

Potential claimants were informed of their options 

to submit a claim directly to the NPFC or to litigate 

with the NPFC if their claim was denied or not acted 

upon by the RP within 90 days. As of February 7, 

2011, the GCCF reported 486,704 unique business 

and individual claimants. Of that number, GCCF 

reports 254,402 claims paid totaling an amount 

in excess of $3 billion. By February 7, the NPFC 

received 541 additional claims, issued determinations on 282 claims and had 259 claims, valued at 

$29.5 million pending. No additional claims have 

been paid.

While no funds have been expended from the 

OSLTF for claims, approximately $700 million 

in removal costs were incurred and billed to the 

RP. Table 7.2 contains a record of invoices to and 

payments from the RP for the Deepwater Horizon

incident.

The RP did not have an adequate mechanism for 

funding multiple government agencies at every 

level of government. However, the RP’s contracting procedures mandated the establishment of a 

Master Vendor Agreement for providers of services. The establishment of such agreements with 

the federal government would have been problematic for both the RP and the United States.

While the RP was able to provide funding at the 

parish, county, and state levels through various 

mechanisms—primarily through a government 

claims process and grants—it was determined that 

the state National Guard elements that assisted 

with the response should be funded by the OSLTF, 

which is funded through interdepartmental agreements between the Coast Guard and the Department of Defense.

7.4 Finance Section Organization

Key functional areas of the UAC Finance Section were organized and titled using the Incident 

Management Handbook (IMH): Time Unit, Cost 

Unit, Procurement Unit, and Claims and Compensation Unit. In addition to the Coast Guard 

Finance Section, the RP maintained a standalone 

Finance Section that mirrored the Coast Guard section structure. The two sections were necessary due 

to agency and company specifi c fi nancial reporting 

requirements outside the ICS structure requirements. Reporting requirements notwithstanding, 

the two fi nance sections worked in close proximity, 

shared information, attended command meetings, 

and accepted joint responsibility for non-agencyspecifi c Finance Section tasks.

Technical specialists were assigned to the Finance 

Section to oversee all matters of fi nancial management, as required by the NPFC and the Shore 

Infrastructure Logistics Center (SILC). Two Case 

Offi cers from the NPFC were employed as technical specialists for management and oversight 

of Pollution Removal Funding Authorizations 

(PRFAs). In addition, they provided use-of-funds 

INVOICE 

NUMBER

INVOICE 

DATE AMOUNT DATE PAID

AMOUNT 

PAID

N10036-001-10 27-May-10 $1,820,725.36 1-Jun-10 $1,820,725.36 

N10036-002-10 2-Jun-10 $69,090,958.57 11-Jun-10 $69,090,958.57 

N10036-003-10 21-Jun-10 $51,435,548.27 30-Jun-10 $51,435,548.27 

N10036-004-10 13-Jul-10 $99,661,359.34 23-Jul-10 $99,661,359.34 

N10036-005-10 10-Aug-10 $167,896,494.27 27-Aug-10 $167,896,494.27 

N10036-006-10 7-Sep-10 $128,450,327.60 29-Sep-10 $128,450,327.60 

N10036-007-10 12-Oct-10 $62,622,046.71 9-Nov-10 $62,622,046.71 

N10036-008-11 18-Nov-10 $25,376,838.50 17-Dec-10 $25,376,838.50 

N10036-009-11 11-Jan-11 $26,249,015.69 8-Feb-11 $26,249,015.69 

TOTAL: $632,603,314.31 $632,603,314.31 

Table 7.2: Invoices to and Payments by the Responsible 

Party for Deepwater Horizon.
154

7. Finance

opinions for the FOSC and Finance Section Chief 

(FSC), and performed a liaison function with the 

NPFC. A Contracting Offi cer from the SILC with an 

unlimited contracting warrant served as a technical 

specialist for MIPRs, and provided management 

oversight for MIPRs and FOSC use-of-funds opinions. Moreover, the specialist provided procurement opinions for the FSC and Logistics Section 

Chief regarding items and services over the micropurchase threshold, and served a liaison function 

with the SILC.

Coast Guard Finance Section staffi ng was initially 

decentralized across the Unifi ed Area Command 

(UAC), Incident Command Posts (ICP), and 

Branches (also known as Forward Operating Bases 

(FOBs)). Decentralized staffi ng facilitated the local 

evaluation of resource requirements based on complex response needs in geographically, politically, 

and commercially diverse regions. The structure 

enabled the rate of purchases necessary to support 

the rapidly expanding response requirements. The 

decentralization also provided necessary oversight 

for the MIPR and PRFA.

The trade-off cost for decentralization was a reduction in the control and coordination of fi nancial 

documentation. The requirements of fi nancial transparency and alignment across the entire response, 

when combined with greater RP and Offi ce of Management and Budget (OMB) scrutiny of cost after 

the spill source was secured, led to an increased 

demand for standardized documentation. Department of Homeland Security (DHS) and DHS–Offi ce 

of Inspector General (DHS–OIG) audit requests 

and site visits additionally improved transparency 

and standardization.

The number of personnel in the Finance Section 

increased after the consolidation of the fi nancial 

management activities from the National Incident 

Command (NIC), UAC, and the Houma, Mobile, 

Houston, and Miami ICPs into the Gulf Coast Incident Management Team (GC-IMT) on September 20, 2010. As the operations at Branches were 

secured and the branches closed, fi nance personnel 

were integrated into the GC-IMT Finance Section 

or released from the response. As the overall complexity of response needs decreased with command 

consolidation and the securing of the spill source, 

the evaluation of the use-of-funds function was centralized at the UAC level, and transitioned to the 

GC-IMT.

As the fi nancial management function centralized, daily monitoring of Coast Guard fi eld personnel was reduced. The lack of on-scene oversight 

for forward deployed fi eld personnel presented 

a safety problem for accountability during a 

hurricane evacuation and a control problem for 

reporting. As the response matured, processes were 

clarifi ed and procedures became institutionalized, 

and a deep fi nancial knowledge at the branches 

became less necessary. The response recruited a 

new cadre of storekeepers and provided responsespecifi c just-in-time training for incident response 

timekeeping and the property inventory custody 

roles. Once trained by the Finance Section, the 

fi nance storekeeper’s accountability shifted to the 

Operations Section as they were sent to forwardfi eld locations. The Finance Section controlled the 

timeliness and quality of daily Finance reports, and 

the property custodian responsibilities.

7.5 Resource Request and Ordering 

Process

The Logistics and Finance Section Chiefs normally 

collaborate in developing a resource request and 

ordering process upon being assigned to an incident. This process is usually developed following 

the rules set out in two sources:

1. ICS-351 Logistics and Finance Course, and

2. NFPA 1600 – Standards on Disaster and Emergency Management and Business Continuity 

Programs. 

NEW ORLEANS – Oil spill containment equipment is off -loaded from 

a C-17 at Naval Air Station Joint Reserve Base New Orleans. The Air 

Force C-17’s from Elmendorf Air Force Base, Alaska, delivered the 

equipment to support the Deepwater Horizon oil spill response. 

Photo courtesy of U.S. Navy
7. Finance

155

When developing a resource request or resource 

ordering process, related documents should 

explain in great detail how to complete an ICS213 Resource Request Form (ICS-213RRs), the 

required signatures on the form, ordering the 

resource, possible constraints and limitations, 

accountability of the resource when it arrives, 

and fi nal disposition of the resource. The resource 

request process entails ordering a resource internally within the Incident Command System (ICS) 

organization. The resource ordering process entails 

ordering a resource from outside the ICS organization, such as contractor services, other government 

agency services, Department of Defense services, 

etc. Thousands of ICS-213RRs were processed 

over the course of the response at ICPs Mobile 

and Houma and the UAC. These forms served 

as the fi rst stage of the audit trail of resources for 

the response.

Reimbursable agreements were used extensively in 

the response—more than 120 PRFAs and MIPRs 

totaling more than $550 million in obligations have 

been issued to federal, state, and local government 

entities. The fi nancial documents were agreements 

that allowed the FOSC access to the widest variety 

of services from all levels of government to ensure 

effective response to the spill while documenting 

its many outcomes.

Many of these agreements, particularly MIPRs, 

required on-the-spot negotiations to ensure proper 

cost documentation was available for accurate 

accounting of government funds and for support 

to future audits. This documentation was also valuable for potential cost recovery actions.

Previously, MIPRs allowed for the agency providing services to access the agreed-upon funding 

without submission of cost documentation via the 

Interagency Payments and Collections (IPAC) process. Valuable cost data and information on the 

activities undertaken by the FOSC would have 

been unavailable. These documents would also not 

be available for the use of auditors, for historical 

purposes, and for cost recovery.

To overcome this problem, the Coast Guard 

entered into a detailed, 22-page agreement with 

the Defense Finance and Accounting Service to 

ensure proper documentation of costs incurred. 

The creation of the ground rules ensured that 

packages received were properly prepared and 

fully documented. It also ensured that submissions 

met NPFC guidelines with regard to reimbursable expenses, thus reducing the time necessary 

to review and authorize payment.

MIPRs were also issued to non-Department of 

Defense entities, including the Department of the 

Interior–National Maintenance Contract (DOI–

NMC) and the Department of Energy (DOE), to 

ensure their assistance could be secured in a timely 

manner. These reimbursable agreements provided 

the necessary funds for each agency to support 

the response and afforded the UAC with another 

means of monitoring and controlling fi eld operations. Agencies were aware that only activities 

described in the agreements would be reimbursed 

and only with proper documentation. These agreements provided a mechanism to ensure that OSLTF 

funds were used only for the purposes allowed 

by the statute and in support of FOSC objectives.

Given the massive scale of the response operation, frequent changes to the agreements were the 

norm rather than the exception. The more than 

120 PRFAs required approximately 600 modifi -

cations, ranging from extensions of the period of 

performance to carving out entire new mission 

areas and areas of operations. They also required 

a substantial administrative overhead in creation, 

review, and tracking of the agreement from an 

initial requirement from the Planning Section until 

fi nal reimbursement was distributed by the Coast 

Guard Finance Center.

The Deepwater Horizon response encountered 

unique and specifi c problems with some agencies. 

Some of the problems included proper handling of 

Confi dential Business Information (CBI), protection of information essential to potential criminal 

prosecution, and management of agency structuring of appropriations and how appropriations 

affected the ability to be reimbursed by the OSLTF.

The NPFC tracked reimbursement agreements and 

reviewed invoices submitted in agency requests for 

reimbursement. There were more than 120 Pollution Removal Funding Authorization (PRFA) 

and over 70 MIPR reimbursement agreements in 

place, many with multiple modifi cations that the 

FOSC was approving for a one-month period of 

performance.
156

7. Finance

7.6 Cost Tracking, Resource Tracking, 

and Financial Reporting

The FOSC verifi ed whether a particular cost was 

incurred for removal and was consistent with the 

NCP (40 CFR 300); the FOSC could not incur 

costs otherwise. The NCP also requires the FOSC 

to collect and maintain documentation to support 

full-cost recovery against the RP. Once the FOSC 

has certifi ed all removal costs for the incident, 

the documentation is submitted to the NPFC to 

determine what will be billed to the RP and to use 

all legal methods to collect these costs.

The Coast Guard manually entered all indirect 

and direct costs (see Section 7.7) into the electronic CG-5136 workbook. Documentation came 

from different systems; and, there was no standard 

method for gathering or storing the documentation. Documentation for basic ordering agreement 

contracts and MIPRs was stored at the SILC, with 

the signed MIPR, invoices, and logs maintained 

on-site during the response.

Requested forecasting of costs led to the development of an internal capability to establish a daily 

burn rate and to forecast the cost forward on a risk 

basis. The forecasts were created at the request 

of the FOSC on a monthly basis. The forecasts 

were submitted through NPFC to the Coast Guard 

Offi ce of Budget Execution (CG-831) to develop 

consistent forecasts for external stakeholders; the 

forecasts were not shared with the RP.

7.7 Tracking of 

Personnel and 

Resources

The NPFC provides guidance to the sector commands 

on how to record personnel 

and other resources through 

the use of Technical Operations Procedures (TOPS) for 

cost documentation, which 

is part of the NPFC User 

Reference Guide (URG). 

The NPFC also provides 

job aids to complement 

these TOPS. 

The Mobilization, Readiness, Tracking Tool (MRTT) 

was one of the tools used to 

solicit or order personnel to the incident. First, an 

ICS-213RR form with all signatures and specifi c 

skill sets was entered in MRTT with an assigned 

Travel Order Number (TONO). Then, requests 

were published throughout the Coast Guard to 

identify appropriate personnel who met the advertised criteria. MRTT had some constraints and limitations. For example, using the MRTT, the Coast 

Guard advertised 20 key ICS positions, each with 

a TONO assigned to the position. Some positions 

were fi lled immediately and others were not. One 

month later, the Coast Guard submitted a second 

request for the same unfi lled positions. It was possible during this period that personnel transitioning within the ICS organization caused confusion 

regarding which positions remained vacant. This 

shuffl ing led to those positions previously advertised being re-entered in MRTT with new TONOs. 

Some of the TONOs were assigned yet never obligated in the Finance and Procurement Desktop 

because they had no listed personnel names just 

an MRTT identifi cation (ID) number. Over time, 

this resulted in many TONOs to be tracked with 

associated costs, but not all obligated—this added 

a substantial increase in the Travel Cost category. 

The Coast Guard eventually corrected this, all the 

un-obligated TONOs were closed, and the cost 

category reduced to the correct amount.

The CG-5136 electronic workbook is one of 

the primary tools for listing personnel and other 

resources. The workbook is maintained by the 

NPFC and updated regularly when the Assistant 

Commandant for Resources, Offi ce of Resource 

Management (CG-83) updates the Coast Guard 

Standard Rates Instruction. This workbook contains 

several pieces of key information, such as hours 

worked by Coast Guard, which must be sought 

by the Finance Section—in particular, the Time 

and Cost Unit Leaders. The CG-5136 workbook 

was constantly evolving during the response as it 

was updated regularly to provide near real-time 

information based on interests in different cost 

categories. The costs are broken down into two 

categories, direct and indirect, as described below.

The direct costs listed above were part of the Coast 

Guard’s normal fi nancial management paper process. The process fl ow evolves as follows:

1. A request is submitted and approved,

2. An obligation document is created in Finance 

and Procurement Desktop,

GULF OF MEXICO – Two 

Coast Guard petty 

offi cers track resources 

at a branch command 

post. Photo courtesy of 

U.S. Coast Guard
7. Finance

157

3. The resource is delivered with a receipt,

4. The resource is utilized, and

5. A fi nal disposition of the resource is recorded 

for an audit trail.

This process was challenging because of the volume 

of purchases and the management of the fi nancial 

records, particularly travel orders, PRFAs, MIPRs, 

and Reservists orders, over several months.

The indirect costs posed a unique scenario. Each 

of these categories required knowledge about how 

to seek and locate this information or have the 

information automatically sent. For various reasons, tracking the costs of—and hours expended 

by—Coast Guard personnel, cutters, small boats, 

aircraft, and vehicles during this response was 

diffi cult. 

Pollution response equipment costs brought several fi nancial tracking issues to light for the Coast 

Guard during the Deepwater Horizon response. 

The fi rst was accountability of the equipment 

brought to the response and the absence of a 

standard rate for recording some equipment in 

the CG-5136 workbook. The standard rate instruction has a generic list of Coast Guard owned pollution response equipment that did not cover all 

Coast Guard response equipment deployed. The 

National Strike Force Center deployed members 

of all three strike teams with equipment, and no 

standard rate to record the hours utilized. Thus, 

some cost information went unreported. The lack 

of a rate category for tracking purposes was the 

primary cause of unreported equipment costs.

Each of the ICPs for Deepwater Horizon response 

collected, collated, and recorded information as it 

applied to their specifi c command post. A NPFC 

representative became the daily collector of all 

the electronic workbooks. This NPFC member 

reviewed each workbook for information consistency, made corrections, fi xed any corrupted 

formulas, and provided feedback to the creator 

of each workbook. The NPFC collected 17 workbooks each day and combined all into one report 

that the NPFC sent to the FOSC staff. This report 

was used for cost projection analysis by the 

FOSC staff, NPFC staff, and CG-8 for advising 

the Department of Homeland Security and Offi ce 

of Management and Budget on fi nancial implications of this response on the Oil Spill Liability 

Trust Fund.

7.8 Property Management 

and Tracking

For much of the response, Property Management sought to catch 

up as the focus at the beginning of 

the response was on initial startup and the procurement needed to 

sustain the response. A signifi cant 

amount of property was purchased 

or transferred into the UAC and the 

ICPs for use before the property 

management system was fully 

established. The Finance Section 

Chief was designated the Property Offi cer, and on-site property 

custodians were assigned from the 

available workforce.

An Operating Facilities Code 

(OPFAC) is required to establish 

an account in the Oracle property 

management system (Oracle). 

However, due to system limitations, a response 

specifi c OPFAC could not be created in Oracle to 

track property. Instead, the Coast Guard used the 

OPFAC from fi rst responding unit, MSU Morgan 

City. Later in the response, transactions were transferred to the Coast Guard District Eight OPFAC, 

and then fi nally transferred to the NPFC account. 

The custodians were then able to conduct inventories and populate Oracle. The Marine Environmental Response Asset Line Field Offi ce in Prichard, 

Ala., handled the tracking of capitalized property.

The Marine Environmental Response Asset Line 

Field Offi ce’s primary function was to re-outfi t 

equipment used during the spill response and 

return it to the donating command. This task was 

complicated by incomplete or missing Requisition 

and Invoice Shipping Documents (DD-1149s), and 

a lack of a physical inventory when the equipment 

fi rst arrived in theater.

The procurement system did electronically capture 

and store documentation for a transaction, but did 

not automatically feed the property system. Even 

if the system had had these abilities, there was no 

OPFAC associated with the Deepwater Horizon

response, and the ICS Incident Property Tracking form (ICS-261) was not designed for such 

a large response. Absent a systematic means to 

prevent duplication, loss of version control, and 

other issues, the Coast Guard used the Oracle asset 

VENICE, La. – A contract 

worker walks along 

a staging barge on 

the Mississippi River, 

conducting inventory 

as part of keeping all 

Deepwater Horizon

response assets 

identifi ed and tracked. 

Photo courtesy of U.S. 

Coast Guard
158

7. Finance

management module to track personal property. 

Though time consuming, Oracle provided a common means to assert that there was a set dollar 

amount of property on hand on any given day. 

Without the hard controls or radio-frequency identifi cation tracking devices employed by the RP, the 

Coast Guard tracked capital assets using a paper 

system—a slow process for such a large response.

Personal property requires storage and control. 

During the Deepwater Horizon response, the 

Coast Guard stored and rebuilt capital assets at 

the Marine Environmental Response Asset Line 

Field Offi ce. Non-capital assets were gathered on 

site, demobilized, and then transferred to a property warehouse where the assets were inventoried, 

bundled, and prepared for disposal.

7.9 Cost Reconciliation

One of the duties of the UAC staff was to reconcile 

the weekly Program Element Status (PES) reports 

from Core Accounting System (CAS) to Finance 

and Procurement Desktop (Finance and Procurement Desktop) for the Deepwater Horizon account. 

With more than 70 MIPRs and 120 PRFAs, many 

with multiple modifi cations specifying different 

periods of performance, it was critical to include 

forecasting in the cost unit to understand, manage, 

and forecast the daily burn rate. There was a decentralized control structure for tracking and reconciling the costs of blanket travel orders, and no 

systems integration between staffi ng management, 

travel management, and fi nancial management 

systems. For the fi rst fi ve months of the response, 

the Cost Unit did not lead reconciliation of transactions, making it hard to understand the real-time 

running cost of the response. This made it diffi cult 

to explain bills to the RP, and created a backlog of 

undelivered orders and un-reconciled transactions.

Between June and November 2010, PES reports 

for the Deepwater Horizon account generated 

reports containing up to 7,000 transactions each 

week. This major increase in transactions put a 

strain on the CAS and Finance and Procurement 

Desktop platforms. For example, it would take 

several hours to process a single PES report with 

7,000 transactions. Additionally, every time a 

transaction required updating on a PES report, 

PES report would have to be re-generated, starting 

the lengthy loading process anew. One solution 

was to run these PES reports during off hours, 

such as nights and weekends, which did cut down 

the processing time. The Coast Guard Finance 

Center also promulgated restrictions to the rest of 

the Coast Guard to ease constraints on the system 

during peak hours.

The Coast Guard experienced instances when 

transactions occurred in the general ledger in 

CAS, but never appeared on the PES report for that 

week. This was a sporadic problem that seemed to 

be linked to system down times, such as monthend and fi scal year closeouts. If an obligating 

document never appeared on a PES report and the 

expenditure and liquidation of that obligation was 

specifi ed on a subsequent PES report, there was no 

reconciled Undelivered Order (UDO) to settle the 

account. This meant the document had to go into 

an unresolved status until the original obligation 

appeared. Once it appeared, a help desk ticket to 

the Coast Guard Finance Center was required to 

have the obligation document reprocessed.

Direct expenditures on the PES report became 

a major issue for the reconcilers to process. The 

Coast Guard had many systems used to create different types of transactions, such as Direct Access 

for Reserve Orders and Coast Guard Travel System 

(TPAX). These systems are not tied to the Coast 

Guard accounting system, which means that if a 

document is created in one, it will not enter automatically into the Coast Guard fi nancial system. 

Eventually, the expenditure will enter the fi nancial system when the Coast Guard Finance Center 

processes a payment for that transaction, which 

creates a direct expenditure. Initially, these direct 

expenditures were labeled as unresolved transactions until the Finance Section could research 

the expenditures to determine the validity of each 

transaction. At one point, there were more than 

10,000 unresolved items in the Finance and Procurement Desktop requiring research.

The use of a government purchase cards also cause 

direct expenditure issues for the Coast Guard. 

Many cardholders switched their purchase cards 

to the Deepwater Horizon accounting line when 

they deployed to the response. However, as the 

reconciler did not have a master list of all the cardholders who changed their card to this account, 

it was diffi cult to determine not only who had 

changed, but what was purchased under a specifi c expenditure.
7. Finance

159

From the outset of the response it was evident 

that a signifi cant number of Coast Guard Reserve 

personnel would be needed to support the effort. 

This posed both logistical and fi nancial challenges. 

Typically, the Coast Guard uses Direct Access to 

issue Reserve Orders and associated travel orders. 

Yet during the Deepwater Horizon response, the 

Coast Guard could not use the Direct Access computer code to issue orders funded by the OSLTF 

as the correct appropriation supporting the FOSC 

response.

A cross-disciplinary team drawn from NPFC, 

CG-13 Mobilization Staff, Coast Guard Pay and 

Personnel Center (PPC) Topeka, and CG-83 Budget Execution Staff were able to make necessary 

changes to Direct Access during May 2010. By 

early June 2010, all reserve orders issued in Direct 

Access correctly cited the OSLTF accounting 

string. To ensure accurate fi nancial management of 

obligations, automated Direct Access obligations 

were augmented by Coast Guard Force Readiness 

Command manual obligations in CAS for each 

set of orders, including travel, for each Reservist. 

Coast Guard Force Readiness Command correctly 

recorded more than $50 million in obligations for 

reserve orders in CAS for the Deepwater Horizon

incident.

The changes made to Direct Access were not a 

one-time fi x, but transcend the Deepwater Horizon

response to apply to future situations where the 

OSLTF is funding the activation of Coast Guard 

Reservists for oil spill response.

Early in the response, there was confusion over the 

proper method of capturing and approving civilian 

overtime. COMDTINST 12550.4I governing the 

management of civilian overtime was outdated. 

The Coast Guard resolved this issue early and 

overtime was tracked and processed, although 

not in the period earned. The biweekly cap on 

civilian pay was waived but not the annual cap 

(the annual cap of GS-15 Step 10 remained in 

effect). However, it did not appear that controls 

in the current time and attendance system were 

suffi cient to prohibit a member from being paid 

in excess of this annual cap.

The combined magnitude of the response effort 

and the practice of billing the RP (based on 75 

percent of MIPR and PRFA obligations to other 

supporting agencies) made it necessary to capture 

and record accrual data on Coast Guard fi nancial 

statements. The difference between the amount 

paid by the RP and the expenses actually incurred 

by the government had to be recorded as deferred 

revenue. The amount of expenses actually incurred 

by the government had two components:

1. The value of services performed by the agency, 

billed to the Coast Guard, and actually expended 

in CAS, and

2. The value of services performed by the agency 

but not invoiced to the Coast Guard, which was 

recorded as accrued accounts payable.

The challenge associated with the accrual process 

was in attempting to determine the dollar value 

of services performed but not invoiced to the 

Coast Guard from each agency involved in the 

response. The Coast Guard Offi ce of Financial 

Management, Transformation, and Compliance 

Internal Controls Division (CG-851) coordinated 

the collection of this information for the FY 2010 

Financial Statements. The NPFC coordinated the 

collection of the data for the FY 2011 First Quarter. This required signifi cant effort to identify the 

correct offi ce or individual within each agency to 

generate the accounts payable accrual fi gures and 

then additional follow up with to ensure fi gures 

were provided in time to be properly recorded on 

the Coast Guard fi nancial statements.

VENICE, La. – A contractor works in the supply trailer dispensing 

perishable goods to workers during the response. Supply personnel 

ensure all responders are equipped with life vests, hardhats, safety 

boots, sunscreen, bug repellant, safety glasses, and safety suits 

before going into the fi eld. Photo courtesy of U.S. Coast Guard
160

7. Finance

7.10 Resources Committed

Figure 7.1: 

Mississippi 

Canyon 252 

Cumulative 

Financial 

Summary

Figure 7.2: 

Mississippi 

Canyon 252

Daily Financial 

Summary
Executive Summary

161

7.10 Resources Committed

7.11 FOSC Key Points

Responsible Party Solvency

The outcome of the response to this spill could 

have been very different had the RP not been able 

to fund the extraordinary expenses involved. In 

the planning process, and during drills, participation of the RP is presumed. If an RP proved 

unable to pay for a major spill, the ability of the 

government to organize a response of this nature 

and complexity—including securing the sub-sea 

source, contracting resources, and funding removal 

actions—would be severely strained. All levels 

of government had diffi culty sustaining their 

involvement the Deepwater Horizon response. If 

the government had had to organize every aspect 

of the response, the strains may have become 

overwhelming. Current planning and drills do 

not address the potential for government having 

to manage a major response due to the unavailability of the RP.

OSLTF Caps

The structure for funding responses set out in the 

Oil Pollution Act of 1990 (OPA 90), and limitations 

on per response costs were outdated and needed a 

legislative change in mid-response to address. In 

addition, without a solvent RP who was willing to 

undertake not only real-time funding of response 

costs—both directly but also in terms of payments 

to the NPFC, as well as setting aside vast sums 

for claims—the OSLTF Emergency and Principal 

Funds could have been overwhelmed. Until the 

arrangements with the RP to provide reimbursement to the OSLTF as the response progressed 

were established, the existing caps limited the 

funding for participation of other agencies through 

PFRAs and Requests for Assistance (RFAs).
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162
8. Natural Resources and Wildlife

163

As soon as the spill began, the National 

Oceanic and Atmospheric Administration (NOAA), U.S. Fish and Wildlife Service (USFWS) and other natural resource trustee 

agencies recognized that the potential impact on 

wildlife from the Deepwater Horizon spill could 

be enormous. The concerns focused primarily on 

three areas:

1. Marine mammals and sea turtles,

2. Migratory birds, and

3. Endangered species (many of the marine 

mammals and all of the sea turtles are threatened or endangered).

The spill also impacted a large number of historic 

and cultural properties.

8.1 Marine Mammals and Sea Turtles

Statutory authority and trustee responsibility for 

the 29 species of marine mammals and fi ve species of sea turtles in the Gulf of Mexico are shared 

between the National Oceanic and Atmospheric 

Administration National Marine Fisheries Service 

(NOAA NMFS), which is responsible for cetaceans and sea turtles in water, and the USFWS, 

which covers manatees and sea turtles on land. 

These species are addressed under two federal statutes, the Marine Mammal Protection Act (MMPA), 

and the Endangered Species Act (ESA). All 34 

species were presumed at risk from impacts of the 

oil from the Deepwater Horizon spill.

Recognizing the potential risk to these taxa from 

the Deepwater Horizon spill, concerns about 

impact to them were specifi cally included in the 

considerations and activities of the Operations Section, Wildlife Branch of the Coast Guard response. 

Due to several factors, including the specialized 

expertise required for response and rehabilitation, 

and the pre-existing response infrastructure, these 

taxa were pulled into a distinct group, the Marine 

Mammal and Sea Turtle Group (MMSTG), under 

the Wildlife Branch at the beginning of the wildlife 

response.

VENICE, La – An oiled sea 

turtle is swabbed down 

by response workers 

during Deepwater 

Horizon oil spill. 

Specialized volunteers 

from numerous 

organizations helped the 

plight of the sea turtles. 

Photo courtesy of U.S. 

Air Force

Initial Establishment of the Marine Mammal 

and Sea Turtle Group

Upon initial notifi cation of the Deepwater Horizon

spill, the Southeast Marine Mammal Stranding 

Coordinator contacted the NOAA Scientifi c Support Coordinator (SSC). NOAA deployed scientists 

to the Unifi ed Area Command (UAC) for marine 

mammal and turtle 

coordination and support. The Responsible 

Party (RP) contacted 

the Oiled Wildlife Care 

Network, University 

of California Davis 

(OWCN) to assist on 

marine mammal and 

sea turtle issues, and 

OWCN then worked 

with NOAA NMFS 

to coordinate efforts. 

By April 30, 2010, the 

MMSTG was formed 

under the Wildlife Branch and was represented at 

the Houma Incident Command Post (ICP). The 

MMSTG was separated into two units, Sea Turtles 

and Marine Mammals.

In addition to those deployed, NMFS utilized preexisting marine mammal and sea turtle response 

personnel and infrastructure in an off-site capacity. 

The personnel included:

1. Both the NMFS and USFWS national sea 

turtle coordinators,

2. The national marine mammal health program 

manager,

3. The regional cetacean and sea turtle stranding 

network coordinators at the NMFS Southeast 

Fisheries Science Center in Miami, Fla.,

4. The regional cetacean stranding network 

administrator at the NMFS Southeast Regional 

Offi ce in St. Petersburg, Fla., and

5. The manatee stranding network coordinator at 

the USFWS offi ce in Jacksonville, Fla. 

MMSTG incorporated these persons into the organization chart within their traditional capacity.

The personnel at the UAC were responsible for 
164

8. Natural Resources and Wildlife

oversight of the MMSTG and its integration into the 

unifi ed command, in coordination with those operating from their home offi ces. Integration efforts 

included:

• Developing protocol, review, and approval,

• Requesting logistics and procurement,

• Obtaining information from and coordinating 

activities with other Branches of the response 

(e.g., fi nding the daily coordinates for the in 

situ burn activities to avoid these areas by the 

turtle on-water capture teams), and

• Reporting daily to the FOSC (Federal OnScene Coordinator).

When multiple ICPs were established across the 

Gulf region, the MMSTG maintained a single operational area, which included coastal and offshore 

areas from the Texas-Louisiana border through 

Apalachicola, Fla., with overall MMSTG coordination out of Houma, La. The operational area was 

established through discussions with the SSCs, as 

well as biological information available from the 

Environmental Unit. This facilitated the collection of all animals that might likely be impacted 

by oil or oil-spill-related activities. Liaison positions were created at the other ICPs: one person 

within the Wildlife Branch, one person within 

the Environmental Unit at ICP Mobile, and one 

person in Florida. The liaisons served as a central 

point of contact regarding marine mammals and 

sea turtles, coordinated the protocols developed 

at ICP Houma through each command post, and 

addressed or relayed concerns or issues regarding 

marine mammals and sea turtles. 

Response to Oiled 

and Stranded Marine 

Mammal and Sea Turtles

In 2004, the OWCN developed guidelines for marine 

mammal oil spill response. 

The document outlines 

stranding response requirements, data collection, 

records maintenance, safety 

and human health, field 

recovery and transportation 

of oiled wildlife, intake procedures, animal washing, 

and instructions on how to 

complete the required forms.

At the beginning 

of the Deepwater 

Horizon response, 

the MMSTG used 

previously developed guidelines for 

determining equipment and personnel 

needs, structuring 

the organization, 

and as a basis 

for animal deoiling and care 

protocols. During the response, 

t h e M M S T G 

expanded these protocols for the various aspects 

of the response and adapted the pinniped and cetacean guidelines for sea turtle and manatee response 

and rehabilitation. MMTSG developed additional 

documents including protocols for sea turtle nest 

protection, hatchling encounters by cleanup crews, 

offshore collection of live and dead oiled turtles, 

and marine mammal carcass retrieval.

MMSTG also developed a transition plan to detail 

the future of the MMSTG response following the 

successful capping of the Deepwater Horizon

wellhead. The transition plan presented criteria to 

guide decisions for the gradual demobilization of 

marine mammal and sea turtle response and recovery actions.

Marine mammals and sea turtles are considered 

to be stranded if they are found dead or in need of 

assistance (sick, injured, debilitated, or in distress) 

on the beach or in U.S. waters. Covering most of 

our coastline, stranding networks consist of different organizations that respond to reports of stranded 

animals. Network participants are authorized and 

coordinated by NMFS (sea turtles, cetaceans, and 

pinnipeds) and USFWS (manatees and sea otters).

The wildlife hotline was created by the FOSC to 

provide a single reporting number for all oiled 

wildlife calls, including birds, turtles, dolphins, 

manatees, and other terrestrial or marine wildlife. 

Hotline reports were received from members of 

the response, as well as the public. All reports of 

stranded marine mammals and sea turtles were 

forwarded to the Houma MMSTG, and one of the 

MMSTG personnel relayed the report to the appropriate stranding network organization.

GULF OF MEXICO – 

A Louisiana Department 

of Wildlife and Fisheries 

biologist releases a 

turtle 50 miles south of 

Grand Isle, La. Photo 

courtesy of U.S. Coast 

Guard

PORT FOURCHON, La. – An oiled 

dolphin lies stranded on the beach.
8. Natural Resources and Wildlife

165

The Sea Turtle Stranding and Salvage Network 

(STSSN) has operated in the Gulf of Mexico 

since the 1980s. When the Deepwater Horizon

spill occurred, NOAA and USFWS called on the 

expertise of sea turtle stranding responders located 

in the region. Unfortunately, the area expected to 

be most severely impacted was in a location with 

the least developed STSSN response capability. 

With an expectation that increased numbers of 

sea turtles would become stranded because of the 

oil spill, NOAA and USFWS began enhancing 

stranding operations by increasing the number of 

responders (federal, state, and contracted personnel), procuring additional equipment, and developing response protocols.

Following the stranding response protocols for 

oiled sea turtles, all stranded sea turtles were photo 

documented, externally wiped to sample any petrochemicals, and collected for necropsy (if dead) 

or for rehabilitation (if alive). Vessels of Opportunity (VOO) were used to respond to strandings 

reported near-shore or stranded on barrier islands, 

and those reported from remote locations along 

the northern Gulf Coast. In addition, response and 

reporting protocols were developed and distributed 

to all UAC Operation Sections likely to encounter 

sea turtles.

Equipment kits necessary for the safe capture 

and recovery of wildlife were also ordered and 

distributed. A challenge encountered during the 

early response period was the proper distribution 

of equipment and reporting information to individuals in the fi eld. Although reporting and collection protocols were disseminated at the Houma 

and Mobile ICPs, the information did not consistently reach the cleanup operations and Shoreline 

Cleanup Assessment Techniques (SCAT) teams on 

the beaches; this impeded response capabilities of 

stranding responders.

Discussions about stepping down the enhanced oil 

spill stranding response began in mid-August. A 

step-down plan was developed specifying criteria 

under which stranding response would transition 

back to the traditional response levels. The transition would occur 30 days after the last oiled turtle 

was observed in any of the Wildlife Branch activities. Stranding response returned to pre-spill levels (demobilized) on October 20, 2010. STSSN 

participants remained on alert for possible oiled 

post-hatchlings. No further reports of oiled posthatchlings were received. If Deepwater Horizon

oil is confi rmed on any future stranded sea turtles, 

the expert working group will convene to determine 

the best course of action. 

Sea Turtle Rescue

MMSTG on-water response operations included 

sea turtle rescue. Offshore convergence areas in 

the Gulf of Mexico, especially areas with Sargassum algae serve as a primary habitat for several 

species of sea turtles. These areas provide forage 

and shelter particularly during the juvenile oceanic 

life stages of sea turtles. Because these convergence zones are generally located offshore near 

the Deepwater Horizon site, MMSTG expressed 

GULF OF MEXICO – The U.S. Navy MZ-3A Airship 

serves as a platform for aerial observers looking for 

marine mammals and other wildlife that may be in 

distress. Photo courtesy of U.S. Coast Guard

VENICE, La – A staff 

biologist with Riverhead 

Foundation for 

Marine Research and 

Preservation scoops up 

a sea turtle in the Gulf. 

Photo courtesy of U.S. 

Air Force
166

8. Natural Resources and Wildlife

signifi cant concerns for impacts to sea turtles specifi cally the juveniles. This was not only due to 

their known usage of this habitat, but also because 

the surface oil (both fresh and weathered) concentrated in the convergence zones compounding the 

exposure risk.

Beginning in mid-May 2010, the MMSTG began 

an at sea survey to determine the probability 

of locating, documenting, and recovering oiled 

sea turtles that utilized Sargassum algae lines as 

primary habitat. As a result of initial effort, the 

MMSTG initiated the Sea Turtle At Sea Rescue 

operation. This operation used one or more vessels and an associated 

aircraft. The aircraft 

would locate habitat 

with the potential 

for oiled turtles, then 

direct vessels to those 

locations.

The vessels would 

work through the convergence zones (of 

Sargassum algae or 

weathered oil) locating and capturing 

oiled or debilitated 

turtles. The location 

of suitable habitat and 

convergence zones varied considerably depending 

upon the prevailing weather conditions, but was 

generally at least 20 miles offshore. At times, the 

closest convergence zones were 50-60 miles from 

the vessels’ ports. The rescue operations initially 

consisted of one team based in Venice, La., and 

subsequently expanded to include teams located 

at the two additional ports of Orange Beach, Ala., 

and Destin, Fla. VOO were used at all three sites. 

From mid-May 2010 until on-water operations 

ended September 21, 2010, on-water teams capture 461 sea turtles. Of these, 330 live oiled and 

debilitated turtles were brought in for rehabilitation, and fi ve dead sea turtles were brought in for 

necropsy. After the Deepwater Horizon oil well 

was capped, an additional 126 lightly oiled turtles 

were examined at sea, cleaned, and released at 

their capture sites. The majority of the rescued sea 

turtles were juvenile Kemp’s Ridley and juvenile 

green turtles. The remainder were juvenile Loggerhead and Hawksbill turtles.

The on-water rescue effort involved staff from the 

Florida Fish and Wildlife Conservation Commission, the In-water Research Group, the Riverhead 

Foundation for Marine Research and Preservation, 

NMFS, USFWS, and Louisiana Department of 

Wildlife and Fisheries.

Relocation of Sea Turtles’ Nests

The Deepwater Horizon spill overlapped in space 

and time with the sea turtle nesting season in the 

northern and eastern Gulf of Mexico, necessitating 

sea turtle nesting beach monitoring operations. 

Approximately 700 nests are laid annually in the 

Florida Panhandle and up to 80 nests annually 

in Alabama. These nests were expected to produce approximately 50,000 hatchlings in 2010. 

The nesting season spans from mid-May to the 

end of August, with the hatching of nests and 

emergence of hatchlings in July through October. 

Several concerns were raised surrounding nests 

and hatchlings, including the potential for disturbance by cleanup operations and the possibility 

that hatchlings would emerge on oiled beaches or 

swim into oiled waters.

To minimize the potential for spill responders to 

harm nests, an intensive visible marking effort 

was undertaken with daily surveys for freshly laid 

nests. Additionally, the MMSTG worked within 

the ICP Mobile to ensure Best Management Practices (BMPs) were developed and implemented for 

nesting beach protection.

In early June, the MMSTG convened a meeting of 

experts in New Orleans, La., to address the threats 

to the turtle hatchlings. A plan was developed and 

submitted for approval through UAC to relocate 

nests during late-term incubation to the east coast of 

Florida for fi nal incubation and release of hatchlings 

into the Atlantic Ocean. These efforts were necessary to prevent hatchlings from entering oiled waters 

of the northeastern Gulf of Mexico. A total of 274 

nests (primarily loggerhead) were relocated between 

late June and mid-August, and 14,796 hatchlings 

were subsequently released. This unprecedented 

effort involved numerous state, federal, local nonprofi t organizations, and volunteers, as well as a 

commercial courier service that donated the use of 

a climate-controlled, air-ride suspension truck to 

transport the nests to Florida.

As with many of the MMSTG response activities, procurement of supplies, personnel, contracts, 

and approval of plans within the ICS hampered 

response efforts. The nest translocation effort had 

GULF OF MEXICO – 

Members of the Audubon 

Nature Institute and 

Louisiana Department 

of Wildlife and Fisheries 

prepare to release a sea 

turtle. Photo courtesy of 

U.S. Coast Guard
8. Natural Resources and Wildlife

167

to be started before a contract could be fi nalized for 

the required activities on the east coast of Florida. 

The contract proved challenging to negotiate due 

to the clauses required by the RP.

In order to provide a mechanism for the rescue 

of animals that were incidentally involved in onwater cleanup operations and to document interactions between the response and the resources, the 

MMSTG and the Southeast Regional NOAA Fisheries Service Endangered Species Branch Chief 

requested observers be placed on skimmers and 

other on-water cleanup operations. During July 

2010, the MMSTG built the Protected Species 

Observer Program. This program provided an onwater person to observe in situ burn operations, offshore skimmers, near-shore skimmers, and several 

experimental on-water oil cleanup technologies. 

All observers were trained in marine mammal, 

sea turtle, and seabird identifi cation, and Hazardous Waste Operations and Emergency Response 

(HAZWOPER), and were provided the necessary 

equipment. The data collected from their observations was reviewed and evaluated during the spill 

and will be used by NOAA Fisheries Service and 

the USFWS as they dispatch their personnel for 

consultation on the Deepwater Horizon event.

Of note, and perhaps not widely known, science 

staff from the Bureau of Ocean Energy Management, Regulation, and Enforcement (BOEMRE), 

Gulf of Mexico OCS Region, and the UAC’s 

Environmental Unit provided the FOSC with the 

scientifi c guidance for attacking the spill. This staff 

also assisted in placement of response resources 

to mitigate natural resource damages. BOEMRE 

provided advice and information concerning over 

fl ights needed for monitoring and potential impacts 

of in situ burns, and for the sub-sea monitoring 

program.

Scientific information and expertise from 

BOEMRE-funded studies proved indispensable 

during the Deepwater Horizon spill response. 

BOEMRE’s protected-species biologists worked 

with the National Park Service and other wildlife 

trustee agencies to develop a comprehensive wildlife management plan.

Sea Turtle Rehabilitation Eff orts

By way of the sea turtle response, signifi cant 

improvements were made to sea turtle rehabilitation facility capabilities in the northern Gulf. Four 

pre-existing facilities (Audubon Nature Institute 

in New Orleans, La., Institute for Marine Mammals Studies in Gulfport, Miss., Gulfarium in Fort 

Walton Beach, Fla., and Gulf World Marine Park 

in Panama City Beach, Fla.) were designated as 

primary care facilities. As such, these facilities 

were equipped to administer de-oiling of animals, 

veterinary care, and rehabilitation of large numbers of oiled sea turtles. Five secondary facilities 

(SeaWorld Orlando, Disney Living Seas, Mote 

Marine Laboratory, Clearwater Marine Aquarium, 

and Florida Aquarium) were 

secured for short- or longterm holding of sea turtles 

following de-oiling at the 

primary facility, but prior to 

release. Protocols for medical clearance of turtles prior 

to release and release plans 

were developed and implemented. In July 2011, the last 

few rehabilitated sea turtles 

were released, resulting in a 

total of 388 turtles that were 

successfully rehabilitated 

and released back into the 

wild. [Update: In July 2011, 

the last few rehabilitated sea 

turtles were released, resulting in a total of 388 turtles 

that were successfully rehabilitated and released back 

into the wild.]

The greatest challenges to 

the sea turtle rehabilitation 

efforts during the response were the procurement 

Bon Secour National Wildlife Refuge, Ala. – Refuge staff make 

preparations to relocate a sea turtle nest. Photo courtesy of U.S. 

Fish and Wildlife Service

NEW ORLEANS – 

A loggerhead sea turtle 

brings her head above 

water at the Audubon 

Nature Institute 

Rehabilitation Center. 

Photo courtesy of U.S. 

Coast Guard
168

8. Natural Resources and Wildlife

of veterinarian and veterinary technician contracts, 

de-oiling equipment, additional tanks, and veterinary and husbandry supplies. All four primary 

rehabilitation facilities required equipment and 

staffi ng to meet response needs, and it proved 

extremely diffi cult to meet these needs in a timely 

fashion.

Dolphins

In order to protect and mitigate damage to bottlenose dolphins, visual health assessments were 

initiated. Dolphin communities in the Perdido 

Bay complex (Wolf, Perdido, Bay La Launch, 

and Arnica Bays) near Orange Beach, Ala., have 

been the focus of a dedicated eco-tourism industry for almost twenty years. Several dolphin tour 

captains and citizens expressed concern about animal health and welfare during the oil spill crisis. 

To determine if any intervention was needed, the 

MMSTG conducted visual health assessments of 

the bottlenose dolphins in this area.

The assessments investigated whether the dolphins 

were exhibiting signs of 

distress or behavioral 

anomalies that could 

potentially require an 

intervention (on-water 

capture).

The visual health 

assessments required 

near-shore, boat-based 

surveys. The MMSTG 

utilized a registered 

VOO assigned to the 

Wildlife Branch. Sighting information and 

behavioral observations of the dolphins 

were recorded on data 

sheets, and photographs 

and video were taken 

to document behavior 

and body condition. 

Additionally, surveys 

attempted to identify 

specifi c animals using 

individual markings of 

the animals’ dorsal fi ns.

The visual assessment 

team conducted surveys 

in June, July, and August. During this time, several 

groups of dolphins in the Perdido Bay complex, 

including calves recently born, were observed and 

documented in good condition. Moreover, these 

dolphins were exhibiting normal socializing and 

feeding behaviors with no visible signs of illness. 

These surveys were essential to assess the animals’ 

health status and determine if further action was 

warranted; none was warranted. During the July 

and August surveys, an independent marine mammal veterinarian with extensive expertise in dolphin health accompanied NOAA’s marine mammal 

biologists. The veterinarian confi rmed the dolphins 

were exhibiting good body condition and showed 

no visible signs of illness. Following the surveys, 

community outreach efforts were conducted to 

present the fi ndings and inform residents about 

the health status of the animals and to explain the 

MMSTG’s protocols for responding to animals 

in distress.

Over the summer of 2010, two dolphins stranded 

dead in the Perdido Bay complex, but neither 

showed visible signs of oiling. Follow-up monitoring and behavioral observations during future 

visual health assessments will continue to provide 

the scientifi c evidence to determine when interventions or rescues are warranted.

Marine Mammal Stranding Operations

The Southeast Marine Mammal Stranding Program has operated in the Gulf of Mexico since the 

1970s. The program operates under the direction of 

NMFS’ Southeast Regional Offi ce and the Southeast 

Fisheries Science Center for cetaceans that strand 

in the Gulf of Mexico. This is the same network 

under authorization of the USFWS for manatees 

that strand in Alabama, Louisiana, and Mississippi. 

The UAC increased operational capacity through 

these organizations. As of February 2011, response 

to stranded animals was still ongoing for some areas 

where there were recent detections of oiled animals.

Based on the Marine Mammal Oil Spill Response 

Guidelines, spill response protocols were expanded 

for cetaceans and adapted to provide response for 

manatees. Efforts to enhance detection and reporting 

of marine mammal strandings were also instituted.

Any live stranded marine mammals were responded 

to as rapidly as possible, evaluated on the beach 

or in the water, and either immediately released 

NEW ORLEANS – 

A veterinary technician 

with the Audubon Nature 

Institute comforts Louie 

the dolphin before he 

is loaded onto a Coast 

Guard HC-144 Ocean 

Sentry from Air Station 

Miami. Members from the 

Audubon Nature Institute, 

the Louisiana Marine 

Mammal and Sea Turtle 

Rescue, and the Dolphin 

Research Center cared for 

and relocated Louie after 

he was found covered 

in oil in the water near 

Port Fourchon, La. Photo 

courtesy of U.S. Coast 

Guard.
8. Natural Resources and Wildlife

169

on-site, transported to rehabilitation, or euthanized. 

The marine mammal response depended upon the 

enhanced reconnaissance and response efforts from 

within the Wildlife Branch (with the primary objective of detecting and responding to oiled birds) and 

the VOO program, to provide reports of animals 

stranded and to assist with collection of, or access 

to, animals. Given the low frequency of manatee 

strandings in the northern Gulf Coast, arrangements 

were made for rapid response teams from Florida 

to provide animal rescues and rehabilitation. Fortunately, those assets were not needed. A transition 

step-down plan for response was implemented on 

November 2, 2010. The plan provided a response 

re-initiation clause based on triggers of oiled dolphins and advice from the working group. Since 

December 3, 2010, three oiled dolphins have been 

recovered and an intermediate response was in 

effect for central and eastern Louisiana through 

March 25, 2011.

Response operations have not been re-initiated 

for the other geographic areas within the Gulf of 

Mexico, and these stranding organizations are using 

normal response protocols.

Due to the high rates of strandings since February 2010 in the northern Gulf of Mexico, consultation with the MMSTG on Marine Mammal 

Unusual Mortality Events (UMEs) was initiated. 

In addition, a formal UME was declared and a 

UME investigation launched for cetacean strandings occurring in the Northern Gulf area from the 

Louisiana and Texas border to Apalachicola, Fla.

The marine mammal program used three of the 

same rehabilitation facilities as for sea turtle care 

in the northern Gulf (Audubon Nature Institute 

in New Orleans, Institute for Marine Mammals 

Studies in Gulfport, and Gulf World Marine Park 

in Panama City Beach) for the UME. These facilities were augmented and capacity was developed 

through equipment, structures, and training to 

enable transport, de-oiling, and holding of oiled 

marine mammals. Arrangements were also made 

to access additional facilities (mobile facilities 

and secondary rehabilitation groups) if the local 

facilities exceeded capacities.

Working with partners from outside of the response 

area, the MMSTG deployed experienced veterinarians, animal handlers, and sample and data 

managers to these primary facilities to assist with 

the overall response as needed. Given the low frequency of manatee strandings on the northern Gulf 

Coast, two additional Florida rehabilitation facilities under use agreements were not needed during the response. Although 12 cetaceans stranded 

live, only three bottlenose dolphins were taken to 

rehabilitate, the others were released in the fi eld, 

died, or were euthanized. Rehabilitation challenges 

include transport time, de-oiling training for handling oiled dolphins, logistical support for access, 

and obtaining resources.

8.2 Migratory Bird Activities and 

Volunteer Wildlife Response Assistance

A paraprofessional and volunteer coordinator position, identifi ed as a need during the Deepwater 

Horizon incident, was established to oversee all 

activities related to Oiled Wildlife Rehabilitation 

Centers, transportation of oiled wildlife, paraprofessional coordination, and volunteer coordination 

throughout Louisiana, Mississippi, Alabama, and 

Florida. In addition to the coordinator position, 

four other positions were established to fulfi ll the 

duties involved in rehabilitation and response to 

impacted wildlife during the incident. These positions included an assistant coordinator, a transport 

coordinator (located in Houma, La.), and one position to maintain the paraprofessional list (located 

in Atlanta, Ga.). 

Within seven days of the Deepwater Horizon

oil rig explosion, the paraprofessional coordinator arrived in Houma, La., to meet the executive 

director of a rehabilitation organization to discuss 

the need for Wildlife Rehabilitation Centers to be 

established in response to the incident. In an effort 

to channel available resources, including staff for 

PORT FOURCHON, La. – U.S. Coast Guard personnel comfort a 

stranded, oiled dolphin on the beach near Port Fourchon, La., 

while awaiting a marine mammal rescue crew.
170

8. Natural Resources and Wildlife

the Centers, the idea of using paraprofessionals 

on a volunteer basis was discussed with the RP 

and a volunteer paraprofessional was defi ned. A 

volunteer paraprofessional was defi ned as an individual who:

• Possessed, or worked directly under a person 

possessing, an active permit or authorization 

related to the species cared for;

• Was affi liated with a wildlife organization 

working within the Wildlife Branch of the 

UAC;

• Was an employee of a wildlife trustee agency;

• Agreed to work under, and abide by, appropriate planning documents prepared by the UAC 

(such as Site Safety Plan, Incident Action 

Plans, public affairs requirements, etc.); and

• Had working knowledge and experience (at 

least three months) with the general protocols, 

procedures, and safety hazards associated with 

working on the species identifi ed as at risk.

An assessment was made to quantify the potential 

wildlife response in each state and the number of 

persons needed to staff each. It was determined 

that additional personnel were needed. A paraprofessional announcement was published nationally, 

regionally, and internationally. An email account 

was established and managed 

by the USFWS Migratory Bird 

Permit Offi ce in Atlanta, Ga. 

The paraprofessional roster 

ultimately contained more than 

1,000 individuals from almost 

every state in the United States 

and nine other countries. Each 

capture team (a two-person 

team) in Mississippi, Alabama, 

and Florida, was comprised of 

one agency employee and one 

experienced wildlife rehabilitator. Those individuals who 

did not meet the qualifi cations 

were directed to the National 

Audubon Society for potential 

volunteer opportunities.

In order to fi ll these positions, 

the RP ultimately agreed to 

pay the volunteers to staff the 

Centers and the capture teams. 

After the number of positions 

and the hiring processes were established, the paraprofessional coordinator staffed these positions 

both at the Centers and on the capture teams for 

the duration of the incident. This involved managing 70 positions on a two-week rotational basis.

The transport coordinator developed the protocols 

and system for transporting animals from the fi eld 

to the Centers, to the release sites, and to other 

rehabilitation facilities. In addition, the coordinator arranged fl ights for the on-site Veterinarian and 

Branch Director. When the oiled wildlife hotline 

began receiving calls, a system was developed to 

retrieve the animals (mainly migratory birds) and 

safely transport them to the Centers. 

Safely transporting the animals involved many factors. Considerations included high temperatures, 

number of birds, manpower, logistics of managing 

a high volume of calls, and response for an area the 

size of four states. The fi rst calls received were from 

vessels in the Gulf of Mexico, close to the source 

of the oil spill. Initially, the RP sought to obtain 

services of volunteers to transport oiled wildlife. 

At that time, the National Audubon Society was 

contacted for assistance. The paraprofessional coordinator on the incident also met with the Louisiana 

state director to identify areas with immediate need 

for transporters. The biggest challenge was identifying volunteers who were both trained to encounter 

potentially oiled animals and individuals who met 

the paraprofessional defi nition. This combination 

limited the available pool of volunteers.

Early in the incident, a system was established 

where National Audubon Society was contacted 

GULF OF MEXICO – 

A biologist holds an 

oiled brown pelican 

rescued from the Gulf. 

Photo courtesy of U.S. 

Fish and Wildlife Service 

JEFFERSON PARISH, La.- Louisiana Department of Wildlife and 

Fisheries and U.S. Fish and Wildlife Service personnel prepare to net an 

oiled pelican in Barataria Bay, La. Photo courtesy of U.S. Coast Guard
8. Natural Resources and Wildlife

171

to locate volunteers to retrieve the wildlife. Bringing animals to designated sites posed problems. 

Some designated sites were great distances from 

the nearest Center. The process quickly became 

too risky for the birds and for the individuals 

providing transportation. Proper vehicles were 

not available. There were already protocols established by International Bird Rescue and Research 

Center for transporting wildlife at oil spills which 

did not include using vehicles the National Audubon Society volunteers had available. Eventually, 

liability concerns drove a change to use of contract transportation services for oiled wildlife. 

As a result, three companies were contracted to 

provide cargo vans and purpose-built vehicles to 

provide transportation for wildlife. Purpose-built 

vehicles allowed safe transport of the animals in 

climate-controlled environs. Cargo vans were used 

to carry animals from capture sites to the Centers, 

and purpose-built vehicles transported large numbers of birds to the Centers, long-term rehabilitation centers, and to release sites.

Once the contracts for transportation services were 

in place, transport teams stationed at designated 

places began to accept animals brought there by 

the capture teams. Purpose-built vehicles were 

either at the Center in Louisiana, or on call with a 

12- to 24-hour report time. The transport coordinator position maintained the schedule for transport 

teams and arranged transportation for all animals 

to the designated release sites.

The paraprofessional and assistant coordinator 

positions were also tasked with organizing the 

volunteer organizations that offered help. Many 

calls came from volunteers and those seeking to 

donate supplies to the response effort. It became 

apparent a system was needed to manage the offers 

for volunteer assistance.

The National Audubon Society had an established 

website designed for volunteer management. Their 

website allowed a volunteer to provide online 

information about their skills and availability. The 

Audubon Society also set up a thirty-person call 

center in Mississippi to help organize volunteer 

efforts throughout the four affected states. Due to 

the ease of this system, the RP’s volunteer coordinator asked to have all volunteer requests funneled 

through the Audubon Society for the remainder of 

the response. The Audubon Society then became 

the source for all non-paraprofessional volunteers 

used by the Wildlife Branch and was responsible 

for maintaining the volunteer schedule. Volunteer 

management proved the biggest challenge for the 

paraprofessional team due to the enormous need 

for, and the limited supply of, experienced individuals with the requisite skills for handling oiled 

wildlife. Audubon’s assistance with this process 

was essential.

Volunteers were placed at each marina in Louisiana 

to which capture teams were bringing wildlife. The 

positions were manned 12 hours each day, and the 

volunteer was responsible for calling the transport coordinator to arrange transport if a vehicle 

was not on-site. Each volunteer was tasked with 

ensuring the animals received from the capture 

teams were not disturbed and were protected from 

the elements until the transport team arrived. This 

allowed the capture teams to deliver the wildlife 

and return immediately to their duties.

The paraprofessional coordinator and assistant coordinator acquired permits from Texas, Louisiana, 

Mississippi, Alabama, 

Georgia, and Florida 

to import and export 

wildlife for release after 

rehabilitation. They 

were also responsible 

for issuing permits for 

USFWS employees and 

their agents to perform 

activities under the 

Migratory Bird Treaty 

Act. The paraprofessional coordinator also 

HOUMA, La. – A U.S. 

Coast Guard pilot and 

U.S. Fish and Wildlife 

Service veterinarian 

transfer a cage of 

Brown Pelicans to an 

HC-144A Ocean Sentry 

aircraft for transport 

to Port Aransas, Texas, 

for release. Photo 

courtesy of U.S. Coast 

Guard

NEW ORLEANS – A U.S. Fish and Wildlife Service veterinarian 

and a U.S. Coast Guard Petty Offi cer observe a sea turtle 

aboard a U.S. Coast Guard HC-144A Ocean Sentry aircraft. 

The turtle was found stranded on the Louisiana coast and 

transported to Egmont Key National Wildlife Refuge near St. 

Petersburg, Fla. Photo courtesy of U.S. Coast Guard
172

8. Natural Resources and Wildlife

worked with the affected 

state’s wildlife agencies to 

verify appropriate release 

sites and to coordinate the 

activities of the Wildlife 

Operations Branch to include 

state agency participation. 

These coordinators were also 

responsible for supervision 

of the two wildlife hotline 

dispatchers at the Daphne, 

Ala., Wildlife Operations 

Branch when the BP hotline was disbanded. The 

coordinators temporally supervised evidence custodians in Alabama, Florida, and Mississippi until 

those duties were transferred to another position. 

The paraprofessional coordinator still serves as the 

liaison for USFWS’s Migratory Bird Program for 

the Southeast Region and responds to all migratory bird related issues related to the Deepwater

Horizon spill. 

Migratory Bird Habitat Initiative

As part of the whole-of-government response to 

the Deepwater Horizon spill, the Department of 

Agriculture Natural Resource Conservation Service (NRCS) developed a proposal to use existing 

programs to enhance migratory bird habitat in the 

southern Mississippi River fl yway to encourage 

birds to not migrate as far as the potentially oiled 

shorelines along the Gulf Coast, or at least delay 

their arrival to reduce impact on migratory populations. One, called the Wetland Reserve Program, 

contracts with private landowners to use fl ooding of 

crop land in appropriate places to provide additional 

migratory bird habitat. The other program would 

fl ood appropriate locations in land managed by 

the federal government. NRCS made the decision 

to implement these programs and initially funded 

them through reallocation of funds from other areas 

within those existing programs. Regardless, a number of tracts of agricultural lands received support 

from the Department of Agriculture to fl ood and 

create diversionary wetlands. At the conclusion of 

migratory season, this diversionary tactic proved 

to be ineffective. 

In June 2010, while oil fl owed unconstrained from 

the well and it was not known when the source 

would be secured, the FOSC indicated such actions 

could be appropriate and thus might be funded under 

the OSLTF. NRCS submitted its funding request in 

August, by which time the well had been capped. 

The FOSC made the fi nal determination not to use 

OSLTF funds on the land fl ooding initiative.

8.3 Environmental Compliance with the 

Endangered Species Act

There are 26 threatened or endangered species in the 

Gulf of Mexico area. Oil represented a threat to each 

of them. As endangered and threatened species were 

present in the area where the spill response took 

place, the Endangered Species Act (ESA) requires 

consultation with wildlife management agencies 

prior to taking action that might jeopardize listed 

species or adversely impact their habitat. In 1999, 

the Coast Guard consulted with wildlife management agencies on the general use of dispersants as 

part of its Region VI Regional Response Team (RRT 

VI) Oil Spill Dispersant Use Policy. The policy was 

developed in accordance with ESA consultation 

procedures and pre-authorized dispersant use three 

miles seaward of land in waters at least 10 meters 

deep. This policy formed the basis for the initial use 

of dispersants as part of the Deepwater Horizon spill 

response. In addition, a Memorandum of Agreement 

(MOA) regarding Oil Spill Planning and Response 

Activities under the Federal Water Pollution Control 

Act’s National Oil and Hazardous Substances Pollution Contingency Plan and the ESA was signed in 

June 2001. The MOA guided ESA Section 7 interagency consultation compliance for the Deepwater 

Horizon oil spill. As soon as it became clear that oil 

would likely reach the coastline of the northern Gulf 

of Mexico, the USFWS and other Natural Resource 

Trustee agencies began to compile a list of federally threatened and endangered species likely to be 

VENICE, La. – A member 

of the U.S. Fish and 

Wildlife Service 

documents birds 

aff ected by the oil spill 

and records their overall 

behavior on a daily 

basis to determine if 

human intervention 

was necessary. Photo 

courtesy of U.S. Air Force

JEFFERSON PARISH, La. – A member of the U.S. Fish and Wildlife Service 

carries an oiled pelican from a nesting area in Barataria Bay, La. to a 

waiting boat for transport to a stabilization center on Grand Isle, La. 

Photo courtesy of U.S. Coast Guard
8. Natural Resources and Wildlife

173

SPECIES SCIENTIFIC NAME OCCURS IN

RESPONSE AREA STATUS

Fish

Gulf Sturgeon Acipenser oxyrinchus desoto Y2 Threatened 

Reptiles Y

Loggerhead sea turtle Caretta caretta Y Threatened 1

Green sea turtle Chelonia mydas Y Endangered 

Kemp’s Ridley sea turtle Lepidochelys kempii Y Endangered 

Leatherback sea turtle Dermochelys coriacea Y Endangered 

Hawksbill sea turtle Eretmochelys imbricata Y Endangered 

Alabama redbelly turtle Pseudemys alabamensis Y Endangered 

Birds

Piping Plover Charadrius melodus Y Threatened 

Wood Stork Mycteria Americana Y Endangered 

Mississippi Sand Hill 

Crane Grus canadensis Pulla Y Endangered 

Marine Mammals

Sperm Whales Physeter macrocephalus Y

Sei Whales Balaenoptera borealis Uncommon 

Finback Whales Balaenoptera physalus Uncommon 

Blue Whales Balaenoptera musculus Uncommon 

West Indian Manatee Trichechus manatus Y

Terrestrial Mammals

Alabama beach mouse Peromyscus polionotus 

ammobates Y

Perdido Key beach 

mouse

Peromyscus polionotus 

trissylepsis Y

Choctawhatchee beach 

mouse Peromyscus polionotus allophrys Y

St. Andrew beach 

Mouse

Peromyscus polionotus 

peninsulari Y

Critical Habitat Critical habitat

Gulf Sturgeon Units 8,9,10, 11, 12 Y Critical habitat

Piping Plover Multiple units Y Critical habitat

Alabama beach mouse Multiple units Y Critical habitat

Perdido Key beach 

mouse Multiple units Y Critical habitat

Choctawhatchee beach 

mouse Multiple units Y Critical habitat

St. Andrew beach 

Mouse Multiple units Y Critical habitat

Table 8.1: Endangered and Threatened Species

1

 Loggerheads have been proposed to be updated to endangered status. 2

 The Gulf Sturgeon is an andronomous fi sh; adults spawn in freshwater, then migrate to feed and grow.
174

8. Natural Resources and Wildlife

affected by the oil and the response activities. In 

addition, these agencies gathered conservation recommendations and BMP that would help minimize 

these impacts. On May 12, 2010, USFWS issued 

an emergency consultation letter to federal agencies 

with general guidelines, BMPs, and contact information to support the memorandum of agreement 

with the Coast Guard and acknowledging that an 

emergency Section 7 consultation was underway. 

Shortly thereafter NOAA’s NMFS issued a similar 

letter.

Endangered Species Act Response Actions 

RRT VI did not discuss impacts on specifi c species as part of its deliberations on dispersants, or 

as part of its discussion of other response activities. 

The Environmental Planning Unit of the UAC did 

review species-specifi c impact issues. Those discussions were determined to be “adequate alternative 

procedures ... consistent with the requirements” 

of the ESA under 50 CFR 402.5. More than any 

other of the endangered and threatened species in 

the Gulf of Mexico, the fi ve species of sea turtles 

that live in the Gulf received the most signifi cant 

public and media attention.

The USFWS Emergency Permit to Rehabilitate Sea 

Turtles Affected by the Deepwater Horizon Oil Spill, 

Gulf of Mexico allowed turtle advocates to perform 

the following tasks:

• Examine and document stranded sea turtles,

• Tag turtles,

• Collect data and specimens,

• Transport live and dead sea turtles to rehabilitation facilities,

• Satellite transmit attachment and necropsy sites,

• Locate egg chambers, retrieve 

eggs for protected incubation,

• Provide care for incubating sea 

turtle eggs,

• Release hatchling sea turtles,

• Capture juvenile sea turtles in 

nets, and

• Collect associated data.

The primary elements of the marine mammal and 

sea turtle rescue and protection efforts were twofold. First, the response effort focused on debilitated, distressed, and dead marine mammals and 

sea turtles. As noted previously, the response effort 

signifi cantly augmented the pre-Deepwater Horizon spill marine mammal and sea turtle stranding networks. The increased capacity enhanced 

detection, response, and rehabilitation capabilities 

across the four states of the upper Gulf of Mexico. 

The second prong of efforts to protect sea turtles, 

marine mammals, and other sensitive wildlife, 

was the use of BMPs, which describe practices 

that should be followed by spill responders (during cleanup activities) to minimize, mitigate, or 

avoid impacts to protected resources, including 

sea turtles and marine mammals. The UAC Environmental Unit (Planning Section) managed BMP 

implementation. Development of the BMPs was 

accomplished by a network of liaisons working 

in cooperation with trustee agencies, including 

the USFWS. The Environmental Unit worked 

closely with the Operations Section to identify 

the applicable BMPs for each response activity and 

facilitate their implementation. If a BMP could not 

be complied with, the responders had to provide 

detailed explanations.

Natural Resource Trustee Agency Oversight 

of Endangered Species Act Requirements in 

the Response

NOAA, USFWS, EPA, the National Park Service 

(NPS) and other agencies and organizations sent 

representatives who became involved in day-today discussions of endangered species. In addition, 

GULF OF MEXICO – An aerial view of the Gulf Coast 

shoreline as seen from a C-23 Sherpa aircraft operated 

by the Florida National Guard’s Detachment 1, Company 

H, 171 1st Aviation unit, which supported the Fish and 

Wildlife Conservation staff in its eff ort to photograph 

and report tar and oil that approached the shoreline. 

Photo courtesy of U.S. Army
8. Natural Resources and Wildlife

175

several volunteer groups contributed time and 

resources to the turtle recovery programs.

The Coast Guard and the EPA had incorporated the 

established ESA Section 7 consultation procedures 

into the response effort, including the procedures 

regarding the use of dispersants. Dispersants have 

not been used in the Deepwater Horizon response 

since July 19, 2010. However, consultation is 

ongoing, and the Coast Guard, EPA, and other 

agencies continue to work to assess the impact of 

the spill on endangered and threatened species.

The FOSC conducted emergency consultation with 

NOAA and USFWS throughout the process of 

approving dispersants for use. This consultation 

followed the procedures of the ESA implementing 

regulations 50 CFR 402.05 and the Inter-agency 

Memorandum of Agreement Regarding Oil Spill 

Planning and Response Activities Under the Federal Water Pollution Control Act’s National Oil and 

Hazardous Substances Pollution Contingency Plan 

and the ESA (2001) Memorandum of Agreement. 

The emergency consultation procedures allowed 

the FOSC to draw upon endangered species expertise and incorporate concerns about listed species 

into response efforts under the National Contingency Plan and relevant Area Contingency Plans.

Several BMPs specifi c to the use of dispersants 

were developed and implemented by the Environmental Unit within the Resources at Risk group 

in each ICP. These BMPs included monitoring 

criteria to detect surface dwelling species and geographic limitations that would prevent any impact 

dispersants might have on sensitive habitats. 

In addition, EPA undertook multi-phase toxicity 

testing of eight chemical dispersants listed on the 

National Contingency Plan product schedule. EPA 

also monitored dissolved oxygen levels at and 

around the well site where sub-surface injection of 

dispersants was occurring. Monitoring information 

and data are posted on EPA’s website at http://

www. epa.gov/bpspill/. NOAA also dispatched the 

research vessel Gordon Gunter to study the effects 

of the spill on endangered sperm whales and other 

species.

During the midst of the response the FOSC was 

informed of one potential lawsuit and an actual suit 

that was fi led—both centered on concerns about 

the impact of response activities on endangered 

species. On June 2, 2010, a Notice of Intent to 

Sue alleged that the Coast Guard and the EPA had 

unlawfully exceeded their authority by allowing 

specifi c chemical dispersants to be used in response 

to the Deepwater Horizon spill in amounts unanticipated in environmental planning documents 

covering regional oil spill response operations; 

thus they had not satisfi ed requirements for ESA 

Section 7 consultations. Review of the applicable 

regulations and memorandum of agreement about 

emergency consultations, as well as information 

about the BMPs, persuaded the non-governmental 

organization that fi led the suit to fi rst engage the 

Coast Guard, EPA, and trustee agencies rather than 

immediately pursue a lawsuit.

The Coast Guard worked with the Department of 

Justice to defend the ICP Houma response operations and protocols relating to in situ burns and turtle 

protection. As part of the government’s reply, the 

FOSC submitted a declaration that explained the 

response processes, authorities, endangered species oversight, and consultation with NOAA and 

USFWS, and the value of in situ burning provided 

as a response mechanism. Four non-profi t environmental organizations fi led suit that sought to enjoin 

future oil spill response operations (including in 

situ burns) that could endanger sea turtles. Prior to 

the July 2, 2010 hearing, the plaintiffs voluntarily 

withdrew their motion for a Temporary Restraining Order; however, the complaint is still pending.

The BMPs for turtles specifi cally included having 

turtle rescue vessels, with trained rescue personnel, accompany burn taskforces into the burn box. 

Personnel would then rescue the turtles prior to 

burning operations, while oil was being boomed 

PENSACOLA, Fla. – 

A National Park Ranger 

guides citizens through 

orientation and training 

to become volunteer 

park rangers for Gulf 

Islands National 

Seashore to educate the 

public on information 

regarding the impact of 

the Deepwater Horizon

oil spill on the shores 

and beaches. Photo 

Courtesy of U.S. Army. 
176

8. Natural Resources and Wildlife

or awaiting burning. Where 

turtle rescue vessels were 

unavailable, BMPs sent 

turtle rescue vessels into the 

next day’s projected burn 

box to search for and rescue 

turtles, and had a trained 

observer or a crew member dedicated to looking 

for sea turtles (and marine 

mammals) join corralling 

operations to record each sighting event.

Upon receiving the notice of the impending ESA 

lawsuit, ICP Houma and the UAC searched for any 

information that might suggest that the in situ burning practices caused turtle death. They found that of 

the dead turtles found in the Gulf of Mexico, none 

showed evidence of being burned. Furthermore, 

no observations were reported of any turtles being 

burned by ICP Houma in situ burns.

Emergency consultations occur, as addressed in the 

memorandum of agreement, during responses to an 

oil spill in order to give advice on measures that will 

minimize effects from response actions. USFWS 

fi eld offi ces in Alabama, Florida, Louisiana, and 

Mississippi assisted the U.S. Army Corps of Engineers (USACE) by responding to multiple requests 

for emergency consultation for specifi c response 

actions permitted by the USACE, such as boom 

placement, dredging, and temporary dock placement to accommodate response actions initiated 

by state agencies or other non-federal entities. The 

fi eld offi ces also provided local support in identifying areas of natural resource concerns, temporary 

meeting facilities, and local points of contact to the 

Natural Resource Damage Assessment (NRDA) 

and response teams.

In June 2010, the 

USFWS staffed 

the UAC with an 

ESA Liaison. Also, 

the USFWS and 

NMFS developed 

a list of refined 

BMPs by habitat 

type to minimize 

impacts to listed 

species and critical 

habitats. Since early 

July, these checklists 

were incorporated 

into every Shoreline Treatment Recommendation 

(STR) and supplied to all Natural Resource Advisors (NRAs) and Resource Advisors (READs). A 

Section 7 liaison was placed into each sector and 

each state Branch to maintain ESA compliance, 

answer BMP questions, provide training, and maintain documentation. Job aids and compliance checklists were developed to facilitate the implementation 

and monitor the effectiveness of the BMPs, and to 

document any catch. In December 2010 and early 

January 2011, the USFWS updated the BMPs.

In order to document baseline conditions for the 

NRDA, as well as impacts of the oil spill on threatened and endangered species, the USFWS expedited 

the review and issuance of a number of research permits under the ESA. The review allowed the permitting of incidental take of endangered or threatened 

species for scientifi c research and to enhance the 

propagation or survival of listed species.

With the success of the static and bottom kills of 

the Macondo well, a transition period began that 

afforded NMFS, the USFWS, and the Coast Guard 

time to prepare for the after-the-fact formal interagency consultation under Section 7 of the ESA. 

As of early February 2011, the USFWS continued 

to staff six Section 7 liaisons to the incident and 

to coordinate information requests, BMP compliance issues, and additional guidance as required. 

For example, the USFWS prepared training for each 

state Branch offi ce to educate READs and NRAs on 

courtship and nesting behaviors of shorebirds and 

colony nesting migratory birds. The READs and 

NRAs could then delineate the habitats, allowing 

work crews and response actions to avoid the area 

while continuing cleanup operations. The USFWS 

provided maps of known nesting locations to prioritize cleanup in these areas, so that the cleanup 

could be completed prior to the beginning of the 

2011 nesting season.

The USFWS and NMFS are currently assisting the 

FOSC in review of a statement of work to contract 

the preparation of a biological assessment. The 

biological assessment will address all the potential 

and known effects to endangered and threatened 

species, and their critical habitats resulting from 

cleanup activities associated with the Deepwater 

Horizon spill. The biological assessment will also 

include an analysis of ESA effectiveness regarding 

the compliance process implemented during the 

response. Once the biological assessment is fi nalized, the USFWS will analyze the effects of the 

GULF OF MEXICO – 

A U.S. Coast Guard 

offi cer logs sample 

data from oiled water 

in the Gulf of Mexico 

to help environmental 

scientists determine 

the eff ectiveness of 

dispersants used to break 

down oil. Photo courtesy 

of U.S. Coast Guard

VENICE, La. – An oil burn 

task force, which includes 

a wildlife observer 

looking out for any oiled 

wildlife, particularly 

turtles, watches a recently 

ignited in situ burn in the 

Gulf of Mexico. Photo 

courtesy of U.S. Air Force
8. Natural Resources and Wildlife

177

cleanup activities in a Biological Opinion. It will 

determine the amount of take that has occurred, if 

any terms and conditions are needed to minimize 

that take, and if any recommendations are needed 

to facilitate ESA compliance during future spill 

response activities.

While the 2001 memorandum of agreement among 

the Coast Guard, NMFS, and EPA outlined emergency consultation procedures, it did not specifi cally 

identify positions in the ICS as an ESA Liaison. 

After BMPs were provided, it took considerable 

work to incorporate them into the Shoreline Treatment Recommendations (STRs) and for BMP 

checklists to be provided to work crews. The turnover of personnel and lack of consistency over time 

hampered the rapid processing of approvals and 

information requests.

8.4 Wildlife Challenges

All wildlife operations encountered challenges 

in three major areas: communications, training 

and preparedness, and logistics. Communication 

was a challenge throughout the response given the 

large scale of the event. As NOAA and USFWS 

had never before engaged in a response this size 

for sea turtles or marine mammals, it was a challenge to ensure MMSTG information was shared 

among those serving in command posts, in organizational functions but at their home offi ce, and 

those deployed in the fi eld. Despite conference 

calls and virtual meeting technologies, messages 

were often not correctly conveyed and understood.

Information sharing between wildlife-focused 

portions of the incident command such as the 

MMSTG and other UAC fi eld operations, SCAT 

fi eld teams, NRDA fi eld teams, and the VOO coordinators was also challenging. Often information 

was communicated to counterparts in the ICPs 

for ultimate use by these programs, but was not 

transferred effectively to the fi eld. It was diffi cult 

for biologists and experts to inform the public 

of the immense efforts undertaken to respond to 

migratory birds, marine mammals, and sea turtles.

Training and preparedness was another challenge 

that pre-existing stranding network responders 

and agency personnel faced. While oil spill and 

ICS training had been previously offered to these 

members, it was not taken by everyone due to the 

perceived low probability of being involved in an oil 

spill. Remedial training efforts were made through 

mechanisms such as recorded Webinars, but those in 

the fi eld did not always utilize these opportunities. 

Supplies and equipment were not always readily 

available. 

Logistics had a signifi cant impact on both personnel and equipment. Contracts took time to process 

through the UAC Logistics Section. Proper distribution of equipment and reporting information 

to individuals in the fi eld was also a challenge. 

Although reporting and collection protocols were 

disseminated at the Houma and Mobile ICPs, they 

did not consistently reach cleanup operations and 

SCAT teams on the beaches. This diminished the 

effectiveness of stranding responders. Delays 

locating and then procuring specialized de-oiling 

equipment, additional 

tanks, and veterinary 

and husbandry supplies caused signifi cant 

impacts on the wildlife 

operations.

Personnel from the 

USFWS National Conservation Training Center did an excellent job of 

establishing a training system. However, training needed to convey the unique safety precautions to both bird specialist personnel and those 

personnel involved in oil spill cleanup. Many of 

the responders did not appreciate the harm that 

could come to birds from their actions, and many 

biologists did not respect the potential harm that 

could result from carelessness near spilled crude 

oil. Cross-training and experience in both areas 

would have been benefi cial. Developing systems to 

train workers quickly for HAZWOPER certifi cation and wildlife capture for rehabilitation created 

a challenge that was answered on an ad hoc basis.

HOUMA, La. – A 

veterinary avian 

specialist takes a last look 

at some Brown Pelicans 

before they depart in a 

Coast Guard HC-144A 

Ocean Sentry aircraft 

for a fl ight to the Port 

Aransas National Wildlife 

Refuge in Texas where 

they will be released. 

Photo courtesy of U.S. 

Coast Guard

GULF OF MEXICO – The 

U.S. Fish and Wildlife 

Service leads the 

wildlife and habitat 

recovery eff orts in the 

Deepwater Horizon oil 

spill. Photo courtesy of 

U.S. Fish and Wildlife 

Service
178

8. Natural Resources and Wildlife

Some response actions, 

undertaken independently 

of the FOSC response organization, caused additional 

harm to wildlife habitat, 

such as changing the profi les of dunes, eliminating 

dune vegetation, compacting beach sand with equipment, and disturbing birds 

and nesting sea turtles with 

the volume of personnel 

responding. Trying to protect bird-nesting colonies with boom anchored in 

areas of strong currents and high wave action for 

sustained periods caused the spilled oil to become 

sequestered inside the boomed area adjacent to the 

nesting colonies. This increased the birds’ exposure 

spatially and temporally. It should be noted that 

some of the boom provided more of an esthetic 

barrier than actual environmental protection.

Despite these challenges, signifi cant and unprecedented achievements were made in several areas:

1. Successful rehabilitation of marine mammals 

and a large number of oiled sea turtles;

2. On-water capture of sea turtles;

3. Marking of nests and relocation of sea turtle 

eggs; and

4. The overall efforts to protect and mitigate the 

damage to all the wildlife. The experiences 

gained will help improve future responses.

8.5 Section 106 of the National Historic 

Preservation Act Consultations

Situation

Section 106 of the National Historic Preservation 

Act, 16 U.S.C. 470f, requires all federal agencies to 

consider historic properties when conducting their 

activities. These responsibilities are carried out in 

the context of federal agency response to oil spills 

in accordance with the 1997 Programmatic Agreement for the Protection of Historic Properties during 

Federal Emergency Response. The Programmatic 

Agreement requires the FOSC, in the context of spill 

response, to consult with all stakeholders regarding 

possible impact of the spill, and response activities 

on Historic Properties. It also requires the Coast 

Guard to conduct, on a government-to-government 

basis, consultations with federally recognized tribes 

having either current land ownership or historic 

interests in the impacted areas.

During the course of the response, 778 archeological sites were checked, including 113 newly 

discovered sites located during the response. Of 

those sites, 121 were impacted by oil or response 

activities (four in Alabama, 39 in Florida, 59 in 

Louisiana, and 19 in Mississippi).

The Department of the Interior provided expert 

staff, mostly from the NPS, to assist the FOSC 

with carrying out the responsibilities within the 

Programmatic Agreement from the earliest days 

of the response. Given the geographic scope of the 

impacted shoreline from the Deepwater Horizon

spill, it took time to gather information about the 

full extent of impact of the spill on historic sites.

Historic property information is sensitive. This is 

particularly true of Native American sites. Most 

State Historic Preservation Offi ces (SHPO) carefully control access to information about historic 

sites as part of the preservation process. Native 

American tribes are even more cautious about 

access to information about their sites. Coordinating historic property information across fi ve states, 

including the interests of eleven federally recognized tribes, was diffi cult and required the assistance 

of historic properties specialists on a scale not previous encountered in a spill response.

Another issue faced when addressing historic and 

traditional cultural properties is the presence of nonfederally recognized Indian tribes in the impacted 

area. Federal law confers standing and rights only on 

tribes recognized by the federal government. Some 

groups in the area are recognized by states as Indian 

tribes, and some have applied for recognition by the 

federal government. These groups, from the perspective of the FOSC carrying out responsibilities under 

federal law, are not afforded rights to consultation. 

The FOSC did meet with them, separately at times, 

and allowed them to voice their concerns through 

cultural monitors, but not through tribal monitors 

and not in the context of government-to-government 

consultations.

RACCOON ISLAND, La. – 

Members of a Shoreline 

Cleanup Assessment 

Technique team search 

for oil on Raccoon Island, 

a protected bird breeding 

sanctuary with a variety 

of species. Photo courtesy 

of U.S. Navy
8. Natural Resources and Wildlife

179

First Actions Taken

The fi rst steps toward compliance with Section 106 

were taken by the RP. Before the end of April 2010, 

the RP hired an environmental services contractor 

who initially supplied an archeologist to assist with 

archeological sites that might be impacted by the 

spill. On approximately May 4, 2010, the NPS 

conducted a conference call with a federal agencies 

stakeholder to discuss actions that might need to 

be taken to protect historic properties and comply 

with Section 106. By mid-May, NPS had its fi rst 

Section 106 staff member at the UAC. Over the 

next several weeks, NPS worked to ensure Section 106 concerns were brought to the attention 

of the FOSC. The Section 106 staff worked with 

the response documentation staff to address concerns about access to information on archeological 

sites and traditional cultural properties, which was 

developed during the course of the response.

Challenges

The biggest challenge faced was that Section 106 

requires consultation with stakeholders prior to any 

ground disturbing activities, with a 30-day review 

period of proposed undertakings prior to approval. 

The Section 106 team used the broad language of 

the Programmatic Agreement to adapt the review 

protocols to meet the intent of the law whereby 

input was provided within a few days, rather than 

the standard 30 days.

Another challenge for Section 106 compliance 

was the lack of capacity of the SHPOs and the 

federally recognized tribes to participate in a 

response organization of this size, especially over 

an extended period. As a result, the NPS hired 

persons selected by the SHPOs and Tribes with 

delegated authority to serve as SHPO and tribal 

liaisons. This approach required the willingness of 

the tribes to make signifi cant concessions in regard 

to direct government-to-government consultation 

with every tribe having concerns in the affected 

areas. This innovative approach was successful in 

giving stakeholders meaningful input into consultation and regarding protecting historic properties. 

As such, it is worth emulating in other disaster 

response contexts.

Resources Used

The archeological services contractor hired to assist 

the RP in Section 106 requirements performed 

site identifi cation and assessments, collected data, 

provided advice and expertise to responders, and 

generally ensured that the requirements of Section 106 and the Programmatic Agreement were 

met. The RP consistently held its contractors to 

a high standard of compliance with historic and 

traditional cultural properties requirements.

Once the well was capped, the fi rst opportunity 

arose to examine the entire cleanup operation from 

the perspective of the need to comply with the 

National Historic Preservation Act. As such, NPS 

planned a formal consultation between the FOSC 

and historic properties stakeholders.

Phase Two Actions Taken

Although historic properties consultations took 

place continuously from the outset of the response, 

the fi rst formal consultation between the FOSC and 

stakeholders regarding historic properties took place 

on August 20, 2010. The NPS Historic Properties 

specialists organized this consultation. Participants 

in the meeting included SHPOs from fi ve states, 

representatives of federally recognized and state 

recognized Indian Tribes, and interested federal 

agencies.

The meeting provided a forum to discuss a range of 

issues with those having interest in historic properties. One example was a subcontractor who established a staging area at a National Historic Landmark 

NEW ORLEANS – Members 

of the U.S. Coast Guard 

meet with governmental 

members of federally 

recognized Native 

American tribes during 

a government-togovernment consultation 

regarding the Deepwater 

Horizon response in New 

Orleans. Photo courtesy 

of U.S. Coast Guard
180

8. Natural Resources and Wildlife

in Alabama. The subcontractor closed the 

park to the public and 

to the state agency 

that administered the 

site, and engaged in a 

variety of ground disturbing activities at the 

park without consulting 

with the State. There 

was a Native American burial site within 

the park, which posed 

a major concern. When the RP Incident Commander 

learned of the contractor’s actions at Fort Morgan, 

they immediately fi red the contractor.

On June 14, 2010, the NPS held its fi rst meeting 

with only the federally recognized tribes concerning 

the response and the protection of traditional cultural properties. That meeting led to the hiring of the 

fi rst tribal liaison in early July. The fi rst governmentto-government consultations with the FOSC and 

eleven federally recognized tribes took place on 

September 17, 2010. The tribes that attended were:

• Alabama-Coushatta Tribe of Texas,

• Chitimacha Tribe of Louisiana,

• Choctaw Nation of Oklahoma,

• Jena Band of Choctaw Indians,

• Mississippi Band of Choctaw Indians,

• Muscogee (Creek) Nation of Oklahoma,

• Seminole Tribe of Florida, and

• Thlopthlocco Tribal Town.

The United South and Eastern Tribes, an umbrella 

organization representing the interests of 25 tribes 

in the eastern states, also attended.

NEW ORLEANS – 

Members of the 

Muscogee Creek Nation, 

Thlopthlocco Tribal Town, 

the U.S. Coast Guard, and 

other local, state, and 

federal agencies attend 

the Historic Property 

and Cultural Resource 

Trustee meeting in New 

Orleans, La., to discuss 

the ongoing Deepwater 

Horizon oil spill response 

and the impact on 

historical properties. 

Photo courtesy of U.S. 

Coast Guard

NEW ORLEANS – A second chief from the Muscogee (Creek) 

Nation of Oklahoma speaks with members of the Deepwater 

Horizon response during a government-to-government tribal 

consultation in New Orleans. The purpose of the meeting was 

to discuss consultation on the protection of historic and cultural 

properties and tribal lands during the response. Photo courtesy 

of U.S. Coast Guard

The tribes expressed concern that consultations with 

the FOSC had not taken place earlier, and requested 

to begin the consultations with direct discussion 

with the FOSC alone. The consultations resulted 

in a list of action items:

• Meet with the FOSC on a regular basis;

• Hold a second consultation with the tribes 

(which took place, per their request, on November 12, 2010);

• Create a map of the oiled archeological sites,

• Utilize cultural monitors on archeological 

surveys;

• Develop a Sharepoint website to share information with the tribes;

• Develop processes for handling archeological 

and ethnographic data developed during the 

course of the response;

• Develop a binding non-disclosure agreement 

for beach operations personnel and boat operators to ensure all those who obtain information 

on archeological sites agree not to disclose anything about the locations or contents of those 

sites (the RP developed an agreement within a 

week of the consultations); and

• Provide the tribes access to the UAC and Gulf 

Coast IMT organization charts.

After the initial meeting, four more governmentto-government consultations took place between 

the tribes and the FOSC. Tribal monitors have participated in the SCAT Teams, and tribal liaisons 

continued to review Shoreline Treatment Recommendations to address traditional cultural property 

concerns.
9. Government Personnel

181

The issue of personnel readiness and training is also addressed in the Coast Guard’s Incident Specifi c Preparedness Review 

(ISPR). The discussion in this chapter mostly 

focuses on specifi cs of federal government personnel and training issues and does not duplicate 

other readiness efforts addressed in Section III.1 

of the ISPR Report.

9.1 Federal 

Government 

Personnel Overview

The response to the mobile 

offshore drilling unit 

Deepwater Horizon oil 

spill was the single largest peacetime operation in 

U.S. Coast Guard history. 

The response to this Spill 

of National Signifi cance 

mobilized more than 7,750 

personnel, which caused 

unprecedented challenges 

to the Coast Guard’s personnel resources. The 

42,883 Coast Guard 

active duty force is generally fully employed 

executing the 11 statutory 

missions of the organization, which leaves very 

little surge capability. The 

authorized 8,100 member 

Coast Guard Reserve does 

provide an organizational surge capability, but the 

focus of workforce planning for the Reserve since 

2001 has been to respond to Maritime Security 

threats and support U. S. Department of Defense 

(DOD) operations. As such, neither the Active 

Duty Coast Guard nor the Reserve was structured 

to provide the specifi c skill sets or competencies 

required to respond to an environmental contingency of this magnitude.

Other governmental agencies also dispatched large 

numbers of response personnel. For example, the 

U.S. Fish and Wildlife Service (USFWS) deployed 

1,761 personnel, seventeen percent of its workforce. The National Park Service fi lled 1,200 

requests for personnel, a number of which were 

fi lled by people who deployed multiple times. The 

Department of Interior (DOI) sent a total of 214 

RIVIERA BEACH, Fla. – Personnel 

from diff erent federal and 

Florida state agencies discuss oil 

identifi cation procedures during 

a Shoreline Cleanup Assessment 

Technique team training scenario 

held at U.S. Coast Guard Station 

Lake Worth Inlet, Texas. Photo 

courtesy of U.S. Coast Guard

COCDRIE, La. – Members 

of a Rapid Assessment 

Team (RAT) investigate 

and collect tar balls 

discovered on the south 

shore of Timbalier Island, 

La. RAT teams are multiagency response teams 

designed to respond to 

initial reports of potential 

oil on the coast and in the 

Gulf. Photo courtesy of 

U.S. Coast Guard

staff to the response. The DOI Offi ce of Environmental Policy and Compliance had eight people 

deploy to the Gulf and fi ve to the National Incident 

Command (NIC), and fi fteen others who performed 

some work related to the response. The DOI Offi ce 

of Occupational Health and Safety deployed 80 

percent senior technical staff and twelve other 

people from elsewhere in DOI to assist with health 

and safety concerns. The Bureau of Land Management deployed two personnel. The U.S. Geologic 

Survey had 420 employees and contractors work 

on the spill response. NOAA personnel from across 

the agency participated, contributing numerous 

areas of expertise. Finally, the Bureau of Ocean 

Energy Management, Regulations and Enforcement (BOEMRE) had 170 personnel work on the 

spill response, both in the Gulf region and on the 

NIC staff.

The scope and scale of the Deepwater Horizon event 

overlapped jurisdictions and authorities at the federal, state, and local levels. Agencies, including the 

National Oceanic Atmospheric Association, Department of Interior, Department of Justice, Department 

of Defense, the Department of Homeland Security, and the states of Alabama, Florida, Louisiana, 

Mississippi, and Texas all contributed personnel to 

the response. Several of the agencies experienced 

similar limited surge capability issues as the Coast 

Guard. Some agencies employed creative personnel 

solutions, including the 

recall of retired personnel with Incident Command System (ICS) and 

environmental response 

experience.

BP accepted designation 

as the Responsible Party 

(RP) for the Deepwater 

Horizon event. Had BP 

not assumed responsibility, the Federal On-Scene 

Coordinator (FOSC) 

would have been required to hire a broad array of 

contractors and cleanup personnel , funded through 

the Oil Spill Liability Trust Fund (OSLTF). While 

this was not necessary, the OSLTF was still utilized as the mechanism for funding the mobilization of government personnel, reimbursed by the 

RP. The total number of personnel working on the 

response peaked at approximately 47,000 people 

in July 2010.
182

9. Government Personnel

The Coast Guard mobilized 14 percent of its 

total workforce as part of the Deepwater Horizon response (7,750 people out of a combined 

active duty and Reserve force of approximately 

51,000). This required developing a careful balance 

between providing on-scene response capabilities 

while simultaneously performing the remainder of 

the Coast Guard’s missions. In other words, only 

Reservists can be considered as “surge” personnel. 

Active duty personnel were pulled away from other 

missions using a risk model, and creating a greater 

risk to Coast Guard missions in various locations 

across the nation.

9.2 Staffi ng the Response

The Deepwater Horizon response was unique in 

the history of United States environmental events 

in that the source of the spill was uncontrolled for 

a long period (87 days), and therefore the impacts 

covered a large area. Trying to control the disaster 

at the outset by committing all available resources 

had to be balanced by the possibility of staffi ng 

the response for several months or even years. 

These unique consequences presented challenges 

to staff the Deepwater Horizon event. To capture 

these challenges, it is best to examine response 

staffi ng in three separate phases, each with distinct 

obstacles to overcome. These phases include the 

initial phase, which lasted for the fi rst 30 days of 

the event; a dynamic phase, which spanned day 

31 through 120; and a transitional phase, from day 

121 through the date of this report.

There is a distinct element of personnel logistical 

support, including transportation, berthing, messing, medical, and administrative support addressed 

in Chapter 6. The Personnel Section is primarily 

focused on planning and sourcing activities.

9.3 Initial Phase 

(April 20 – May 19, 2010)

The initial phase of the incident was characterized 

by great uncertainty surrounding the scope of the 

event. During the initial search and rescue phase, 

and the subsequent realization that oil was indeed 

escaping from the broken riser, personnel requirements were largely undefi ned. As knowledge of the 

scope of the event changed at a frenetic pace, planners struggled to remain apprised of the emerging 

requirements, making it very diffi cult to develop a 

functional incident personnel list.

The earliest Coast Guard response was executed 

with active duty and Reserve personnel assigned 

to local commands in Robert and Houma, La. Support from active duty forces sourced at the national 

level soon followed. The Coast Guard was quick to 

request the ability to involuntarily recall Reserve 

forces that were under authority granted within 

14 U.S.C 712 for an initial authorization of 500 

Reserve personnel. This required Secretary-level 

approval, which was granted within days of the 

request. A short delay in approval was due, in part, 

to the determination of how the OSLTF would be 

accessed to fund pay and entitlements for Reserve 

forces being brought on duty before April 23, 2010.

Although Reserve forces and Coast Guard Chaplains from local responding units were on scene 

from the outset of the event, the fi rst Reserve forces 

mobilized on the national level began to arrive in 

theater April 23, 2010. In total, 1,138 Coast Guard 

personnel rotated through the event during this 

phase of the response, with an average of 834 personnel in theater on any given day. The initial rotational period for active duty personnel was 30 days, 

and 60 days for Reservists. The primary difference 

in active duty and reserve periods was driven by 

reserve recall duration defi ned in 14 U.S.C. 712. 

Civilian personnel rotations varied by position.

VENICE, La. – The Coast 

Guard Reserve Forces 

Master Chief meets with 

members of the Coast 

Guard reserves deployed 

to Venice, La. Photo 

courtesy of U.S. Coast 

Guard

Figure 9.1 Coast Guard Personnel in theater 

by Type, May 19, 2010
9. Government Personnel

183

Initial personnel requirements focused on certain 

core competencies that impacted specifi c Coast 

Guard skill set communities, such as command 

and control (i.e., ICS) staff, marine safety, public 

affairs, fi nancial and administrative support, and 

Chaplain personnel. The specifi c core competencies and qualifi cations included the ICS, Federal 

On-Scene Coordinator Representative (FOSCR), 

Pollution Investigator (PI), Public Affairs (PA), and 

Procurement Offi cials with contracting warrants. 

The great demand for personnel with those specifi c competencies quickly strained the Coast Guard 

human resources inventory during the initial phase 

of the response.

A portion of the personnel rotating through the 

Deepwater Horizon response area included 16 Coast 

Guard Chaplains, one Navy Reserve Chaplain, as 

well as Chaplains from the Civil Air Patrol and the 

Army Air National Guard. Civilian pastoral services 

were not contracted for the duration of the response 

but were provided by volunteers. At the beginning 

of the response effort, all Chaplain services were 

provided by the four Chaplains assigned to Coast 

Guard District 8. Additional Coast Guard Active 

Duty and Reserve Chaplains were requested from 

the onset of the response and began reporting on 

June 15, 2010, to augment the District 8 staff. Chaplains from all agencies provided essential support 

to response personnel such as religious worship 

services for multiple faiths. Separation, family, 

grief, and individual counseling sessions were also 

provided. Chaplain services were not restricted to 

military members, but instead were open to all 

governmental agencies and contracted personnel. 

Services were based in the major ICPs rotating with 

Chaplains through all Branches on a regular schedule with additional site visits as requested.

9.4 Dynamic Phase 

(May 20 – 15 August 15, 2010)

As the scope of the environmental impacts of 

the event became more defi ned, media scrutiny 

and public perception of the unfolding events led 

to increased interest and involvement by political leadership. This resulted in a tripling of government responders following Presidential and 

U. S. Department of Homeland Security (DHS) 

Secretary visits, and subsequent directives, in late 

May. This increase in requirements created a mass 

infl ux of personnel ordered into theater ahead of 

existing plans for their utilization. It overtaxed the 

response organization’s personnel processing ability, and stressed the Coast Guard’s pool of qualifi ed personnel. Other agencies also experienced 

strains associated with the need to immediately 

grow the size of the response organization, and 

sustain the number of people needed to oversee 

response operations over many months.

In order to manage the arrival and fi eld deployment of incoming personnel, a central arrival and 

in-processing area was established in Kenner, La. 

This central processing facility helped redirect some 

arriving personnel to higher priority positions than 

those they were originally ordered to fi ll. While 

this enhanced the capability of the FOSC to meet 

emerging requirements, it became apparent that 

personnel management systems had gaps caused by 

the mid-stream redirection. This created uncertainty 

about which requirements still needed to be fi lled. 

The process of correcting for these redirections was 

time consuming and diffi cult.

In total, 4,986 Coast Guard personnel rotated 

through theater during this phase, with a peak 

number of 2,855 personnel in theater on July 17. 

One tool that proved valuable in reducing the number of personnel rotations was a newly instituted 

ability to offer Reservists 

voluntary Active Duty 

Operational Support 

(ADOS) orders for periods up to 180 days. ADOS 

orders were granted at the 

conclusion of the Reserve 

member’s 60 days of involuntary Title 14 active duty. 

By the end of this phase, 

approximately 350 Reservists volunteered for ADOS, 

Figure 9.2: Coast Guard Personnel by Skill 

set May 19, 2010

VENICE, La. – U.S. Coast 

Guard Capt. Larry Hewett, 

Incident Commander for 

the Deepwater Horizon

Houma Incident Command 

Post, speaks during an 

all-hands meeting to 

answer questions from 

Coast Guardsmen about 

the current and future 

operations. Photo 

courtesy of U.S. Coast 

Guard
184

9. Government Personnel

signifi cantly reducing the number of personnel 

rotations required. Planning for the potential use of 

targeted skill sets of personnel from other government agencies occurred during this phase, but was 

not widely implemented due, in part, to a slowing pace of operations after well containment on 

August 15, 2010.

9.5 Transitional Phase 

(August 16, 2010 – December 17, 2010)

By August 15, 2010, the discharge from the Deepwater Horizon event had been secured; the permanent well kill occurred September 19, 2010. 

No recoverable oil was observed in the offshore 

environs, and operations focused on near-shore 

and onshore locations, as well as on equipment 

recovery. During this period, the NIC transitioned 

response leadership to the Unifi ed Area Commander and FOSC. The Unifi ed Area Command 

(UAC) worked with state and local offi cials to draft 

and implement an acceptable transition plan that 

would reduce the size of the response organization 

footprint in affected states.

Also during this time, the organizational structure 

changed. For most of the response, operations were 

organized through the UAC with Incident Command Posts (ICPs) in Houma, La., and Mobile, 

Ala., and smaller command posts in Miami, Fla., 

and Houston, Texas. An air operations center was 

located at Tyndall AFB, Panama City, Fla. With the 

source secured and response operations focused on 

shoreline cleanup, there was no longer the need for 

the overhead of ICPs Galveston, Houston, Houma, 

Mobile, and Miami, so the demand for aviation 

sorties dropped dramatically.

Beginning September 20, the ICPs were consolidated into a single Gulf Coast Incident Management Team (GC–IMT), located in New Orleans 

with the UAC. This consolidation resulted in a 

personnel requirement of 253 CG personnel.

On December 17, the UAC dissolved and the GC–

IMT remained.

9.6 Project Phase

 (December 18, 2010 – Present)

By December 18, 2010, most stretches (approximately 90 percent) of beach and marsh had Shoreline Treatment Recommendations (STRs) that 

outlined the steps toward fi nal cleanup. Most of 

these stretches of beach and marsh were already in 

the maintenance and monitoring phase. In essence, 

each STR represented a project. Each project had 

associated resource requirements and an estimate 

timeline until it was complete. The response was 

no longer a dynamic, reactionary event, but a 

quasi-systematic project. The remaining smaller 

stretches of beach or marsh needed new STRs and 

some existing stretches needed revised STRs, but, 

overall, the response was being managed as a massive project with sound performance and activity 

metric that enabled overarching decisions to move 

resources and effort to environmentally and politically sensitive areas across the AOR.

9.7 Coast Guard Personnel Tracking

The primary Coast Guard personnel management 

system, the Mobilization Readiness Tracking Tool 

(MRTT), struggled to keep up with the volume and 

position specifi c requirements that would allow 

Incident Commanders to re-allocate forces within 

an ICS construct.

Figure 9.3: Coast Guard Personnel in Theater 

by Type, July 17, 2010

Figure 9.4: Coast Guard Personnel in 

Theater by Type, February 1, 2011
9. Government Personnel

185

Also, personnel were frequently shifted to different 

positions and locations. This personnel transfer 

process was called reallocation. When members 

transferred, the CRU had to ensure the moves were 

properly recorded—a diffi cult process, considering 

the number of shifts and the number of locations 

in which personnel were deployed.

9.8 Other Federal Agency Personnel 

Eff orts

Strains to provide personnel to participate in the 

Deepwater Horizon response were not limited to 

the Coast Guard. All agencies that played a role 

in the spill response were challenged to staff the 

response organization with appropriately skilled 

personnel.

For example, the USFWS deployed 1,761 responders (17 percent of its workforce), many of whom 

deployed multiple times. USFWS responders 

contributed over 586,000 hours of work (or the 

equivalent of 338 full time employees) through 

February 12, 2011. This number does not include 

the numerous contributions from state and federal partners who deployed in support of USFWS 

activities and who were critical to USFWS activities, especially during the preliminary stages of 

the response. As of mid-October 2010, USFWS 

received assistance from more than 313 individuals 

(greater than 74,000 hours or 71 FTE) from numerous state and federal agencies, and administratively 

determined hires.

There were a total of more than 1,000 individuals deployed as part of EPA’s efforts in response 

to the Deepwater Horizon oil spill. This included 

both direct support to fi eld operations, EPA, and 

contractor personal from EPA Regions 4 and 6, as 

well as support from the Emergency Operations 

Centers in Washington, D.C., Atlanta, Ga., and 

Dallas, Texas. This number does not include the 

hundreds of individuals who also provided support 

from their offi ces. Of the numbers mentioned, many 

individuals were deployed for numerous rotations.

The USFWS has a small contaminants program 

representing approximately 200 individuals nationwide who typically respond to oil and hazardous 

substance releases. The USFWS initial response 

relied heavily on this contingent. However, the 

requirements of this response quickly overwhelmed USFWS’ typical responder pool. At the 

height of the response USFWS had approximately 

500 people deployed at one time. 

The duration of this response also 

taxed its resources beyond sustainable levels, and it had to rely 

on wild land fi refi ghting teams 

to provide planning, logistical, 

and operations support. USFWS 

also relied heavily on other state 

and federal agency partners for 

assistance.

This response was unique in 

that a large number of technical 

specialists were required to fulfi ll USFWS obligations and to 

provide support to response and 

cleanup efforts. The USFWS 

deployed wildlife observers and 

handlers (by ground, boat, and 

air), Endangered Species Act Section 7 and National Historic Preservation Act Section 106 experts, resource advisors, veterinarians, 

and many others. This response also taxed very 

limited sets of potential responders in the areas 

of public affairs, safety, air operations, fi nance, 

and administration, information technology, and 

documentation. Very few of these staff had ever 

deployed to an incident and were not registered 

in the qualifi cations database or supported by 

USFWS resource ordering and status system. Very 

few of the 1,761 responders had any experience 

responding to a spill, and most had not previously 

been trained regarding spill response generally, or 

their role in the spill response.

The National Park Service relied on a mix of fulltime, part-time, seasonal, emergency hires, retirees, 

and term appointments to meet the demands for 

NPS’ expertise. Some emergency hires and term 

appointments exceeded 120 days. The DOI Offi ce 

of Environmental Policy and Compliance had to 

borrow personnel from other agencies within DOI 

to meet requests for its staff; this was the largest 

ever deployment of DOI Offi ce of Environmental 

Policy and Compliance personnel for a response. 

The DOI Offi ce of Occupational Health and Safety 

and BOEMRE struggled to fi nd suffi cient personnel with the necessary skills to assist in response 

efforts and had to rely on multiple deployments 

of some personnel.

VENICE, La. - A U.S. Fish 

and Wildlife Service 

Southeast Louisiana 

regional supervisor 

operates a boat in the 

Delta National Wildlife 

Refuge in search of 

workboats removing 

boom from the marshes. 

Photo courtesy of U.S. 

Coast Guard
186

9. Government Personnel

9.9 Training

The Deepwater Horizon response tested the limits of personnel preparedness and training. As the 

response grew, particularly after the requirement 

to triple personnel, identifi cation of people with 

the right set of skills and competencies for positions within the response organization became very 

diffi cult. The size of the organization precluded 

screening and selection of all personnel based on 

their qualifi cations. This was a continuing concern.

To address this 

challenge, a Justin-Time-Training 

(JITT) center was 

established at 

Coast Guard Base 

New Orleans and 

at the UAC. This 

allowed agencies 

to surge personnel 

with a basic level 

of training within 

a required competency to the JITT 

center to receive 

the higher level of training needed to meet mission 

demands. JITT proved effective in training more 

than 2,077 responders through the center. However, 

the time members spent training for their positions 

reduced the amount of the time they were available 

for response duties. The UAC retained ICS experts 

who provided basic ICS training, position-specifi c 

training, and acted as coaches at all levels of the 

response organization to enhance responder function within the Incident Command System.

Issues of training and qualifi cations for a response 

the size and duration of the Deepwater Horizon 

spill were not limited to the Coast Guard. As a 

representative example, sourcing trained personnel to the response was also a challenge for 

the USFWS. During the fi rst few weeks of the 

response, USFWS identifi ed that trained personnel were a critical resource. The USFWS National 

Conservation Training Center in Shepherdstown, 

W. Va., was employed, dispatching a team to ICP 

Houma where they conducted a training needs 

assessment. The needs assessment showed that the 

greatest demand was for Hazardous Waste Operations and Emergency Response (HAZWOPER) 

Training and Orientation Training. Within a week, 

the training center opened a Pre-Deployment 

Training Academy near ICP Houma that delivered on-site training to USFWS and other agency 

responders. Deploying personnel were assessed 

during check-in at ICP Houma and if they did not 

have the required training, they were sent to the 

Academy for four hours of Orientation Training 

and up to two days of HAZWOPER training. A 

duplicate Pre-Deployment Training Academy was 

established near Mobile a week after the Houma 

training was stabilized.

Simultaneously, National Conservation Training 

Center staff in Shepherdstown, W. Va., arranged 

hazardous material training for Internet delivery. 

Once the Internet training was launched, deploying personnel received the majority of their spill 

response training before arriving on scene. However, orientation to ICP Houma operations and ICP 

Mobile operations continued for months and the 

training staff from National Conservation Training Center worked on improved job aids and met 

new training needs as they arose (bird identifi cation, bird handling, Resource Advisor training). By 

mid-September 2010, all training was converted to 

Internet delivery and the training staff was released 

from the response. The National Conservation 

Training Center website is still operational for 

staff deploying to the Gulf.

The National Park Service required similar JITT 

efforts. They were able to make use of the National 

Conservation Training Center incident specifi c 

Web site for deployed DOI staff to acquire required 

training. Many NPS, U.S. Geological Survey, 

and other DOI fi eld personnel had to receive 

BAYOU LA BATRE, La. – 

Petty offi cers work with 

a civilian boat crew to 

deploy an oil skimmer 

during a training exercise 

aboard a converted 

commercial shrimping 

vessel. The Coast Guard 

Reserve members work 

with Coast Guard active 

duty members to train 

civilian boat crews 

to set up and deploy 

Coast Guard skimming 

equipment on Vessels 

of Opportunity. Photo 

courtesy of U.S. Coast 

Guard

VENICE, La. – A geographic information systems coordinator 

with the U.S. Fish and Wildlife Service discusses communication 

methods with an airboat operator in South Pass, La. The U.S. 

Fish and Wildlife Service provided on-the-ground intelligence 

on oil sightings and cleanup methods to the Unifi ed Area 

Command. Photo courtesy of U.S. Coast Guard
9. Government Personnel

187

HAZWOPER training. BOEMRE required a number of employees to receive aviation safety training for their roles in the response, and BOEMRE 

arranged for a number of their deployed personnel 

to receive basic ICS training as they deployed.

In general, personnel mobilization across the federal government to support the Deepwater Horizon 

response was successful. The Coast Guard mobilized 14 percent of its total workforce, establishing 

the equivalent in personnel numbers of an Area 

command, two District commands, and several 

Sectors. In total, over 7,750 Coast Guard personnel 

mobilized to support Deepwater Horizon operations in theater. Of those, the breakdown by source 

was 53 percent active duty, 44 percent Reserve, 

and three percent civilian personnel. The volunteer based Coast Guard Auxiliary contributed an 

additional 147 personnel. While each phase of 

the response had unique challenges for personnel 

managers, several common themes were observable. Other agencies were similarly able to fi nd a 

way to sustain participation in the response effort. 

The USFWS deployed an even greater percentage 

of its workforce—seventeen percent. All agencies that played a signifi cant role in the response, 

particularly those trustee agencies that frequently 

respond to large spills, experienced diffi culty 

sustaining the number of personnel required to 

oversee the response operations over the many 

months required. On July 7, 2010, the number of 

response personnel reached its pinnacle of 47,849 

responders. Figure 9.6 provides a representation of 

the responders by agency and by geographic location at the point in the response when the highest 

number of personnel were assigned.

 State Key Location RP USCG National 

Guard Contractor Other Total Totals 

 LA 1 UAC - New 

Orleans 63 165 4 122 89 443 19,488 

2 ICP - Houma 95 191 6 653 213 1,158 

3 Field 146 795 941 14,959 1,046 17,887 

 AL 5 ICP - Mobile 91 273 9 662 216 1,251 9,308 

6 Field 20 269 374 7,350 44 8,057 

 MS 4 Field/Branch 6 31 146 7,008 57 7,248 7,248 

 FL 7 ICP - Miami 9 40 2 33 24 108 8,944 

8 Field 5 35 97 8,629 24 8,790 

9 Tyndall AFB - - 46 - - 46 

 TX 10 ICP - Houston 265 5 - 220 22 512 512 

 Off shore 11 Off shore 23 556 - 1,734 36 2,349 2,349 

 Total 723 2,360 1,625 41,370 1,771 47,849 47,849 

RIVERA BEACH, Fla. – 

A geologist provides 

training for federal, state, 

and county personnel on 

methods of identifying 

and documenting oil 

along various shoreline 

types. Photo courtesy of 

U.S. Coast Guard
188

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10. Communications

189

10.1 Information Management

During the Deepwater Horizon response, 

strategic decision making depended upon 

accurate, timely, and relevant information. 

The response required coordination and information sharing across many federal, state, and local 

governments, the Responsible Party (RP), and 

response organizations.

Natural barriers to synchronized, holistic information management included the vast geography of 

the response area of operation, the lack of appropriate interoperable communications technology, the 

limited ability to push real-time data both vertically 

and laterally throughout the response organization, 

and differing computing standards. These barriers 

and others were overcome through the application 

of advances to communications and organizational 

changes.

Application of Advances to Communications 

to Support Information Management—

Development of a Common Operating 

Picture

During the early stages of the Deepwater Horizon

response, the development of a Common Operating 

Picture (COP) became critical to provide full situational awareness. At the beginning of the operation, 

a series of maps prepared by a contractor was the 

source for situational awareness at the Unifi ed Area 

Command (UAC). The response organization soon 

outgrew that process.

At the Incident Command Post (ICP) level, a variety of systems maintained operational awareness. 

Different RP contractors used different proprietary 

systems to track the developing situation—there 

was one system at the UAC, one at ICP Houma, 

u

s

a D

Th

JEFFERSON PARISH, 

La. – The U.S. Coast 

Guard Commandant, 

Admiral Robert Papp, 

gives an interview to 

local a news station 

during his visit to 

the Deepwater 

Horizon response in 

Grand Isle, La. Photo 

courtesy of U.S. Coast 

Guard 

NEW ORLEANS, La. – Admiral Thad Allen provides a briefi ng to the 

Unifi ed Area Command in New Orleans. Photo courtesy of U.S. Coast 

Guard 

and another at ICP Mobile. National Oceanic and 

Atmospheric Administration (NOAA) employed 

Environmental Response Management Application 

(ERMA) as a situational awareness tool, at fi rst for 

NOAA use, at the UAC in Robert, La. and ICPs in 

Houma, La., and Mobile, Ala. NOAA also established a secure File Transfer Protocol (FTP) site to 

provide data management and fi le sharing for all 

parties and platforms. Initially, neither the National 

Incident Commander nor the underway Coast Guard 

cutters had access to this real time operational data.

On June 5, 2010, the National Incident Commander 

determined ERMA would be the backbone of a 

response-wide COP. Developed through a partnership between NOAA and the University of New 

Hampshire’s Coastal Response Research Center, 

ERMA is a Web-based Geographic Information 

System (GIS) tool designed to assist emergency 

responders and environmental resource managers 

with environmental incidents. ERMA synthesized 

and integrated various forms of information and 

provided a common operational picture of the oil 

spill situation and trajectory, among other data representations, for the incident. It also improved communication and coordination among responders and 

stakeholders, and provided resource managers with 

the information necessary to make faster and betterinformed decisions. The application was used in the 

March 2010 Spill of National Signifi cance (SONS) 

exercise. NOAA established the Gulf of Mexico 

Exercise (GOMEX) ERMA in less than two days at 

the end of April, and had on-site staff in UAC Robert 

and ICP Houma to start posting response data.
190

10. Communications

ERMA assisted the responders and environmental 

resource managers in a variety of ways. It provided a centralized system for the stakeholders’ 

data storage, manipulation, and information sharing 

requirements. Furthermore, it provided a secure 

upload and download capability for plotting new 

data on customized maps. These specialized maps 

could display a variety of existing data, including 

Environmental Sensitivity Index shoreline classifi cations, spill response plans and resources, contaminant data sets, regulated facilities, baseline 

resource data (including resources at risk), and restoration projects. The maps had the capability to 

display real-time data on blue force locator, weather 

forecasts, and tidal information from observation 

buoys. The system allowed computer uploading 

and access to data such as fi eld surveys, over fl ight 

information, satellite imagery, and hi-resolution 

photogrammetry on incident command areas.

ERMA, as enhanced during the Deepwater Horizon 

spill, was an information sharing tool. It improved 

communication and coordination among responders and stakeholders and identifi ed inconsistencies with data across state lines. This highlighted 

the need for standardized products such as operational divisions, symbology for Shoreline Cleanup 

Assessment Technique (SCAT) team survey results, 

over fl ight oil observation waypoints, and vessel tracking. It allowed functional user interface 

through the ability to choose a desired base map 

view such as NOAA navigational charts, raster 

images, or aerial photography. It also afforded a 

central location for stakeholders to access links to 

documents, such as spatially referenced photos, 

area contingency plans, and site survey results.

The ERMA tool also presented current federal and 

state information on seafood safety and fi sheries 

closure areas. Command staff, responders, and 

stakeholders were able to request added functionality as needed. Requests included fi nd bar function, 

enhancements to Automatic Identifi cation System 

(AIS) displays, animations, and slide shows. It was 

also capable of accepting and managing non-standard data formats. ERMA was fi rst used in a UAC 

briefi ng on June 14, 2010. It generated the ability to 

see real-time information regarding response assets, 

spill trajectory, and environmental conditions.

An added benefi t of ERMA was the ability to generate awareness of the response via the public face 

of ERMA, www.geoplatform.gov/gulfresponse. 

This site represented the response effort and presented updates to a range of groups affected by the 

spill. While access to the full ERMA functionality 

was restricted, the public could access a similar 

version with a subset of the response layers and 

functionality. Agencies touted the public version of 

ERMA as a central access point for detailed, nearreal-time information about the response. While 

publically announcing the introduction of ERMA, 

the Under Secretary of Commerce for Oceans and 

Atmosphere and NOAA Administrator stated:

“This website provides users with an expansive, 

yet detailed geographic picture of what’s going on 

with the spill; Gulf Coast fi sherman, recreational 

boaters, beach users, and birders will be able to 

become more informed. It’s a common operational 

picture that allows the American people to see 

how their government is responding to the crisis.” 

Within 48 hours of its inception, the website 

received 3.4 million visits. The Government 

Accountability Offi ce proclaimed the use of ERMA 

to be a best practice for government transparency.

Because of the number of vessels involved, vessel 

tracking became an important facet of the response 

effort, and resulted in a challenge to create a display of vessels supporting the spill and their corresponding functions. ERMA had the ability to receive 

AIS track, which identifi es the position of nearby 

vessels, but it proved a challenge to identify the 

vessels supporting the response fi ltered from all 

other vessels in the region. Ultimately vessels were 

tracked through the creation of a database that could 

house and cross reference Maritime Mobile Service 

Identity numbers and associated vessel names with 

their performed function. Functions included skimming, government, research, support, or Vessels of 

Opportunity (VOO) operations. The Coast Guard 

manually updated the vessel database throughout 

the response as vessels reported and departed.

The National Incident Commander authorized the 

posting of real-time AIS data for response vessels 

in ERMA. Initial security concerns for posting this 

information were outweighed by the need for public awareness of response assets’ real-time positions. There was a related issue regarding cutters, 

and particularly patrol boats, which transferred to 

the response for one-week periods. The problem 

arose when these vessels were not immediately 

removed from the database once they resumed law 

enforcement operations outside of the Deepwater 
10. Communications

191

Horizon response. The Coast Guard and NOAA 

worked diligently to update information on the 

patrol boats.

Not all response vessels were initially AIS equipped 

because they did not meet the carriage requirements. 

Notable exceptions were contract sentry vessels 

deployed north of the Florida Keys near the Loop 

Current, some Vessels of Opportunity Skimming 

System (VOSS)-equipped workboats, and the 

majority of the VOO. There were concerns that 

supplying every vessel, particularly thousands of 

VOO, with either Class-A or Class-B AIS transmitters would overwhelm the Nationwide Automatic 

Identifi cation System (NAIS). Policy was implemented to ensure that all major response vessels, 

as well as VOO lead vessels, were equipped with 

a tracking ability and displayed in ERMA using 

commercial product transmitters.

Misinterpretation of data became another concern 

for the COP. Due to the nature of some layers in 

ERMA, it became easy to misinterpret data without 

the benefi t of a technical advisor. For example, a 

common misperception was that the National Environmental Satellite, Data, and Information Service 

Anomaly Analysis displayed the actual extent of 

the oil slick—it did not. It showed analysis of the 

total area in which data indicated slicks could be 

expected to be found, but did not indicate oil covered the area displayed; actual slick coverage was 

a small percentage of the surface displayed by the 

Anomaly Analysis. In this case, the science and 

technology behind the display could easily be lost 

on the viewers, fostering misinformation. This reality underscored the value of the NOAA Scientifi c 

Support Coordinator (SSC) and the ERMA team’s 

on-scene presence to provide interpretation of 

remote sensing data and explanation of the scientifi c data. Furthermore, ERMA’s ability to provide 

direct access to metadata gave context to both the 

advanced and novice users of the response data in 

ERMA.

ERMA has a tremendous capacity to display a wide 

variety of data and to have these data entered from 

multiple locations and time zones. However, one 

of the early limitations to data management and 

coordination among the GIS groups was the ability 

to create and store timely compatible data fi les to 

facilitate real-time decision-making. This required 

a robust staff of GIS specialists at each layer of 

the response, to include SCAT teams on the beach 

inputting photos of oil impacts and making them 

available to the UAC, and decision makers in a 

timely fashion.

VENICE, La. – A 

reconnaissance data 

gatherer inputs GPS 

data into a spread sheet 

while conducting a daily 

mission. Reconnaissance 

missions are done twice 

daily to record sightings 

of oil fi ndings from the 

Deepwater Horizon spill. 

Photo courtesy of U.S. Air 

Force. 
192

10. Communications

Those generating data included federal, state, 

and local government agencies, as well as the RP 

and its supporting contractors. The Federal OnScene Coordinator (FOSC) swiftly generated large 

amounts of information from these disparate data 

sources to meet specifi c and often unique requirements. The overall understanding of the digital 

delivery of these data varied between data sets as 

well. Unfortunately, the metadata behind some of 

these datasets were incomplete due to the immediacy of the response requirements. As a result, 

it proved challenging to evaluate, leverage, and 

manage the numerous datasets generated in support of this response.

An additional challenge to utilizing ERMA was its 

incompatibility with some Coast Guard computers. At the time of the response, ERMA required a 

specifi c type of Internet browser to operate. Many 

Coast Guard computers, including all carried on 

the supporting cutters, had an older standard image, 

which did not support the ERMA requirement. 

At the back end of ERMA, the versions of the 

layering and mapping functionalities also caused 

incompatibility issues. This was outside of the 

Coast Guard’s control. Furthermore, Coast Guard 

Information Technology policies prohibited the 

installation of alternative browsers or programs. 

To address this, each ship received newer laptops 

with updated systems, in order to provide supporting cutters, such as the medium endurance cutters 

and sea going buoy tenders, with the COP.

Responders had additional concerns in making 

the website public, including the original server 

capacity and preserving the responder ERMA site. 

The responder site remained at the University of 

New Hampshire, and only malfunctioned once due 

to a power failure from a lightning strike. ERMA 

was down for only a few hours, and the new server 

moved to a different building. NOAA secured a 

robust infrastructure for the public ERMA site, 

and replicated the ERMA database several times 

to balance the volume of visits to the site. This 

infrastructure is part of NOAA’s Web Operations 

Center (WOC).

For the Deepwater Horizon response, there was no 

previous ERMA coverage, and NOAA established 

ERMA in less than two days. There are ERMA 

regional products currently in New England, the 

U.S. Caribbean, Puget Sound, the U.S. Arctic, and 

the U.S. Pacifi c Islands. NOAA is working toward 

national coverage, but should another spill occur, 

NOAA could quickly create a COP with ERMA.

Organizational Changes to Support 

Information Management

Information management also entailed tracking resources and responding to Requests for 

Information (RFIs) using near real-time reports 

created from the authoritative repositories that 

contained the actual data entered about the plans, 

activities, and outcomes by the fi eld-level response 

organization.

The Incident Command System (ICS) structure 

prescribes standardized information reporting 

timelines, forms, and procedures. Under the ICS 

construct, the ICPs transmit information to the 

UAC for compilation. The UAC then routes the 

consolidated information to the National Incident 

Command (NIC) for distribution and response to 

information requests. Situation Units at each level 

of the response organization are the focal points 

for operational information.

In the fi rst six weeks of the response, the volume, 

type, and frequency of data requested taxed the situation units at every level. The internal and external 

demand for immediate spill response information 

often caused a departure from the ICS information 

protocols. For example, requests for information 

regarding boom placement in a particular state 

might often be routed from the NIC level directly 

to the ICP level. The NIC received information 

from the ICP that was not yet reviewed by the 

UAC to determine whether it was the most current 

DAUPHIN ISLAND, Ala. – 

A Coast Guard petty 

offi cer works with a 

Vessel of Opportunity 

operator from Bayou 

La Batre, Ala., to log 

data collected with subsurface oil surveillance 

gear near Dauphin 

Island in the southwest 

corner of Mobile Bay, 

Ala. Photo courtesy of 

U.S. Coast Guard 
10. Communications

193

information available. 

S t a t e e m e r g e n c y 

responders reported 

information obtained at 

ICPs and Branches to 

other parts of their state 

government. Depending on who was asked, 

when the question was 

asked, and which part of 

the command structure 

prepared the response, 

different reports of what 

appeared to be similar 

types of data were generated. Also, states, counties, and parishes were 

interested in information segregated by political subdivisions, not by ICP or Branch, the way 

the ICS structure initially tracked resources. The 

differing numbers and answers provided without 

prior vetting and the lack of immediately available 

requested data for offi cials led to perceptions that 

the response organization did not know what was 

happening.

To resolve this issue and provide accurate and 

timely information, the response organization 

established a separate dedicated unit, entitled the 

Information Reporting Unit. This unit, staffed by 

senior Coast Guard offi cers, became the central 

conduit for information management. As the scope 

of the situation escalated, consultants were brought 

in, including contract support and a team from 

Coast Guard Headquarters.

The comprehensive Incident Action Plans (IAPs) 

produced by each ICP proved unwieldy for reporting response status. Overall, a need for standardized enterprise metrics in a simplifi ed, concise 

reporting format became readily apparent. It took 

time for the ICPs to come to a consensus on how 

to measure the same things, the same way.

The response organization overcame this challenge 

by developing a defi nition of metric calculations 

and units of measure. The Coast Guard identifi ed 

best practice measures for gathering, validating, 

and fi nalizing data, and for reporting and establishing tracking teams to tag assets based on common 

categories. The UAC directed information fl ow 

through one central collection point and developed 

procedures for collection, distribution, assignment, 

tracking, and resolution of requests. The FOSC conducted regular briefi ngs of the National Response 

Team and then the U.S. Department of Homeland 

Security (DHS), and published periodic reports 

using this standard template.

The response organization also developed systems 

to facilitate information sharing across the broad 

geography of the Deepwater Horizon response. NIC 

Staff, UAC, and ICPs used the Homeland Security 

Information Network to post unclassifi ed yet sensitive information, such as operations plans and offi -

cial correspondence. Responders also utilized the 

SharePoint system, set up by the RP, which allowed 

for version control over important documents. However, the use of the RP SharePoint site required a 

process to duplicate data on government systems.

10.2 Interaction with Federal and State 

Offi cials, and Congressional Aff airs

Because of the size and scope of the Deepwater 

Horizon response, many networks and processes 

were involved in facilitating cooperation between 

the federal government, states, and impacted local 

communities. Intergovernmental collaboration was 

key to the effective execution of the Deepwater 

Horizon response effort.

The NIC Legislative and Intergovernmental Affairs 

Branch coordinated responses to all matters of 

offi cial inquiries regarding response operations, 

including informal questions and answers (Q&As) 

passed through congressional affairs staff, offi cial 

correspondence from elected offi cials, briefi ngs 

MOBILE, Ala. – Retired 

Admiral Thad Allen, National 

Incident Commander for 

the Deepwater Horizon

response, briefs the crew 

at Incident Command Post 

Mobile. Photo courtesy of 

U.S. Coast Guard 
194

10. Communications

of congressional staff, and prepared senior Coast 

Guard offi cials prior to formal testimony before 

Congress and its committees.

To respond to informal requests for information 

from members of Congress and the Congressional 

Research Service (CRS), the NIC utilized the Coast 

Guard Resource Directorate’s pre-existing internal 

process of Q&As. The Coast Guard utilized the 

Q&As to track inquiries from members of Congress, CRS, the Offi ce of Management and Budget, 

and various Department of Homeland Security 

(DHS) offi ces. The existing process required only 

minor changes to incorporate the review by personnel from the NIC, DHS, and the White House. 

During the period of April 20 through August 31, 

2010, 1,064 Q&As were drafted and delivered. Of 

these, 656, or 62 percent, were directly related to 

the Deepwater Horizon response. In addition to 

the Q&A responses, the Coast Guard senior personnel participated in 17 hearings in Washington, 

DC and in the fi eld, and provided 10 briefi ngs in 

Washington, DC.

From the onset of the Deepwater Horizon spill, 

the governors of all affected Gulf States were 

intimately involved in the response efforts. To 

provide the governors of Alabama, Florida, Louisiana, Mississippi, and Texas with the most current 

information on response efforts, the White House 

staff instituted and moderated a daily conference 

call. During these calls, the NIC, FOSC, Incident 

Commanders from the Incident Command Posts, 

and other federal agencies briefed the governors 

of affected states and the White House staff.

The daily conference call was not only to impart 

information, but also to provide the governors with 

a venue to ask questions, communicate concerns, 

and share their priorities and assessments of the 

response. In return, their candid feedback allowed 

the FOSC to adjust priorities, focus efforts, and 

tailor response strategies with each state. This 

forum became an important medium that infl uenced tactical decisions and shifts in strategy such 

as boom deployment, skimming equipment allocations, and other protection and removal actions 

such as the sand berms. Additionally, the daily 

operations statistics and policy papers prepared 

for this call were widely disseminated throughout 

the response structure as well as through the interagency group. The papers provided responders and 

departmental leaders information that facilitated 

a unifi ed approach among the NIC, FOSC, and 

responders in the fi eld. The daily conference call 

also allowed the governors to discuss many social 

and economic issues, such as seafood testing to 

promote consumer confi dence in Gulf seafood, as 

well as to share the behavioral and mental health 

concerns of their affected constituents with the 

federal government.

The UAC developed systems to keep state and 

local offi cials informed. To ensure governors had 

immediate access to the response efforts, the Incident Commander for ICP Mobile assigned senior 

offi cers as Deputy Incident Commanders in Alabama, Florida, and Mississippi. In Louisiana, the 

Incident Commander and FOSC were in state, and 

they interacted with the Governor and his staff 

through a dedicated liaison offi cer and in person. 

This step made unity of effort and information 

sharing easier, to leverage these relationships and 

ensure the response organization was meeting the 

needs of the public. Each Deputy Incident Commander focused on states’ critical resource allocation, as well as state response activities, and 

served as the communications bridge between their 

state and the ICP. The Incident Commander then 

ensured the FOSC knew of those concerns.

The Government Affairs team developed out of 

the UAC in New Orleans, La. and through DHS 

Offi ces of Intergovernmental Affairs and Legislative Affairs. The Government Affairs staff in 

the UAC and ICPs helped answer questions from 

state and federal elected offi cials, arrange tours, 

over fl ights, and coordinate subject matter experts 

for daily or tri-weekly calls with state, local, and 

federal offi cials. They also ensured state, local, and 

Tribal partners had the opportunity to provide input 

GRAND ISLE, La – The 

entire process of beach 

cleaning is explained 

to members of the 

Senate staff from the 

Committee for Science, 

Technology, and 

Commerce. Photo 

courtesy of U.S. Coast 

Guard
10. Communications

195

into UAC operations. The Government Affairs 

team established local government hotlines in Robert, La., Houma, La., and Mobile, Ala. The daily 

calls provided participants with key information and 

contact information, as well as a daily update. The 

daily Government Affairs update helped distribute 

the claims and information hotline number Gulfwide. The distribution list for the daily update grew 

from approximately 40 contacts at the end of April 

2010 to more than 760 by the end of June 2010. 

The list expanded as other agencies, such as the 

Environmental Protection Agency, U.S. Department 

of Interior, and NOAA, which shared information 

on their outreach efforts. Government Affairs also 

coordinated with the Joint Information Center (JIC) 

to develop outreach materials for intergovernmental 

partners.

To address further local concerns, Federal Emergency Management Agency (FEMA) deployed 

Government Relations Teams to resolve immediate 

questions from local community-based organizations and businesses. The Government Relations 

Teams consisted of approximately 80 FEMA 

staff members, operating as DHS personnel. This 

included two outreach specialists in each affected 

county or parish (with the exception of Alabama), 

a government relations leader in each ICP, and 

support staff throughout the coastal region. The 

Government Relations Teams provided local groups 

and businesses with the latest information on the 

claims process and the overall response effort.

After the well was capped, the number of government affairs personnel decreased commensurate 

with the workload. A government affairs lead 

remained in the UAC and the ICPs to help distribute information to state and local partners. They 

also coordinated elected offi cial and congressional 

delegations.

10.3 Interaction with Local Government

To ensure the highest level of coordination, the 

National Incident Commander created formal liaison offi cer positions throughout the Deepwater 

Horizon response organization. These positions 

were fi lled by dedicated Coast Guard offi cers and 

were found at many levels within the state organizations. CGLOs (Coast Guard Liaison Offi cers) 

were assigned to work closely with state and local 

offi cials in Louisiana, Mississippi, Alabama, and 

Florida, specifi cally to handle emergent needs and 

provide direct access to the response for local offi -

cials. The ultimate goal of the liaison program was 

to capture the concerns of state and local leaders, 

VENICE, La – Admiral 

Thad Allen speaks 

during a conference call 

at Coast Guard Station 

Venice. Admiral Allen 

received input from local, 

state, and other federal 

offi cials concerning 

the uncontrolled oil 

discharge into the Gulf of 

Mexico. Photo courtesy 

of U.S. Coast Guard 
196

10. Communications

and resolve issues in the most effi cient way, and at 

the most localized level possible.

Soon after the Deepwater Horizon oil platform 

sank on April 22, 2010, the state of Florida proactively established and staffed an Emergency 

Operations Center (EOC) function for the incident at its facility in Tallahassee, Fla. Coast Guard 

offi cers from the Seventh Coast Guard District 

acted as liaisons to the Florida EOC. The Florida 

EOC continued to operate throughout the response.

ICP Houma established a formal Liaison Offi cer 

function under the Command Staff in accordance 

with the ICS; however, the RP initially staffed 

this function. The liaison group focused on community relations and not on traditional liaison 

role of intergovernmental communication and 

coordination. Soon after its establishment, ICP 

Mobile also founded a liaison function for community relations. The UAC assigned a Liaison 

Offi cer to the Governor of Louisiana. The UAC 

also formed a small liaison staff that coordinated 

reports. While this served the community relations goals of the RP and the response, it did not 

provide state and local emergency management 

and elected offi cials with the federal presence they 

wanted to ensure a coordinated, unifi ed response. 

Further, this structure did not adequately apprise 

national-level leadership of developing issues in 

Gulf Coast communities.

In response to this organizational gap, on May 

27, 2010, senior offi cials directed the assignment 

of Parish President Liaison Offi cers (PPLOs) for 

the Deepwater Horizon response in the coastal 

parishes of the Louisiana under ICP Houma. 

Soon after, the program was extended to the 

coastal counties of the states of Alabama, Florida 

(Panhandle counties only), and to Mississippi as 

County Liaison Offi cers and State Liaison Offi -

cers under ICP Mobile. Up until late June 2010, 

Coast Guard Sectors on the west coast of Florida 

peninsula provided information on the potential 

impact and response operations to local offi cials. 

The Coast Guard Seventh District offi ce managed 

outreach to congressional members for Florida.

In late June 2010, and in anticipation of potential 

oil spill impact in these areas, Coast Guard Liaison 

Offi cers assigned under the Florida Peninsula Command Post (FPCP), initially located in St. Petersburg 

but eventually established as ICP Miami, began 

to work with local elected offi cials from the west 

coast of Florida In addition, the CGLOs engaged 

representatives from the Chamber of Commerce and 

tourism boards, as well as the commercial shipping, 

fi shing, and cruise line industries.

On July 9, 2010, the UAC assigned an offi cer to 

coordinate the reporting of CGLOs across all three 

ICPs—Houma, Mobile, the Florida Peninsula—and 

the Louisiana Governor’s offi ce. After the oil well 

was capped in mid-July, the UAC directed a gradual 

demobilization and consolidation of CGLOs as the 

requirement for liaisons diminished over the next 

few months.

The RP also established liaisons whose primary 

focus was providing information on the claims 

process and helping local businesses and private 

citizens submit claims. They also managed the 

involvement of local and regional volunteer organizations in the response, as well as the process for 

local businesses and private citizens to participate 

in the VOO program.

The primary responsibility of the CGLOs was 

to relay information between the Incident Commanders at their respective ICPs, the state and local 

emergency response, and elected offi cials in their 

area of responsibility. CGLOs were a single point 

of contact for these offi cials to obtain information 

and understand the ICs’ operational plans, policies, 

and future intentions. They also relayed requests, 

concerns, and issues from state and local offi cials to 

the Incident Commander. Generally, PPLOs worked 

daily with their designated parish presidents, and 

were the ready source of information on response 

operations and the conduit for the offi cials to the 

Incident Commander. The County Liaison Offi cers 

and State Liaison Offi cers’ responsibilities entailed 

many individual and group visits with the offi cials, 

as well as daily operations briefi ngs in the EOCs. 

Secondarily, the CGLOs compiled and relayed a 

nightly report of developing local issues to the UAC 

and to the national level of the federal government.

The UAC encouraged stakeholders (including state 

and local offi cials, and other entities such as private 

citizens and local businesses) across the response 

theater to present ideas to improve the unifi ed 

response for consideration and potential implementation. CGLOs helped the stakeholders understand 

the process for submitting their ideas, monitored 

the proposals, and provided status updates to their 

proponents.
10. Communications

197

CGLOs fi led daily situation reports and internally 

briefed continuing and pressing issues throughout 

the response. These reports included top issues 

from state and local elected offi cials, details on 

how these issues were addressed, engagements 

with state and local offi cials, and potential future 

issues in the CGLOs’ areas of responsibility. Once 

the Mississippi Canyon 252 Macondo well was 

capped on July 15, 2010, the CGLOs incorporated 

recovery information in addition to information on 

response operations.

The ability of the liaison offi cers to act as effective conduits between response leaders and local 

offi cials depended on the seniority of the liaisons. 

Junior offi cers were replaced with more senior 

offi cers. Points of friction remained, however. 

Some liaison offi cers had to be replaced when their 

relationships with local offi cials broke down, usually over expressions of concern regarding spill 

response actions taken by local responders outside 

the incident command structure. A local offi cial 

threatened to arrest one liaison offi cer if the ICP 

removed any response equipment from his jurisdiction in advance of Tropical Storm Bonnie.

Ten senior Coast Guard active duty and Reserve 

offi cers staffed the PPLO positions in Louisiana. 

A staff of three to four offi cers at the ICP Houma 

oversaw and coordinated the program. In some 

cases, the PPLOs had Coast Guard junior offi cers 

or senior enlisted members to assist them. Senior 

Coast Guard offi cers staffed 13 County Liaison 

positions in the coastal counties of Alabama, Florida (panhandle counties only), and Mississippi. In 

addition, each of these counties had one or two 

county EOC representatives (a total of 15) who 

were more junior Coast Guard personnel.

At the peak of activity, ICP Mobile had a staff 

of fi ve offi cers who oversaw and coordinated the 

CGLO function across the three-state operational 

area. ICP Miami had approximately 10 personnel involved in the CGLO function, and the UAC 

had fi ve personnel. At the height of the response, 

the number of personnel involved in the CGLO 

function across the entire area of operation totaled 

approximately 70 offi cers distributed across 33 

state, county, and parish governments. After the oil 

well was capped July 15, the number of CGLOs 

began to decrease, commensurate with the scale 

of response operations.

PPLOs faced signifi cant information technology 

and connectivity challenges due to the remote 

nature of their operating areas in coastal Louisiana. 

Most had no consistent way to access the Internet, 

and those who had smart phones generally did not 

have suffi cient data plans or coverage. PPLOs’ 

effectiveness was sometimes constrained by their 

inability to send and receive timely and complete 

information via email. For example, dissemination of voluminous Incident Action Plans for ICP 

Houma was both technically and organizationally challenging. Response personnel, including 

PPLOs, were often unable to utilize or distribute 

large IAPs, hampering execution of a more centrally developed plan. Long travel distances from 

ICP Houma to fi eld destinations made paper copy 

delivery an especially arduous backup to electronic 

delivery.

Generally, the County Liaison Offi cers and State 

Liaison Offi cers in Alabama, Florida, and Mississippi did not experience the connectivity issues 

faced by the PPLOs in Louisiana. This was due 

primarily to the more robust communications 

infrastructure present in those states. Those states 

disseminated daily operations briefi ngs, maps of 

response resource placements, and other situational 

awareness information electronically each morning 

to the County Liaison Offi cers and State Liaison 

Offi cers. The county EOCs used these reports to 

conduct daily briefi ngs and provide timely information to state and local elected offi cials.

The CGLOs represented the Incident Commander 

and the federally led response at many public 

forums and gatherings of state and local elected 

offi cials. Prior to deployments to their individual 

assignments, CGLOs received briefi ngs on what 

they would generally encounter in the fi eld, along 

with an outline for standard presentations. However, they did not receive any formal training to 

prepare them for the often highly charged and 

politically nuanced activities they would experience. Quite often CGLOs encountered hostile 

and emotional situations that would have challenged even the most seasoned and fully trained. 

Due to varied backgrounds and experiences, some 

CGLOs were more successful in navigating these 

challenges.
198

10. Communications

10.4 Interaction with Aff ected 

Communities

The Deepwater Horizon incident attracted attention on many levels, including internationally, 

nationally, and locally.

Initially, the response organization addressed 

the local populace through town hall meetings 

to provide updates on actions taken directly by 

Incident Commanders. The meetings consisted 

of response representatives in front of the room in 

panel format, presenting information on stage to 

a seated public audience. These meetings proved 

ineffective at communicating information about 

the response to the local citizens who attended. 

The format was revised and an exposition style 

event was adopted. In this presentation style, citizens could converse one-on-one with experts at 

booths and tables confi gured around the room, 

each devoted to a particular topic of the response. 

Topics included use of dispersants, in situ burning, skimming, booming, health and safety, the 

VOO program, alternative response technologies, 

employment opportunities, claims, and many others. This format proved more benefi cial and constructive than the town hall forums.

Broader based community outreach meetings 

eventually evolved to an open house meeting style 

as well, and likewise proved more benefi cial than 

town hall meetings. The open houses encouraged 

and enabled open dialogue between responders and 

community members. They allowed members of 

the response organization to tell their story directly 

to stakeholders. The open house featured multiple 

tables placed along the perimeter of a large space, 

each staffed with a subject matter expert to address 

particular response topics. Tables contained materials needed to convey information; visual displays 

of hardware, photos, and charts. The public was 

able to browse and visit each table. In the middle 

of the room, visitors could meet with more subject matter experts who could speak to broader 

response issues and answer more questions. This 

facilitated one-on-one dialogue about individual 

concerns. The UAC and ICP Houma held open 

houses extensively throughout the Gulf Coast. 

Every parish and county where response operations took place had at least one open house.

In addition to open house meetings, the UAC 

and ICPs identifi ed key stakeholders, non-governmental organizations, and community leaders 

and invited them into the ICPs. There, they had the 

opportunity to view all the planning and response 

activities.

The FOSC held several parish presidents meetings over the course of the Deepwater Horizon

response. These gatherings facilitated discussion 

on specifi c topics of greatest importance to local 

governments regarding the spill response and 

future institutions. While at times emotional, the 

meetings were well attended and created the necessary unity of effort to resolve a wide array of pollution response issues affecting the lives of those 

living and working in the impacted communities. 

The FOSC also regularly visited county and city 

offi cials in Alabama, Florida, and Mississippi.

BRAITHWAITE, La. – 

Capt. Meredith Austin, 

Deputy Incident 

Commander of the 

Houma Incident 

Command Post, part 

of the Deepwater 

Horizon oil spill 

response, answers a 

reporter’s questions 

during an open house 

at Phoenix High 

School in Plaquemines 

Parish. Photo courtesy 

of U.S. Coast Guard 

VENICE, La. – Venice community members voice concerns about the 

safety of seafood at a dockside chat in Venice. Several senior federal 

agency offi cials attended the meeting to promote safety of seafood. 

Photo courtesy of U.S. Coast Guard 
10. Communications

199

10.5 Strategic Communications

Situation and Actions

During the fi rst several days after the explosion of 

the Deepwater Horizon Mobile Offshore Drilling 

Unit, the FOSC relied upon the Eighth Coast Guard 

District Public Affairs Offi ce and BP Public Information Offi cers handled the initial media response 

by sending news releases, establishing an incident 

website, responding to media queries, arranging 

media over-fl ights, providing video and photos 

to the media, coordinating news interviews, and 

arranging and participating in news conferences.

Public Affairs Specialists were deployed to Houma, 

La., on April 21, 2010, in support of the incident, 

followed by the Public Information Assist Team 

(PIAT). A JIC was soon established at ICP Houma 

using the National Response Team/National Incident Management System JIC model prescribed in 

the National Contingency Plan (NCP).

Shortly thereafter, on April 23, 2010, the UAC was 

established in Robert, La., to oversee the multiple 

functions of the growing response. A JIC was established and the UAC became the primary interface for 

the media and external entities including intergovernmental and community relations. A Government 

Relations Offi cer (GRO) established relationships 

with local governments. Daily briefi ngs between 

the GRO and the media were scheduled, but did 

not always take place. The Coast Guard dispatched 

photographers and videographers to capture operations, town hall meetings, and dignitary visits. In its 

fi rst week, the JIC established media pools for overfl ights. The UAC JIC approved all corresponding 

releases and images for review, release, and posting. 

It also established a daily press brief with the UAC 

FOSC and the RP representative. 

As the spill and response continued, the number of 

personnel and resources dedicated to public affairs 

and intergovernmental affairs expanded signifi -

cantly; this included deployment of resources to support and staff media embeds on cutters and aircraft, 

media visits to staging areas and forward operating 

bases, and bolstering external affairs capabilities at 

the various ICPs. By early May 2010, a hybrid structure based on the National Response Framework’s 

ESF-15 model was established to place media, 

governmental, and congressional affairs under one 

entity, yet all the traditional functions of a National 

Response Team JIC remained in place.

The UAC External Affairs Section established a 

daily internal communication process to coordinate 

activities of the staff in Robert, La., the ICP JICs 

and fi eld external affairs entities. This included 

two daily meetings. The UAC external affairs 

staff morning meeting was used to gather information and coordinate the staff in Robert, La. In 

the evening, an additional meeting of the external 

affairs leadership the ICP JIC staffs (via conference call) was used to establish priorities, develop 

daily strategies, exchange information, and plan 

for the following day. This capability was bolstered 

as ICPs with JICs were staffed in Mobile, Ala., 

and the Florida Peninsula (Miami). These efforts 

were synchronized with national efforts via daily 

National Incident Communications Conference 

Line calls that included participating federal entities and interagency senior communicator calls.

In late May 2010, the NIC became a signifi cant 

interface for the national media, shifting daily 

press briefi ngs away from the UAC (FOSC). 

These briefi ngs where combined with conference 

calls to allow hundreds of outlets to participate; 

they then were transcribed, and the transcripts and 

audio fi les were posted to the incident website 

daily. The UAC External Affairs staff maintained 

frequent communications with the NIC Press 

Secretary, and continued daily coordination with 

Coast Guard Headquarters, DHS, and other federal Public Affairs staffs based in Washington, 

DC, via the senior communicator’s calls. While 

the National Incident Commander became the 

NEW ORLEANS, La. 

– Coast Guard petty 

offi cers fi eld media 

inquiries at the Unifi ed 

Area Command’s Joint 

Information Center. Both 

women work as part 

of an integrated team 

of civilian and military 

personnel who provide 

timely and accurate 

information about BP oil 

spill cleanup operations 

to the media and public. 

Photo courtesy of U.S. 

Coast Guard 
200

10. Communications

primary spokesperson for the response, the UAC 

JIC remained the central point of release for all 

entities including the NIC, UAC, and the FOSC.

In June 2010, FEMA assumed leadership and organization for the UAC New Orleans Community 

Relations Section, which augmented the efforts of 

the UAC External Affairs staff. This section provided foreign language assistance and experienced 

Public Information Offi cers to canvass the community. In addition, CGLOs were provided to local and 

state government offi cials to expedite the fl ow of 

information and enable effi cient communications 

between the federal-led response and local and state 

government offi cials.

By late June, the response included a robust force of 

experts for the demanding missions in public affairs, 

community relations, intergovernmental affairs, 

and congressional and tribal outreach. This talented 

force was assigned across four primary locations: 

the UAC, ICP Houma, ICP Mobile, and ICP Miami. 

They were also supported by the NIC staff and the 

Coast Guard Headquarters congressional and Public 

Affairs staffs of the participating federal agencies. 

Additionally, external affairs experts were employed 

in supporting media over fl ights, bolstering community outreach efforts, and enabling visits to the 

offshore source control operation and to cleanup 

and recovery operations onshore. At the height of 

the response in July 2010, there were approximately 

220 responders serving in the role of external affairs.

The Macondo well was successfully capped on 

July 15, 2010, stopping the infl ux of petroleum into 

the environment, and subsequently killed and permanently sealed over the subsequent two-month 

period. National media interest greatly declined 

once the well was no longer leaking, and continued 

to decline in the months afterward. In proportion, 

external affairs support at the ICPs and Branches 

decreased throughout the six months following 

including disestablishing ICPs, and consolidating their JIC functions and resources to UAC. In 

October 2010, the response website shifted from 

the www.deepwaterhorizonresponse.com response 

site to www.restorethegulf.gov restoration website. 

The shift to a .gov address in place of the .com 

address was made in part to ensure compliance 

with the 2004 OMB web guidelines on use of 

approved domains.

Resources Committed

During the course of incident response, 88—or 

80 percent of the active duty Coast Guard Public 

Affairs force—and 10—or 97 percent of the billeted Public Affairs Offi cers (PAOs)—deployed to 

the Deepwater Horizon response. Many of these 

personnel deployed multiple times from April 2010 

to January 2011. Multiple former Coast Guard 

PAOs also augmented this staff, and 90 percent 

of the enlisted Coast Guard PA Reserve force (23 

Reserve Public Affairs Specialists) deployed.

In addition, the FOSC relied heavily on PAOs 

from other agencies to serve on the UAC external 

affairs staff and in the fi eld at JICs and Branches. 

PAOs from all the participating agencies—NOAA, 

USFWS, EPA, and National Parks Service—as 

well as those from agencies not involved in the 

operational response—Department of Defense, 

Air National Guard, Federal Bureau of Investigations, Customs and Border Protection, Immigration 

and Customs Enforcement, Federal Emergency 

Management, Health and Human Services, U.S. 

Geological Survey, U.S. Marshals, U.S. Secret 

Service—were crucial to staffi ng external affairs 

functions. Many other agency PAOs were used 

in crucial roles where one agency’s PAOs did not 

possess the required governmental affairs or large 

response experience. In total, more than 300 interagency PAOs supported the response.

ST. PETERSBURG, Fla. – 

Members of the Joint 

Information Center at 

the Deepwater Horizon

Unifi ed Command in 

St. Petersburg, Fla., 

work to keep the 

public informed of 

the ongoing response 

eff orts. Photo courtesy 

of U.S. Coast Guard 
10. Communications

201

Challenges Encountered

The response culled all available talents and 

resources from the Coast Guard Public Affairs and 

external affairs communities—active duty, Reserve, 

civilian, auxiliary, and even Coast Guard retirees 

serving in other agencies. The effort validated the 

depth of training and commitment by all. The effort 

also revealed the fi nite pool of talent and resources 

for establishing, staffi ng, and maintaining the external affairs capabilities for a military-campaignscope response with international visibility. In 

all, the response produced a bevy of deliverables 

including press briefi ngs, on-camera interviews, 

town hall meetings, press releases, photo releases, 

video releases, and updates to the two websites, and 

multiple social media outlets. In addition, novel 

tactics were used to inform the public, including 

multi-day embarkations on a cutter at the well site, 

fi rst person immersion media embeds with fi eld 

teams, live media broadcasts from cutters offshore 

an airship conducting oil spill surveillance, routine 

press tours of animal treatment facilities, and realtime reporting from the drill ships during key well 

kill operations.

The response identifi ed a need for capabilities in 

public affairs positions, intergovernmental affairs 

positions, and community relations positions and a 

worst-case scenario for building the required capacity at these positions. This model can be wed to 

training and skill-honing opportunities. Specifi c 

emphasis should be given to commissioning a coding system for key skill sets of members expected to 

serve in future responses from among interagency 

partners represented in the NRT. The fi ne nuances 

of hosting VIPs, handling protocol for Presidential 

and other senior offi cial visits, fl uidly communicating with emotionally distraught members of a 

local community, adeptly addressing the needs and 

concerns of key demographics and ethnically distinct groups (especially Native Americans), and 

proactively engaging in dialogue for both local and 

national media should not be overlooked. These are 

critical skills that are learned and matured with real 

time practice and experience.

The adoption of a blended Natural Response Framework Emergency Support Function-15 and NCP JIC 

model for this response allowed for the alignment 

of outreach to governmental, congressional, media, 

and stakeholder audiences at all levels from local 

to national and international. It also allowed PAOs 

familiar with one or the other system to have a 

frame of reference to begin their support for the 

organization. However, it produced diffi culties for 

those who had trained and exercised over the years 

GULF OF MEXICO – 

National Incident 

Commander, Admiral 

Thad Allen (Ret.) is 

interviewed by a 

reporter for the New 

Yorker during a fl ight 

from Mobile, Ala., 

to New Orleans. The 

reporter embedded 

with the National 

Incident Command 

for two days. Photo 

courtesy of U.S. Coast 

Guard 
202

10. Communications

using solely the decentralized JIC model for spill 

response. As SONS doctrine is reviewed, these two 

models should be compared and doctrine updated 

to prescribe the best organization and process for 

future SONS. In addition, the two models should be 

harmonized for other types of responses where both 

will be used, such as a hurricane where a Stafford 

Act FEMA-led ESF structure is employed alongside the National Incident Management System 

JIC structures used by state and local emergency 

management entities, and Coast Guard incident 

response activities.

Having the JIC serve as the single, central point of 

contact for all inquiries, including national level 

policy issue questions, has the benefi t of creating 

great synergy and alignment in information but is 

also problematic. The incident-specifi c JIC staff 

was sometimes overwhelmed by a high volume 

of inquiries coupled with a broad base of interest—often exceeding the authority and subject 

matter expertise of the JIC staff. This resulted in 

unanswered calls, an irritable press corps working against deadline, countless opportunities for 

miscommunication and antagonistic interaction, 

and an overall perception of less-than-transparent 

media access and responsiveness. It can also result 

in the confusion of tactical, operational updates to 

be provided by fi eld Public Affairs entities, and strategic, government-wide, or agency specifi c issues 

to be provided by other agencies, departments, or 

national leaders. In future incidents, decisionmakers should consider the value and importance of 

a national-level, policy-focused JIC at the NIC 

working closely with the operational JIC to better 

respond to information requests and separate tactical from strategic issues. The relationship between 

the Multi-National Forces Iraq Operations Center 

and the Aerospace and Defense Public Affairs staff 

might be a useful model.

Finally, understanding that other federal agencies 

are a key resource pool for Public Affairs staff in 

an event of this magnitude (or even in more routine 

natural disasters), the NRT should advocate cultivating relationships, skills, and standardization of 

incident Public Affairs training. This should include 

JIC operations for other agencies’ PAOs. A more 

refi ned outcome could include a pool of reserve or 

stand-by federal Public Affairs staff members who 

are categorized by their skill sets, such as photographers, data researchers, news desk managers, fi eld 

specialists, across the federal government.

10.6 FOSC Key Points

The Need for a Common Information 

Reporting Template

The response demonstrated the need to capture 

accurately where critical resources were located, 

what was deployed, what was staged, and what 

activities had taken place. Incident Action Plans 

are not suitable in communicating the status of the 

response to those outside the incident command. 

This is particularly true the larger the response. 

Predetermined information reporting templates 

designed for executive use, along with established 

processes, standardized and readily explainable 

terms, reporting times, and protocols for information sharing are necessary. In any major spill, the 

ability immediately to report accurate information 

about response activities and resources is essential.

Common Operating Picture

NOAA’s ERMA was scalable and capable of 

performing as a COP. It is currently available 

and unclassifi ed. During the Deepwater Horizon 

response, it was modifi ed to make much of the 

data in the COP available to the public. Because 

of its success, ERMA should be adopted as the 

COP for oil spill response. The need for a COP is 

linked to the requirement for a common information reporting template—it is essential to be able to 

communicate adequately with offi cials, the public, 

and the media, as well as within the response, in 

a uniform manner.

External Aff airs

In order to meet the media demands of a large spill 

response, a robust external affairs staff, including 

one large enough and with the requisite skills to 

engage with social media, is necessary. Also, it is 

important to be able to maintain a consistent rhythm 

for media engagements. This includes communicating with the press daily, issuing press releases, 

managing embed opportunities, overfl ights, and 

interview opportunities. 
Appendix

203

Chronology

On April 20, 2010, at approximately 10 p.m. Central Standard Time (CST), an explosion occurred 

on the Deepwater Horizon oil drilling rig in the Gulf of Mexico, located at 28 degrees 45.23 

minutes north of the equator and 088 degrees 18.89 minutes west of the meridian, approximately 

42 miles southeast of Venice, La. There were 126 people on board at the time. Fifteen of those people 

were injured and 11 went missing. Commercial vessel operators and Coast Guard assets rescued 115 

crewmen and rig personnel. The Deepwater Horizon, owned by Transocean Ltd., was under a contract 

with Beyond Petroleum (BP) to drill an exploratory well. BP was the lessee of the area in which the 

rig was operating. At the time of the explosion, BP and Transocean were in the process of temporarily 

closing the well in anticipation of returning in the future for commercial production. Halliburton had 

completed some cementing of casings in the well less than 24 hours prior to the accident. The Coast 

Guard responded to the explosion and subsequent fi re, and President Obama was alerted to the unfolding events. The following is a timeline of events as they unfolded.

April 21, 2010 – DAY 2: Representatives from the Coast Guard, Department of Homeland Security 

(DHS), National Oceanic and Atmospheric Administration (NOAA), Department of the Interior (DOI), 

and the Environmental Protection Agency (EPA), as well as state and local representatives activate 

the Regional Response Team (RRT). The RRT begins developing plans, providing technical advice, 

accessing resources and equipment from its member agencies, and overseeing BP’s response. The 

modeling team at NOAA’s Offi ce of Response and Restoration begins generating daily trajectories for 

the Deepwater Horizon oil spill. Search efforts continue for the 11 missing rig workers.

April 22, 2010 – DAY 3: The Deepwater Horizon sinks into the Gulf of Mexico at 10:22 a.m. CST, 

containing upwards of 700,000 gallons of diesel fuel on board and taking with it the riser pipe that 

remained attached to the blow-out preventer (BOP). The riser pipe breaks as the Deepwater Horizon

sinks. The Coast Guard activates the National Response Team (NRT). Air and sea restriction zones are 

established at the response site for safety. Aircraft apply surface dispersants for the fi rst time.

April 23, 2010 – DAY 4: The Commandant of the Coast Guard signs a memorandum naming the Eighth 

District Commander, Rear Admiral Mary Landry, as the Federal On-Scene Coordinator (FOSC) for the 

Deepwater Horizon spill. The Coast Guard establishes the Unifi ed Area Command (UAC) in Robert, 

La., and creates a Unifi ed Command (UC), and an Incident Command Post (ICP) in Houma, La. A 

remotely operated vehicle (ROV) survey locates the sunken rig upside down, approximately 1,500 

feet northwest of the BOP. Oil sheen is reported, but no apparent leak is discovered. NOAA’s Offi ce 

of Response and Restoration begins conducting fl yovers and modeling the movement of the oil. At 5 

p.m. CST, the Coast Guard suspends the search and rescue efforts. An initial debrief of the surviving 

crew members places the 11 missing in the vicinity of the explosion.

April 24, 2010 – DAY 5: ROVs inspect the capsized rig on the sea fl oor and fi nd two oil leaks from 

the well pipe along the sea fl oor (at a depth of approximately 5,000 feet). The Coast Guard establishes 

the Joint Information Center in Robert, La., and an ICP in Houston, Texas.

April 25, 2010 – DAY 6: An attempt is made to activate the BOP rams with the sub-sea accumulator. 

BP activates a toll-free call center and opens two claims offi ces to process claims.

April 26, 2010 – DAY 7: The Louisiana governor issues an executive order that calls for the fl ags at 

all state buildings to be fl own at half-staff in honor the of oil rig explosion victims from this date until 

sunset May 3, 2010. An ICP is established in Mobile, Ala., at the Mobile Convention Center, reporting to the FOSC and handling operations in Alabama, Florida, and Mississippi. Responders attempt 

to activate the Variable Bore Ram and actuate shear rams on the BOP using ROVs. The Department 

of Energy (DOE) assembles a scientifi c oversight team under the direction of the Secretary of DOE to 

monitor the progress and critically review the Responsible Party’s (RP’s) efforts to contain and secure 

the source of the leak from the Macondo well.
204

Appendix

April 27, 2010 – DAY 8: The Secretary of DHS and the Secretary of the Department of the Interior 

(DOI) sign an order establishing the next steps for a joint investigation into the causes of the explosion. 

The joint investigation holds the power to issue subpoenas, hold public hearings, call witnesses, and 

take other steps needed to determine the cause of the incident. A controlled in situ burn test is conducted. The Operations Branch mobilizes near-shore protective resources to Breton Sound Island, La., 

to initiate the protective booming of sensitive areas. Protective booming is deployed at Pass a Loutre, 

La., (approximately 9,000 feet) and Pensacola, Fla. (approximately 2,500 feet).

April 28, 2010 – DAY 9: The Louisiana governor visits ICP Houma for a briefi ng on the oil spill and 

then joins Coast Guard and BP executives for a fl yover of the oil spill area in the Gulf. The Coast Guard 

and the National Pollution Funds Center (NPFC) designated BP a Responsible Party (RP) under the 

Oil Pollution Act of 1990 (OPA 90). Responders conduct the fi rst controlled in situ burn. An additional 

leak is discovered by a ROV. NOAA sampling for seafood safety begins.

April 29, 2010 – DAY 10: The Secretary of DHS declares the incident to be a Spill of National Signifi cance (SONS), enabling the appointment of a National Incident Commander to coordinate response 

resources at the national level. The governor of Louisiana declares a State of Emergency.

April 30, 2010 – DAY 11: The Secretary of the Department of Defense (DOD) mobilizes the Louisiana 

National Guard to assist local communities in the cleanup and removal of oil and to protect critical 

habitats from contamination. In a precautionary move, the Louisiana Department of Health and Hospitals, and the Louisiana Department of Wildlife and Fisheries announce the closure of select fi shing 

areas and oyster harvesting beds. The governors of Alabama, Florida, and Mississippi declare a State 

of Emergency. The RP initiates the fi rst test of new sub-sea dispersant techniques in accordance with 

required testing protocols with the approval of the FOSC and EPA, and with advice from NOAA. The 

RP dispenses 3,000 gallons sub-sea at rate of nine gallons per minute per the testing procedure. The 

test appears successful based on sonar data and ROV visual indications.

May 1, 2010 – DAY 12: The Secretary of DHS names Coast Guard Commandant Admiral Thad Allen 

the National Incident Commander. RP contacts scientists at the Woods Hole Oceanographic Institution 

about measuring the fl ow of oil from the BOP using a ROV with sonar and acoustic sensors.

Cumulative statistical snapshot:

Amount of oily liquid recovered: 20,313 barrels

Amount of surface dispersants applied: 156,012 gallons

Amount of sub-sea dispersants applied: 3,000 gallons

Amount of boom deployed: 420,280 feet

Total number of vessels: 231

Total number of skimmers: 98

Total wildlife impacts (includes birds): 1

Total number of responders (does not include Mobile, Ala.): 1,623

May 2, 2010 – DAY 13: Development Driller III (DD III) arrives at the Macondo well to drill the fi rst 

deep-water intercept relief well, located one-half mile from the Macondo well, in a water depth of 

roughly 5,000 feet. This relief well attempts to intercept the existing wellbore at approximately 16,000 

feet below the sea fl oor. The RP estimates this process to take at least 90 days. A second sub-sea dispersant injection test begins with approval to continue injection until Monday, May 3, with approved 

total volume of 13,000 gallons. The Alabama governor requests to utilize a state defi ned booming 

requirement instead of the current Area Contingency Plan. The FOSC approves this request. NOAA 

closes federal portions of the Gulf of Mexico to fi shing based on the trajectory of the spill.
Appendix

205

May 3, 2010 – DAY 14: Training begins for more than 2,000 volunteers to assist in the response effort. 

Volunteers include local fi shing crews, whose boats can be used as Vessels of Opportunity (VOO) to 

assist contractors in deploying boom.

May 4, 2010 – DAY 15: DOD approves the federal mobilization of up to 17,500 National Guard 

troops to help various states with the oil spill, assigning up to 3,000 personnel to Alabama, 2,500 to 

Florida, 6,000 to Louisiana, and 6,000 to Mississippi. The Louisiana Governor sends a letter to the 

U.S. Small Business Administration requesting that it issue an economic injury disaster declaration for 

six parishes in Louisiana: Jefferson, Lafourche, Orleans, Plaquemines, St. Bernard, and St. Tammany. 

This economic injury disaster declaration makes Economic Injury Disaster Loans available to small, 

private, and non-profi t businesses in the parishes and contiguous parishes that are impacted by the oil 

spill. Dispersant test number two concludes.

May 5, 2010 – DAY 16: The RP plans to deploy the cofferdam, a 125-ton, 14x24x40 foot structure 

to be set over the end of the riser (the pipe that normally goes from the wellhead to the drilling ship). 

The RP makes $25 million block grants to the states of Alabama, Florida, Louisiana, and Mississippi 

to help them implement oil spill contingency plans.

May 6, 2010 – DAY 17: Oil reaches the shores of Chandeleur Islands, La. The RP cancels the Woods 

Hole project.

May 7, 2010 – DAY 18: NOAA modifi es and expands the boundaries of the closed fi shing area to refl ect 

the current location of the oil spill. After deploying test applications of sub-sea dispersants, EPA halts 

sub-sea dispersant operations, awaiting additional test results. Secretary of DOI Salazar announces 

that no applications for new drilling permits will go forward for any new offshore drilling activity 

until DOI completes the safety review process requested by President Obama. The RP completes the 

cofferdam containment dome, a sub-sea oil collection system that is lowered to the sea fl oor. Sheen 

and emulsifi ed oil are confi rmed at Chandeleur Islands, La. The oil spill volunteer plan is approved.

May 8, 2010 – DAY 19: The RP announces that while lowering the cofferdam over the riser, an excess 

of hydrate crystals formed inside the dome, preventing the successful placement of the dome over the 

leaking riser. The dome remains on the sea fl oor while the RP evaluates conditions. The RP begins 

preparing a smaller containment dome known as the top hat, an eventual component of Lower Marine 

Riser Package (LMRP) containment system. The motor vessel Brooks McCall collects the fi rst water 

sample. Tar balls are reported on Dauphin Island, Ala.

May 9, 2010 – DAY 20: The Coast Guard and EPA sign a Dispersant Monitoring and Assessment 

Directive. Tar balls are confi rmed on Dauphin Island, Ala. Cleanup operations commence.

Pinnacle for the entire Deepwater Horizon incident: Highest single-day quantity of oily liquids 

recovered: 33,865 barrels.

May 10, 2010 – DAY 21: EPA accepts a testing protocol created by RP scientists with NOAA oversight 

as its directive regarding sub-sea dispersant use. Response personnel exceed 13,000. 

Pinnacles for the entire Deepwater Horizon incident: Highest single-day quantity of aerial dispersants applied: 56,220 gallons. Highest single-day quantity of aerial, surface, and sub-sea dispersants 

combined applied: 68,530 gallons.

May 11, 2010 – DAY 22: Secretary of DOI Salazar announces that he will restructure the DOI Minerals 

Management Service (DOI MMS) in order to establish a separate and independent safety and environmental enforcement entity. Secretary Salazar also announces that the administration will seek additional 

resources for federal inspectors, requests an independent, technical investigation of the causes of the 

Deepwater Horizon spill from the National Academy of Engineers, and requests expanded authority 

to review explorations plans. The Louisiana Offi ce of Coastal Protection and Restoration applies to 

the Army Corps of Engineers for an emergency permit to construct berms to help reduce the inland 

movement of oil.
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Appendix

May 12, 2010 – DAY 23: The Secretary of Energy travels to Houston to participate in meetings with 

DOE and national laboratory staff, industry offi cials, and other engineers and scientists involved in 

fi nding solutions to cap the fl ow of oil and contain the spill. The Assistant Secretary of Defense authorizes the use of National Guard assets for the Deepwater Horizon oil spill response. The RP releases 

a 30-second video of oil and gas streaming from the end of the broken riser. The RP places the Top 

Hat on the seabed.

May 13, 2010 – DAY 24: First attempt at Operation Riser Insertion Tube Tool (RITT) is conducted. 

As of this date, 6,700 claims for spill-related losses are fi led, and around 1,000 are paid. More than 

16,000 people are registered as volunteers and 46,500 calls have been made to RP help lines, around 

30 percent offering ideas to help the response or other assistance.

May 14, 2010 – DAY 25: President Obama announces that he has ordered Secretary Salazar to conduct 

a top-to-bottom review of the DOI MMS.

May 15, 2010 – DAY 26: The Secretary of DHS and the Secretary of the Interior issue a letter to the 

BP CEO reiterating that as an RP for this event, BP is accountable to the American public for the full 

cleanup of this spill and all the economic loss caused by the spill and related events. The Coast Guard 

and EPA approve the use of sub-sea dispersants. Operation RITT is tested successfully and inserted 

into the leaking riser, capturing some oil and gas.

Cumulative statistical snapshot:

Amount of oily liquid recovered: 151,391 barrels

Controlled in situ burns: 10 burns

Amount of surface dispersants applied: 575,816 gallons

Amount of sub-sea dispersants applied 37,813 gallons

Amount of containment boom deployed: 1,294,910 feet

Amount of sorbent boom deployed: 441,620 feet

Total number of vessels: 656

Total number of skimmers: 32

Total wildlife impacts (includes birds): 32

Total number of responders: 19,163

May 16, 2010 – DAY 27: A second drill rig, the Transocean Development Driller II, begins drilling a 

second relief well. The RITT is successfully inserted into the end of the broken riser and begins carrying oil and gas up to the Discoverer Enterprise on the surface.

May 17, 2010 – DAY 28: The RP announces grants to help Gulf Coast states promote tourism: $25 

million to Florida and $15 million each to Alabama, Louisiana, and Mississippi.

May 18, 2010 – DAY 29: Maintenance is performed on the BOP stack. Drilling and casing operations 

continue on the Development Driller II relief well, whose depth remained at 3,537 feet below sea fl oor. 

The RITT is operational, initially collecting an estimated 2,000 barrels of oil a day. Gas brought to the 

surface by the RITT is fl ared and burned off.

May 19, 2010 – DAY 30: The Secretary of DOI signs a secretarial order leading to the fundamental 

restructuring of the DOI MMS and the division of its three missions into separate entities for leasing, 

safety, and revenue collection with independent missions to strengthen oversight of offshore energy 

operations. In addition, Chairman Markey of the House Energy and Environment Subcommittee requests 

that the RP immediately make its live video feed from the underwater ROVs of the leak points and 

undersea activities publicly available. The National Incident Command (NIC) creates the interagency 

Flow Rate Technical Group to generate a preliminary fl ow rate as soon as possible.
Appendix

207

May 20, 2010 – DAY 31: Secretary of DHS Napolitano announces that Coast Guard Admiral Thad 

Allen will keep his role as National Incident Commander after stepping down from his post as Coast 

Guard Commandant. In addition, Secretary Napolitano and EPA Administrator Jackson send a letter 

to BP CEO Tony Hayward stressing their expectation that the RP conduct all actions in a transparent 

manner, with all data and information related to the spill readily available to the U.S. government and 

the American people. The EPA also issues a directive requiring the RP to identify and use a less toxic 

and more effective dispersant from the list of EPA authorized dispersants. The directive requires the 

RP to identify this less toxic alternative—to be used both on the surface and under the water at the 

source of the oil leak—within 24 hours, and to begin using the less toxic dispersant within 72 hours 

of submitting the alternative. The RP makes available a live feed of the underwater leak at its source 

that was posted by The Committee on Energy and Commerce. The RP does this following Chairman 

Markey’s request on May 19.

May 21, 2010 – DAY 32: The RP launches a second website with a live webcam of the underwater 

oil leak at its source.

May 22, 2010 – DAY 33: President Obama signs an executive order establishing the bipartisan National 

Commission on the BP Deepwater Horizon Oil Spill and Offshore Drilling with former Florida Governor and Senator Bob Graham and former EPA Administrator William K. Reilly serving as co-chairs. 

The Administration tasks the bipartisan National Commission on the BP Deepwater Horizon Oil Spill 

and Offshore Drilling with providing recommendations on how to prevent—and mitigate the impact 

of—any future spills that result from offshore drilling.

May 23, 2010 – DAY 34:

Cumulative statistical snapshot:

Amount of containment boom: 1.75 million feet

Amount of sorbent boom: 997,000 feet

Amount of surface dispersants applied: 704,000 gallons

Amount of sub-sea dispersants applied: 116,000 gallons

May 24, 2010 – DAY 35: Secretary of Commerce Gary Locke declares a fi sheries disaster for commercial and recreational fi sheries in the Gulf of Mexico as a result of the ongoing impacts from the 

Deepwater Horizon oil spill. The fi sheries closure encompasses 19 percent of federal waters in the Gulf 

of Mexico. The RP commits $500 million to the Gulf of Mexico Research Initiative—a ten-year open 

research program to study the impact of the spill and response on the environment.

May 25, 2010 – DAY 36: Oil spill information websites are established for Alabama, Florida, Louisiana, and Mississippi.

May 26, 2010 – DAY 37: The top kill procedure commences in an attempt to stop fl ow of oil by 

injecting heavy drilling fl uids into the well. The FOSC and EPA issue Dispersant Monitoring and 

Assessment Directive Addendum III, a directive requiring the RP to signifi cantly scale back the use 

of dispersants. Coast Guard Parish President Liaison Offi cers are assigned to the potentially affected 

parishes in Louisiana.

May 27, 2010 – DAY 38: The NIC’s Flow Rate Technical Group develops an independent, preliminary estimate of the amount of oil fl owing from the RP’s leaking oil well. The analysis estimates that 

12,000 to 19,000 barrels per day are leaking into the Gulf. The ACOE approves a scaled-back Louisiana sand berms project. The National Incident Commander approves the implementation of a section 

of Louisiana’s Barrier Island berm project proposal that could help stop oil from coming ashore. The 

Subcommittee on Energy and Environment holds a hearing titled “Combating the BP Oil Spill.” The 

hearing examines the ongoing response to the oil spill at the Deepwater Horizon drilling rig site. The 

fi rst billing for over $1.8 million is sent to the RP for response and recovery operations relating to the 

Deepwater Horizon oil spill.
208

Appendix

May 28, 2010 – DAY 39: President Obama travels to the Gulf Coast for the second time. The President 

announces that he directed Secretary of DHS Napolitano and the National Incident Commander to 

triple the manpower in the places where oil has reached or will reach the shoreline within 24 hours of 

impact in order to intensify the response effort.

May 29, 2010 – DAY 40: The RP announces that the top kill procedure did not overcome the fl ow 

of oil, despite 30,000 barrels of heavy mud pumped into the well. Plans begin for deployment of the 

LMRP containment cap from the Discoverer Enterprise to pump oil and gas to the surface.

May 30, 2010 – DAY 41: The 100th controlled in situ burn is conducted. Estimates of cumulative total 

oil burned at the completion of the 100th burn range from approximately 48,185 to 68,947 barrels. The 

DOI MMS moratorium on deepwater drilling takes effect, halting work on 33 offshore deepwater rigs 

in the Gulf of Mexico.

May 31, 2010 – DAY 42: NOAA extends the northern boundary of the closed federal fi shing area in the 

Gulf of Mexico. The closed area represents 61,854 square miles, slightly less than 26 percent of Gulf 

of Mexico federal fi sheries waters. In addition, the RP issues a statement that it has found no evidence 

of underwater oil plumes, despite evidence documented by scientists.

June 1, 2010 – DAY 43: The U.S. Attorney General visits Louisiana to coordinate the Administration’s 

response to the oil spill. NOAA extends the northern and southern boundaries of the closed federal 

fi shing area in the Gulf of Mexico to include portions of the waters off eastern Alabama and the western 

tip of the Florida panhandle. The closed area represents 75,920 square miles, which is slightly more 

than 31 percent of Gulf of Mexico federal fi sheries waters. Coast Guard Rear Admiral James A. Watson 

assumes the FOSC position from Coast Guard Rear Admiral Mary Landry. The 2010 Gulf of Mexico 

hurricane season offi cially begins.

Cumulative statistical snapshot: 

Amount of oily liquid recovered: 338,848 barrels

Controlled in situ burns: 125 burns

Amount of surface dispersants applied: 755,893 gallons

Amount of sub-sea dispersants applied: 238,530 gallons

Amount of containment boom deployed: 2,002,946 feet

Amount of sorbent boom deployed: 2,192,430 feet

Total number of vessels: 1,783

Total number of skimmers: 120

Total wildlife impacts (includes birds): 867

Total number of responders: 18,081

June 2, 2010 – DAY 44: The Coast Guard directs the RP to pay for fi ve additional barrier island projects, in addition to the one previously approved, attempting to protect coastal communities from oil. A 

second billing of more than $69 million is sent to the RP for response operations relating to the Deepwater Horizon oil spill. The Administration states that it will continue to bill the RP regularly for all 

associated costs to ensure the Oil Spill Liability Trust Fund (OSLTF) is reimbursed on an ongoing basis.

June 3, 2010 – DAY 45: The Secretary of the Department of Commerce declares a fi shery disaster in 

Florida due to the economic impact on commercial and recreational fi sheries from the oil spill, increasing 

the affected area from the May 24 determination, which includes Alabama, Louisiana, and Mississippi. 

The RP cuts off a portion of the riser and successfully lowers the LMRP containment device over the 

source area to capture the leaking oil; recovers oil and gas, which begins to be siphoned through riser 

to the Discoverer Enterprise. The RP releases live feeds from all 12 underwater cameras to the public. 

The cameras are mounted on automated rovers working on the oil spill.

Pinnacle for the entire Deepwater Horizon incident: Highest number of square miles of fi sheries 

closed: 88,522 square miles.
Appendix

209

June 4, 2010 – DAY 46: President Obama makes a third trip to the Gulf Coast. The RP announces 

advance payments of claims for those losing income or net profi t. The RP closes the fi rst valve on the 

LMRP cap. The Coast Guard establishes the Interagency Alternative Technology Assessment Program to receive, acknowledge, and evaluate response-related product ideas. Tar balls are discovered 

in Pensacola, Fla.

Pinnacles for the entire Deepwater Horizon incident: Highest single-day quantity of sub-sea dispersants 

applied: 20,655 gallons. NOAA opens more than 16,000 square miles of previously closed fi shing area 

off the Florida coast. Additionally, NOAA closes a 2,275-square mile area off the Florida panhandle 

as a precautionary measure to ensure that seafood from the Gulf will remain safe for consumers. The 

total closed area represents 33 percent of Gulf of Mexico federal fi sheries waters.

June 5, 2010 – DAY 47: EPA Administrator and the National Incident Commander convene a meeting of science and technology experts in Houma, La., to explore new ideas and methods for coastal 

protection and cleanup technologies.

June 6, 2010 – DAY 48: Tar balls are sighted at Fort Walton Beach, Fla.

June 7, 2010 – DAY 49: The House Subcommittee on Oversight and Investigations holds a fi eld hearing titled, “Local Impact of the Deepwater Horizon Oil Spill,” in Chalmette, La. The hearing examines 

the impact of the oil spill at the Deepwater Horizon drilling rig site on the Gulf region.

June 8, 2010 – DAY 50: The LMRP containment cap collects 15,000 barrels to date. A Memorandum 

of Understanding is established between the Occupational Safety and Health Administration (OSHA), 

Department of Labor (DOL), FOSC, DHS concerning OSHA issues related to the Deepwater Horizon 

response.

June 9, 2010 – DAY 51: The Secretary of DOL travels to Louisiana to inspect the ongoing efforts to 

ensure the health, safety, and well-being of workers affected by the oil spill. The House Energy and 

Environment Subcommittee holds a briefi ng titled, “Beneath the Surface of the BP Spill: What’s Happening Now, What’s Needed Next,” where witnesses discuss the evidence of underwater plumes and 

suspended oil pollution in the water column.

June 10, 2010 – DAY 52: The House Energy and Environment Subcommittee holds a hearing titled, 

“The BP Oil Spill: Human Exposure and Environmental Fate.” The hearing examines the potential 

impacts to humans and the environment associated with the spill. The Discoverer Enterprise completes 

its fi rst offl oad of oil. The RP provides an additional $25 million in grants to Alabama, Florida, and 

Mississippi for their protection plans. The ICP relocates from St. Petersburg, Fla., to Miami, Fla. A 

Branch remains in St. Petersburg, Fla.

June 11, 2010 – DAY 53: The FOSC, Rear Admiral James Watson, issues a letter to BP Chief Operating 

Offi cer Doug Suttles to identify additional leak containment capacity within 48 hours.

June 12, 2010 – DAY 54: A 5,000 pound tank from the Deepwater Horizon platform washes ashore 

in Panama City Beach, Fla.

June 13, 2010 – DAY 55: The Coast Guard extinguishes the fi rst of two controlled burns that were 

never purposely extinguished. The extinguished burn is burn number 182. The total duration of the 

burn is 11 hours and 21 minutes, the second longest burn recorded. The total quantity of oil burned is 

approximately 4,774 barrels.

June 14, 2010 – DAY 56: Version 3 of the Recovered Oil and Waste Management Plan for ICP Houma 

is approved to cover waste issues in Louisiana.

June 15, 2010 – DAY 57: President Obama signs an amendment to OPA 90 that authorizes advances 

from the OSLTF. More than 40 Shoreline Cleanup Assessment Technique (SCAT) Teams begin assessing shorelines in Alabama, Florida, Louisiana, and Mississippi. Relief well drilling continues, the fi rst 

relief well at an approximate depth of 15,000 feet and the second at an approximate depth of 9,500 feet. 

The RP prepares to fast track fund $25 million as part of the Gulf Coast Research Initiative to support 

environmental studies at Louisiana State University, the Florida Institute of Oceanography, and the 

Northern Gulf Institute consortium.
210

Appendix

Cumulative statistical snapshot:

Amount of oily liquid recovered: 504,590 barrels

Controlled in situ burns: 214 burns

Amount of surface dispersants applied: 885,476 gallons

Amount of sub-sea dispersants applied: 413,735 gallons

Amount of containment boom deployed: 2,543,745 feet

Amount of sorbent boom deployed: 3,479,017 feet

Total number of vessels: 4,323

Total number of skimmers: 136

Total wildlife impacts (includes birds): 1,853

Total number of responders: 31,062

June 16, 2010 – Day 58: The second containment system attaches to the BOP, which sends recovered 

oil to the Q4000 service platform via sub-sea manifold, becomes operational. The RP agrees to create 

a $20 billion fund over three and a half years to meet obligations arising from the spill. Oil spill claims 

are to be administered by an independent facility. BP cancels dividend payments for the rest of 2010. 

The Coast Guard purposely extinguishes burn number 224. The total duration of the burn was 11 hours 

and 48 minutes. The total quantity of oil burned was approximately 5,956 barrels.

June 17, 2010 – Day 59: BP CEO Tony Hayward testifi es before the House Energy and Commerce 

Subcommittee on Oversight and Investigation. The UAC relocates to New Orleans from Robert, La.

June 18, 2010 – Day 60: Pinnacle for the entire Deepwater Horizon incident: Highest single-day 

quantity of oil burned: 59,550 barrels.

June 20, 2010 – Day 62: The response issues document preservation guidance to all responders.

June 21, 2010 – Day 63: The agency formerly known as the MMS is renamed the Bureau of Ocean 

Energy Management, Regulation, and Enforcement (BOEMRE).

June 22, 2010 – Day 64: The RP announces that its net revenue from the sale of oil recovered from 

the Macondo well will be donated to the National Fish and Wildlife Foundation.

Pinnacle for the entire Deepwater Horizon incident: Highest single-day quantity of oil recovered: 

27,097 barrels.

June 24, 2010 – Day 66: The Mississippi Department of Environmental Quality issues a revised precautionary closure to an additional area of Mississippi marine waters previously closed to commercial 

and recreational fi shing. The 601st Air and Space Operations Center, located at Tyndall Air Force Base 

in Panama City, Fla., is established to provide centralized airspace management of resources and aircraft 

activity supporting the Deepwater Horizon response in the Gulf of Mexico area.

June 25, 2010 – Day 67: Hurricane Alex enters the Gulf region, heading toward northern Mexico.

June 28, 2010 – Day 70: The Coast Guard Commandant and EPA sign the Joint Interim Rule regarding 

the response time requirement, location requirement, and re-location of Navy Supervisor of Salvage 

and Diving. Capping stack fabrication completes. NOAA expands the closed federal fi shing area in 

the Gulf of Mexico to 80,228 square miles, which represents 33 percent if the federal fi shing waters 

in the Gulf of Mexico.

June 29, 2010 – Day 71: The Coast Guard and EPA issue a directive requiring the RP to test waste for 

hazardous materials and to publicize the results.

June 30, 2010 – Day 72: Pinnacle for the entire Deepwater Horizon incident: Highest number of 

vessels assigned to the incident: 6,050 vessels.
Appendix

211

July 1, 2010 – Day 73:

Cumulative statistical snapshot:

Amount of oil recovered: 557,155 barrels (Discovery Enterprise, Q4000, 

Helix Producer 1)

Amount of oily liquid recovered: 671,457 barrels

Amount of gas recovered: 1,243.7 million standard cubic feet (Discovery 

Enterprise, Q4000, Helix Producer 1)

Controlled in situ burns: 275 burns per 237,950 barrels

Amount of surface dispersants applied: 1,051,159 gallons

Amount of sub-sea dispersants applied: 600,971 gallons

Amount of containment boom deployed: 3,017,472 feet

Amount of sorbent boom deployed: 4,954,735 feet

Total number of vessels: 6,026

Total number of skimmers: 550

Total wildlife impacts (includes birds): 2,781

Total number of responders: 43,128

July 3, 2010 – Day 75: Collection of oil from the LMRP containment cap and Q4000 system continues 

with 25,000 barrels collected to date. The ACOE denies Jefferson Parish’s request to construct rock 

dike structures for the purpose of reducing oil entering Barataria Basin. A Taiwanese skimming vessel 

dubbed A Whale arrives on-scene.

July 5, 2010 – Day 77: Tar balls are reported at the Rigotlets, at the entrance to Lake Pontchartrain, La.

July 6, 2010 – Day 78: The 601st Air and Space Operations Center begins centralized airspace management of resources and aircraft activity supporting the Deepwater Horizon response in the Gulf of 

Mexico area.

Pinnacle for the entire Deepwater Horizon incident: Florida’s highest single-day quantity of heavy 

to moderately oiled shoreline: 18.7 miles.

July 7, 2010 – Day 79: Pinnacles for the entire Deepwater Horizon incident: Highest number of 

personnel assigned to incident: 47,849. Highest single-day quantity of gas recovered: 58 million standard cubic feet.

July 8, 2010 – Day 80: The National Incident Commander issues a letter to the RP requiring a detailed 

timeline and contingency procedures for the capping stack process to secure the fl ow of oil from the 

source.

July 9, 2010 – Day 81: An ICP is established in Galveston, Texas

July 10, 2010 – Day 82: The Discover Inspiration moves off to allow capping stack installation. The 

LMRP containment cap is removed in preparation for its replacement with a sealing cap assembly 

capable of increasing containment capacity or potentially shutting in the well, includes a fl ange transition spool and a three-ram capping stack.

Pinnacles for the entire Deepwater Horizon incident: Highest number of helicopters assigned to 

response: 82. Alabama’s highest single-day quantity of heavy to moderate oiled shoreline: 24.5 miles. 

Highest single-day quantity of response wide heavy to moderately oiled shoreline: 180.8 miles. Highest 

number of VOOs utilized: 3,233.

July 12, 2010 – Day 84: Rear Admiral Paul Zukunft relieves Rear Admiral James Watson as the FOSC. 

The RP installs a three-ram capping stack that put the sealing cap in place by the Discoverer Inspiration. The BOEMRE issues a revised moratorium that limits drilling based on the equipment a rig uses 

instead of the depth of the wellhead.
212

Appendix

July 13, 2010 – Day 85: The Helix Producer I starts oil recovery (20 to 25 thousand barrels of oil per 

day).

July 14, 2010 – Day 86: Pinnacle for the entire Deepwater Horizon incident: Highest single-day 

number of controlled burns: 26.

July 15, 2010 – Day 87: The RP closes the well capping stack, which successfully stops oil fl ow, 

securing the source at 2:22 p.m. Well integrity testing begins.

Cumulative statistical snapshot:

Amount of oil recovered: 817,739 barrels (Discovery Enterprise, Q4000, 

Helix Producer 1)

Amount of oily liquid recovered: 783,490 barrels

Amount of gas recovered: 1,844 million standard cubic feet (Discovery 

Enterprise, Q4000, Helix Producer 1)

Controlled in situ burns: 377 burns per 261,400 barrels

Amount of surface dispersants applied: 1,072,314 gallons

Amount of sub-sea dispersants applied: 762,881 gallons

Amount of containment boom deployed: 3,505,921 feet

Amount of sorbent boom deployed: 6,836,224 feet

Total number of vessels: 5,745

Total number of skimmers: 588

Total wildlife impacts (includes birds): 3,711

Total number of responders: 44,264

July 16, 2010 – Day 88: Following tests, a decision is made that the supertanker skimmer A Whale

will not be used.

July 17, 2010 – Day 89: The vessel West Sirius installs the second free standing riser.

Pinnacles for the entire Deepwater Horizon incident: Louisiana’s highest single-day quantity of 

heavy to moderate oiled shoreline: 153.4 miles. Mississippi’s highest single-day quantity of light to 

trace oiled shoreline: 107.5 miles.

July 19, 2010 – Day 91: The 411th and fi nal in situ controlled burn is conducted during Deepwater 

Horizon. Estimated cumulative total volume burned ranged from approximately 219,986 to 309,452 

barrels. The last dispersant application is conducted.

Pinnacle for the entire Deepwater Horizon incident: Highest number of fi xed wing aircraft assigned 

to incident: 20.

July 21, 2010 – Day 93: Pinnacle for the entire Deepwater Horizon incident: Highest quantity of 

containment boom deployed: 3,795,985 feet.

July 22, 2010 – Day 94: Tropical Storm Bonnie begins, occurring through July 24. All response 

operations are secured. NOAA opens federal fi sheries 190 miles southeast of the Deepwater Horizon 

wellhead along the Florida shelf, which is one third of the previously closed area.

July 24, 2010 – Day 96: Tropical Storm Bonnie ends, all response operations are secured. Ships return 

to the Deepwater Horizon wellhead area.

July 25, 2010 – Day 97: Parish presidents participate in an overfl ight of coastal Louisiana following 

Tropical Storm Bonnie.
Appendix

213

Cumulative statistical snapshot:

Amount of oil recovered: 827,046 barrels (Discovery Enterprise, Q4000, 

Helix Producer 1)

Amount of oily liquid recovered: 827,829 barrels

Amount of gas recovered: 1,866 million standard cubic feet (Discovery 

Enterprise, Q4000, Helix Producer 1)

Controlled in situ burns: 411 burns totaling 265,450 barrels

Amount of surface dispersants applied: 1,072,514 gallons

Amount of sub-sea dispersants applied: 771,272 gallons

Amount of containment boom deployed: 3,710,430 feet

Amount of sorbent boom deployed: 7,815,656 feet

Total number of vessels: 1,067

Total number of skimmers: 794

Total wildlife impacts (includes birds): 5,173

Total number of responders: 9,496

July 27, 2010 – Day 99: The fi rst parish presidents’ meeting is held in New Orleans, La.

Pinnacle for the entire Deepwater Horizon incident: Texas’s highest single-day quantity of light to 

trace oiled shoreline: 1 mile.

July 29, 2010 – Day 101: The FOSC issues letters to all parish presidents outlining the creation of 

parish-specifi c transition plans utilizing the framework from the UAC’s transition plan, while capturing 

the impacts of the Deepwater Horizon spill unique to each parish.

August 1, 2010 – Day 104:

Cumulative statistical snapshot:

Amount of oil recovered: 827,046 barrels (Discovery Enterprise, Q4000, 

Helix Producer 1)

Amount of oily liquid recovered: 826,361 barrels

Amount of gas recovered: 1,866 million standard cubic feet (Discovery 

Enterprise, Q4000, Helix Producer 1)

Controlled in situ burns: 411 burns total 265,450 barrels

Amount of surface dispersants applied: 1,072,514 gallons

Amount of sub-sea dispersants applied: 771,272 gallons

Amount of containment boom deployed: 3,646,640 feet

Amount of sorbent boom deployed: 8,032,036 feet

Total number of vessels: 4,038

Total number of skimmers: 831

Total wildlife impacts (includes birds): 5,675

Total number of responders: 30,075

August 2, 2010 – Day 105: The government approves the RP’s static well kill plan to inject drilling 

mud slowly into the well.

Pinnacle for the entire Deepwater Horizon incident: Highest number of skimmers assigned to incident: 835.

August 3, 2010 – Day 106: Operational annex sub-sea water sampling begins. The RP begins the static 

well kill process.
214

Appendix

Pinnacle for the entire Deepwater Horizon incident: Highest single-day quantity of all wildlife collected: 261.

August 4, 2010 – Day 107: Static well kill is determined successful.

Pinnacle for the entire Deepwater Horizon incident: Highest single-day quantity of non-visibly oiled 

wildlife collected: 136.

August 5, 2010 – Day 108: The RP carries out cementing operations to seal the well. Claims payments 

top $300 million, with distributions to more than 40,000 individuals and businesses affected by the spill.

August 6, 2010 – Day 109: Cement pumping completed at the wellhead.

Pinnacle for the entire Deepwater Horizon incident: Highest single-day quantity of visibly oiled 

wildlife collected: 168.

August 7, 2010 – Day 110: Well pressure testing begins.

August 8, 2010 – Day 111: The National Incident Commander announces the static well kill cementing procedure pressure test is complete and holding. The controlled burn after action report for May 

28 to August 3 is released.

August 9, 2010 – Day 112: Following the completion of cementing operations on August 5, pressure 

testing indicates there is an effective cement plug in the casing and successful completion of the static 

kill and cementing procedures.

August 10, 2010 – Day 113: Relief well drilling is delayed due to a tropical storm approaching the 

Gulf of Mexico. NOAA reopens more than 5,000 square miles of federal fi sheries waters for ocean 

fi shing, 52,000 square miles remain closed.

August 11, 2010 – Day 114: Pinnacle for the entire Deepwater Horizon incident: Alabama’s highest 

single-day quantity of light to trace oiled shoreline: 70.5 miles.

August 12, 2010 – Day 115: Relief well work recommences.

August 13, 2010 – Day 116: A second parish president meeting is held in Houma, La. Ambient pressure 

testing on the oil well begins. The National Incident Commander signs the Sub-sea and Sub-surface 

Oil and Dispersant Detection Sampling and Monitoring Strategy Memorandum 16451.

Pinnacle for the entire Deepwater Horizon incident: Louisiana’s highest single-day quantity of light 

to trace oiled shoreline: 267.4 miles.

August 14, 2010 – Day 117: Bottom kill procedure is authorized to begin.

August 15, 2010 – Day 118:

Cumulative statistical snapshot:

Amount of oil recovered: 827,046 barrels (Discovery Enterprise, Q4000, 

Helix Producer 1)

Amount of oily liquid recovered: 826,988 barrels

Amount of gas recovered: 1,866 million standard cubic feet (Discovery 

Enterprise, Q4000, Helix Producer 1)

Controlled in situ burns: 411 burns total 265,450 barrels

Amount of surface dispersants applied: 1,072,514 gallons

Amount of sub-sea dispersants applied: 771,272 gallons

Amount of containment boom deployed: 2,586,653 feet

Amount of sorbent boom deployed: 8,770,086 feet

Total number of vessels: 2,914

Total number of skimmers: 835

Total wildlife impacts (includes birds): 7,175

Total number of responders: 28,277
Appendix

215

August 16, 2010 – Day 119: Pinnacles for the entire Deepwater Horizon incident: Mississippi’s 

highest single-day quantity of heavy to moderate oiled shoreline: 11.4 miles. Highest single-day quantity 

of response wide light to trace oiled shoreline: 543.8 miles.

August 18, 2010 – Day 121: Rear Admiral Zukunft signs the Sub-sea and Sub-surface Oil and Dispersant Detection Sampling and Monitoring Strategy Memorandum 16451. The RP fl ushes drilling mud 

and hydrocarbons from the Macondo well in advance of pressure test to ensure the well was secure. 

Bottom kill process is delayed due to analysis of annulus. Ambient pressure testing is under way. The 

University of South Florida researchers report oil on ocean fl oor in Desoto Canyon, a valley in the Gulf 

of Mexico. Twenty-three Kemp’s Ridley Sea Turtles are released into Gulf of Mexico.

Pinnacle for the entire Deepwater Horizon incident: Florida’s highest single-day quantity of light to 

trace oiled shoreline: 130.4 miles.

August 20, 2010 – Day 123: The fi rst formal consultation between the FOSC and stakeholders regarding historic properties occurs.

August 21, 2010 – Day 124: The 48-hour ambient pressure test is deemed successful. All states 

inside and outside territorial waters east of the Mississippi River, north of the northern shore of Pass a 

Loutre, and 29 degrees 12 minutes 40 seconds north latitude open to the commercial harvest of crabs. 

The FOSC approves an operational procedure authorizing the removal of drill pipe segments and an 

inspection of BOP.

August 23, 2010 – Day 126: The Operational Science Advisory Team is created. The RP reports that it 

made claim payments of nearly $400 million during the 16 weeks it managed claims related to the oil 

spill. The National Incident Commander announces that 90 percent of the containment boom deployed 

was recovered. The 601st Air Operations Center demobilizes and stops providing centralized airspace 

management of resources and aircraft activity supporting the Deepwater Horizon response in the Gulf 

of Mexico area. The RP VOO advisor issues a letter to the parish presidents stating that many recreational vessel participants will be removed from the VOO program, and their Master Vessel Charter 

Agreements with the RP will be terminated.

August 26, 2010 – Day 129: All Florida fi sheries, with the exception of blue crabs, which were unavailable for testing, are opened for harvesting.

August 27, 2010 – Day 130: To date, 978 birds have been treated and released to the Atchafalaya 

Delta Wildlife Management Area (WMA) in St. Mary Parish La., as part of the wildlife rescue and 

recovery effort.

August 29, 2010 – Day 132: The fi ve-year anniversary of Hurricane Katrina.

September 1, 2010 – Day 135: The third parish president meeting is held in Houma, La.

Cumulative statistical snapshot:

Amount of oil recovered: 827,046 barrels (Discovery Enterprise, Q4000, 

Helix Producer 1)

Amount of oily liquid recovered: 827,026 barrels

Amount of gas recovered: 1,866 million cubic standard feet (Discovery 

Enterprise, Q4000, Helix Producer 1)

Controlled in situ burns: 411burns totaling 265,450 barrels

Amount of surface dispersants applied: 1,072,514 gallons

Amount of sub-sea dispersants applied: 771,272 gallons

Amount of containment boom deployed: 1,755,528 feet

Amount of sorbent boom deployed: 9,239,365 feet

Total number of vessels: 3,242

Total number of skimmers: 835

Total wildlife impacts (includes birds): 8,602

Total number of responders: 28,430
216

Appendix

September 2, 2010 – Day 136: The capping stack on top of the Deepwater Horizon’s BOP is removed 

by the drillship Discoverer Enterprise.

September 3, 2010 – Day 137: The Deepwater Horizon’s BOP is successfully removed from the Mississippi Canyon 252 well at 1:20 p.m. CST. A new BOP installed by Development Driller II. Development Driller II then fl ushes the stack and pressure tests the connection.

September 4, 2010 – Day 138: The Q4000 raises the Deepwater Horizon BOP and secures it on deck 

to a shipping frame. DD II unlatches LMRP and pulls perforated riser to surface. Discoverer Enterprise

raises capping stack to surface and secures it to the deck.

September 5, 2010 – Day 139: The Q4000 washes the Deepwater Horizon BOP stack and preserves 

it as evidence, as per protocol.

September 6, 2010 – Day 140: The Q4000 completes inspection of hoses and fi ttings on the Deepwater 

Horizon BOP.

September 7, 2010 – Day 141: Aerial observations confi rm all containment boom is removed from 

Alabama, Florida, and Mississippi.

September 8, 2010 – Day 142: The Development Driller II displaces riser to mud; tests BOP; cleanout 

commences to 1,500 feet below the wellhead.

September 9, 2010 – Day 143: The Q4000 departs for South Pass 55 at 7:01 p.m. CST for the transfer 

of BOP and LMRP to a transfer barge.

September 10, 2010 – Day 144: The Q4000 transfers the failed BOP, LMRP, and baskets containing 

other evidence collected from the sea fl oor near the Macondo well to transfer barge. The barge is enroute to NASA Michoud facilities in New Orleans, La.

September 11, 2010 – Day 145: BOP arrives at the NASA Michoud facility. Aerial observations confi rm that only six parishes in Louisiana still have containment boom deployed.

September 13, 2010 – Day 147: The Q4000 rig receives Coast Guard certifi cation to move to dry 

dock in Galveston, Texas. Relief well drilling operations restart from DD III. The UAC Consolidated 

Decontamination Plan is signed and promulgated.

September 14, 2010 – Day 148: The response vessel Gyre collects fi rst sediment sample.

September 15, 2010 – Day 149: The VOO program demobilizes in the states of Alabama, Florida, 

and Mississippi.

Cumulative statistical snapshot:

Amount of oil recovered: 827,046 barrels (Discovery Enterprise, Q4000, 

Helix Producer 1)

Amount of oily liquid recovered: 827,251 barrels

Amount of gas recovered: 1,866 million standard cubic feet (Discovery 

Enterprise, Q4000, Helix Producer 1)

Controlled in situ burns: 411 burns total 265,450 barrels

Amount of surface dispersants applied: 1,072,514 gallons

Amount of sub-sea dispersants applied: 771,272 gallons

Amount of containment boom deployed: 690,638 feet

Amount of sorbent boom deployed: 3,437,885 feet

Total number of vessels: 1,911

Total number of skimmers: 835

Total wildlife impacts (includes birds): 9,223

Total number of responders: 25,800
Appendix

217

September 16, 2010 – Day 150: The relief well drilled by the Development Driller III drilling rig 

intercepts the annulus of the Macondo well.

September 17, 2010 – Day 151: The fi rst government-to-government consultations with the FOSC 

and 11 federally recognized tribes is held.

September 19, 2010 – Day 153: The National Incident Commander confi rms that well kill operations 

on the Macondo well in the Gulf of Mexico are completed, with both the casing and annulus of the 

well sealed by cement.

September 20, 2010 – Day 154: ICPs Houma and Mobile demobilize. Operations are consolidated 

under the Gulf Coast Incident Management Team (GC-IMT) located in New Orleans, La.

September 22, 2010 – Day 156: Operational annex sub-surface sediment sampling begins.

September 23, 2010 – Day 157: The Cameron Branch and ICP Houston demobilize and close. Commercial and recreational fi shing reopen to the harvest of fi sh, crabs, and shrimp in all state waters east 

of the Mississippi River and north of the northern shore of Pass a Loutre.

September 25, 2010 – Day 159: Yates decontamination yard closes. Development Driller III recovers 

a 135-by-8-inch casing and sets a third cement plug.

September 26, 2010 – Day 160: The Development Driller III continues plug and abandonment operations.

September 28, 2010 – Day 162: Secretary of the Navy Ray Mabus’s report titled America’s Gulf Coast: 

A Long-Term Recovery Plan After The Deepwater Horizon Oil Spill, is released.

September 29, 2010 – Day 163: Nineteen decontamination sites are operational.

October 1, 2010 – Day 165: The NIC demobilizes and the National Incident Commander’s personal 

report is released. The U.S. Department of Health and Human Services (HHS) launches Oil Spill 

Distress Hotline.

Cumulative statistical snapshot:

Amount of oil recovered: 827,046 barrels (Discovery Enterprise, Q4000, 

Helix Producer 1)

Amount of oily liquid recovered: 827,829 barrels

Amount of gas recovered: 1,866 million standard cubic feet (Discovery 

Enterprise, Q4000, Helix Producer 1)

Controlled in situ burns: 411 burns total 265,450 barrels

Amount of surface dispersants applied: 1,072,514 gallons

Amount of sub-sea dispersants applied: 771,272 gallons

Amount of containment boom deployed: 23,020 feet

Amount of sorbent boom deployed: 389,010 feet

Total number of vessels: 1,329

Total number of skimmers: 835

Total wildlife impacts (includes birds): 9,416

Total number of responders: 19,482

October 4, 2010 – Day 168: The Gulf-Wide Recovered Oil and Waste Management Plan is signed, 

and supersedes the previous waste management plans for both the ICPs Mobile and Houma.

October 6, 2010 – Day 170: The response returns to standard NRC oil reporting protocols.

October 8, 2010 – Day 172: The St. Mary and Iberia Branch demobilizes and closes.

Pinnacle for the entire Deepwater Horizon incident: Highest amount of sorbent boom deployed: 

566,140 feet.
218

Appendix

October 12, 2010 – Day 176: BOEMRE lifts the moratorium on deepwater drilling. Sixty-nine VOO 

vessels are taken off hire.

October 14, 2010 – Day 178: Approximately 33 HESCO Baskets are installed at Perdido Pass East 

in Alabama.

October 15, 2010 – Day 179: Five helicopters demobilize (one at the Western Branch; one at Lafourche; 

one at Jefferson and two on standby). Twenty aircraft demobilize over the past 30 days; 16 aircraft 

remain (including 1 military). Bollinger’s site in Texas City, Texas, receives full approval for decontamination safety. The Middle River Decontamination site for Orleans and St. Tammany Parish close 

with all equipment to be removed by October 18, 2010. A Choctaw Tribe representative and archeologist 

travels to Sugar Island for a Native American artifact reconnaissance mission. NOAA announces reopening of 6,879 square miles of oil impacted federal waters for commercial and recreational fi shing. 

The total amount of re-opened waters is 81.4 percent.

Daily statistical snapshot:

Amount of oily liquid recovered: 68 barrels

Total number of vessels: 1,722

Total number of VOOs: 319 (on hire); 2,838 (under contract)

Total number of skimmers: 25

Total number of responders: 15,629

October 16, 2010 – Day 180: Volunteer Beach Cleanup Day is held in Harrison County, Miss. All 

Shoreline Treatment Recommendations developed by the SCAT Teams for Orange Beach and Gulf 

Shores, Ala., are ready for implementation.

October 17, 2010 – Day 181: The joint U.S. Geological Survey and the RP near-shore water and sediment sampling operations are complete.

October 18, 2010 – Day 182: RP representatives and Tri-State Bird Rescue and Research hold a press 

update at the Hammond Wildlife Rehabilitation Center, which was the main rehabilitation center in 

the Gulf during the response. Operation Deep Clean began in Orange Beach, Ala. The Sediment and 

Water Column Sampling Program completes.

October 19, 2010 – Day 183: Coast Guard Rear Admiral Zukunft and media personnel fl y over the barrier islands (Chandeleurs, Ship Island, and Grand Isle) to survey the response cleanup work completed.

October 20, 2010 – Day 184: The Marine Mammal and Sea Turtle Group ceases operations for sea 

turtles. Daily reporting of impacted wildlife numbers to UAC discontinues. The Terrebonne Branch 

receives approval from all agencies to use small walk-behind sand sifters (Sandman 850) on the beaches 

of Trinity Island and Timbalier Island.

October 21, 2010 – Day 185: NOAA representatives perform a turtle release approximately 60 miles 

south of Grand Isle, La. These are the fi rst turtles to be released off the Louisiana coast since the start 

of the Deepwater Horizon response. The Stage III STR for operational distance of mechanical beach 

sifters near the dunes and vegetation lines is reduced from 50 feet to 10 feet on Orange Beach, Ala., 

amenity beaches.

October 22, 2010 – Day 186: Vermillion Branch demobilizes and closes. The SCAT Technical Advisor gives a presentation to the Alabama Branches to discuss guidelines and objectives in 2010, and 

treatment techniques for subsurface oil.

October 23, 2010 – Day 187: The last sediment sample is collected by response vessel Ocean Veritas, 

which visited more than 500 stations to create over 2,400 sediment samples and 450 water samples 

collected for processing and archiving. The Alabama state decontamination site closes. A Strategic 

Planning and Applied Methods Team forms to facilitate the fl ow of information and equipment for 

best methods across the AOR. The Environmental Unit’s Rapid Response Environmental Site Support Team (RRESST) program completes, evaluates, and analyzes fi ndings from more than 2,800 site 
Appendix

219

inspections. The Shallow Water Submerged Oil (SWSO) program begins a revised sample collection 

protocol near the Pass a Loutre area, which includes both core soil samples and water samples. Samples 

are anticipated to be collected at six locations. The Technical Advisory Group is scheduled to meet to 

discuss next transition milestones. Mississippi completes zero-based inventory analysis. The Florida 

Branch begins zero-based inventory analysis.

October 24, 2010 – Day 188: The Subsurface Monitoring Unit’s last remaining active vessel completes 

the assigned offshore sampling and returns to Morgan City, La., to begin the decontamination process.

October 26, 2010 – Day 190: The three-mile decontamination site located near Venice, La., is closed. 

Special Operations Branch Strike Team No. 3 demobilizes.

October 27, 2010 – Day 191: An amendment to the Gulf Wide Solid Waste Management Plan is approved 

and changes weekly waste stream sampling to monthly sampling beginning November 1, 2010.

October 29, 2010 – Day 193: The fourth parish president meeting is held in New Orleans.

October 30, 2010 – Day 194: A new radio communications repeater is installed on West Point Island in 

the Mobile Division to improve communications. Approval is received from the National Park Service 

to use mechanical beach cleaning equipment (Beach Tech) to a depth of six inches on Horn Island, Miss.

October 31, 2010 – Day 195: Four archaeologists conduct enhanced archaeological surveys along 

Navarre Beach, Fla., in segments that have a high probability for yielding subsurface archaeological 

artifacts. Florida turtle nesting season ends.

November 1, 2010 – Day 196: Florida Division A operations personnel complete setting the barge 

anchors under the supervision of a Natural Resources Advisor and a marine archaeologist. The Cameron Parish, La., Hesco Basket Removal Project begins. Florida Division C completed the Zero Based 

Audit, which results in the release of the one remaining water operations vessel. An STR revision, 

approved by Section 106, discontinues all vacuum operations in the Upper Barataria Bay marsh areas. 

The revision is based on fi eld observations and reports from multiple sources, including the Bay Jimmy 

marsh treatment tests.

Daily statistical snapshot:

Total number of vessels: 932

Total number of skimmers: 19

Total number of VOOs: 2,838 (on contract), 135 (on hire)

Total number of responders: 9,758

November 2, 2010 – Day 197: Plaquemines Branch conducts random drug tests of personnel to continue through November 3. Venice Wildlife Stabilization site, equipment, and personnel demobilize.

November 3, 2010 – Day 198: The Terrebonne Branch is demobilized. The Wildlife Group transports 

the last remaining bird from the Hammond Rehabilitation Center to the Monroe Zoo. The zoo agrees 

to care for the bird until it molts. Both marine mammal and sea turtle stranding response reverts back 

to NOAA and the existing stranding network protocols and procedures. The Army Corps of Engineers 

approves Louisiana’s request to modify the emergency berm permit to realign the berm construction 

closer to the Chandeleur Islands.

November 4, 2010 – Day 199: The Subsurface Monitoring Unit meets at the Stennis Space Center 

in Mississippi to discuss the needs and progress on short-, mid-, and long-term data management and 

archive issues. The manual removal of Hesco Baskets near the Baldwin County, Ala., Staging Area 

completes.

November 5, 2010 – Day 200: Hesco Basket Removal Project, Cameron Parish Area C, completes. 

Operations removes 153 Hesco baskets. FOSC issues a letter to Louisiana Governor Jindal outlining the 

termination of the RP managed Louisiana VOO program, and transitions to Vessel Charter Agreements.
220

Appendix

November 7, 2010 – Day 202: The Long-Term Monitoring Program, established by the Environmental 

Unit, sets up one additional phragmites (a perennial grass) reference site at Pass a Loutre, making eight 

sites in the program. Bird recovery data is uploaded to GeoPlatform.gov, powered by Environmental 

Response Management Application.

November 8, 2010 – Day 203: The Wildlife Branch Technical Advisory Group meets and agrees that 

the wildlife group is no longer in a reconnaissance and recovery phase but now in a wildlife monitoring 

phase. A series of fi ve seafood safety forums are scheduled across the Florida Branch, with the initial 

meeting is set for November 8, in Port St. Joe, Fla., Division C.

November 9, 2010 – Day 204: Responders sign the proposed Environmental Unit Plan to remove all 

sentinel snares by November 24, 2010.

November 10, 2010 – Day 205: Strategic Planning and Applied Methods Team and SCAT participate 

in an alternative cleanup method meeting in New Orleans.

November 11, 2010 – Day 206: A UAC SCAT Team participates in a landowner meeting in New Orleans 

with the Wisner Foundation Representatives to discuss no further treatment guidelines, monitoring, 

and other cleanup discussion points for property owned by the Foundation.

November 12, 2010 – Day 207: The second consultation between the FOSC and eleven federally 

recognized tribes occurs.

November 13, 2010 – Day 208: The fi rst split of the Louisiana Regular Duck Season opens and runs 

through December 5, 2010.

November 15, 2010 – Day 210: The National Marine Fisheries Services and NOAA announce the 

reopening of approximately 8,400 square miles of commercial and recreational federal fi sheries.

Daily statistical snapshot:

Total number of vessels: 617

Total number of skimmers: 7

Total number of VOOs: 2,838 (on contract), 127 (on hire)

Total number of responders: 6,937

November 17, 2010 – Day 212: The fi fth parish president meeting is held in New Orleans. The EPA 

and the Offi ce of Inspector General visit the UAC to interview staff about dispersant use.

November 19, 2010 – Day 214: GC-IMT Strike Team Chandeleurs recovery and removal operations 

are secured. St. Bernard Branch decontamination location demobilizes.

November 20, 2010 – Day 215: Snare sentinel removal begins.

November 22, 2010 – Day 217: St. Bernard Branch demobilizes.

November 23, 2010 – Day 218: The Wildlife Branch attempts to install a wailer unit in Bay Jimmy to 

replace the current air hazing cannons.

November 28, 2010 – Day 223: Cameron Parish, La., Hesco Basket Removal Project completes (3,960 

baskets or 59,400 feet of shoreline barrier removed). The contractor expects completion of demobilization activities by November 30, 2010.

November 30, 2010 – Day 225: The 2010 Gulf of Mexico hurricane season offi cially ends.

December 1, 2010 – Day 226: The UAC dissolves and the GC-IMT remains to lead the response effort. 

GC-IMT Inclement Weather Policy Version 1.0 completes.

Daily statistical snapshot:

Total number of vessels: 427

Total number of skimmers: 2

Total number of responders: 6,363
Appendix

221

December 2, 2010 – Day 227: The Marine Mammal and Sea Turtle Group releases approximately 11 

sea turtles offshore of Carrabelle, Fla.

December 4, 2010 – Day 229: Snare sentinel removals are 100 percent completed in Caillou Bayou 

(Terrebonne), Isle Dernieres (Terrebonne), and Lake Barre (Terrebonne). Orleans and St. Tammany 

Branch demobilize all 11 protection barges. Snorkel SCAT surveys Pelican Island. Nothing signifi cant 

is found.

December 5, 2010 – Day 230: SCAT Team 3 meets with the Louisiana Department of Wildlife and 

Fisheries and successfully completes Stage III survey of Middle Ground (North Pass). Vessel Beau 

Rivage returns to port. Communications indicate that no oil is noted on its nets and only two tar balls 

are collected.

December 8, 2010 – Day 233: The New Orleans and St. Tammany branches close.

December 16, 2010 – Day 241: Orange Beach, Ala., mechanical beach cleaning completes.

December 17, 2010 – Day 242: UAC functions transition to the GC-IMT. Coast Guard Captain Stroh 

relieves Coast Guard Rear Admiral Zukunft as the FOSC. The FOSC for the Deepwater Horizon spill 

returns to reporting to the Eighth Coast Guard District. The OSAT releases the Summary Report for 

Sub-sea and Sub-surface Oil and Dispersant Detection: Sampling and Monitoring Report. The report 

includes an analysis of water and sediment samples that represent a subset of the data collected by the 

Sub-surface Monitoring Program that is most relevant to the primary response questions addressed by 

the OSAT. A National Park Service archaeologist determines that 80 percent of segment 17 (approximately 1,761 feet) in East Ship Island, Miss., should not continue recovery efforts due to artifacts found 

in the area. At Grand Isle in Jefferson Parish, the mechanical removal of tar mats is suspended by the 

State Park Manager until further notice.

December 18, 2010 – Day 243: Captain James Hanzalik relieves Captain Lincoln Stroh as the FOSC.

December 20, 2010 – Day 245: The piling removal subcontractor removes all nine pilings from Bayou 

Thomas in Orleans Parish. Auguring under the Hesco Baskets in Fourchon Beach completes, with the 

exception of the sensitive areas identifi ed by archeologists. All carpet boom remaining in St. Tammany 

(approximately 900 feet) is removed.

December 21, 2010 – Day 246:

Daily statistical snapshot:

Total number of vessels: 260

Total number of responders: 6,170

January 03, 2011 – Day 259: Florida organizational restructuring and a safety demobilization is 

conducted for all response personnel. A Technical Advisory Group meeting is held to discuss recent 

bird captures.

January 04, 2011 – Day 260: Hammond Wildlife Rehabilitation Center temporarily re-opens due to 

oiled birds recently captured.

Daily statistical snapshot:

Total number of vessels 345

Total number of responders 5,428

January 5, 2011 – Day 261: In Plaquemines, Lafourche, and Jefferson Parish, Natural Resource Advisors begin assignments within the operations section of each branch.

January 6, 2011 – Day 262: The FOSC visits the Mississippi Branch and fl ies over the island operations.

January 7, 2011 – Day 263: Louisiana Piling Removal Project: the divers and equipment demobilize 

after completion of survey and piling recovery and removal activities. The Environmental Unit’s sampling team collects a site closure sample at the Hopedale facility.
222

Appendix

January 12, 2011 – Day 268: The Florida Branch location at Mary Esther opens. A consultation meeting between the FOSC and eleven federally recognized tribes occurs.

January 14, 2011 – Day 270: The Tampa, Fla., dry dock site closes and demobilizes. Louisiana National 

Guard barge commences demobilization and is replaced by a commercial barge.

January 15, 2011 – Day 271: The sand relocation project completes with 34,000 cubic yards of sand 

relocated in Grand Isle, La. Four hundred feet of containment boom is deployed in Southwest Pass 

due to tar mat excavation.

January 17, 2011 – Day 273: Alabama Sand Shark operations are suspended due to effi ciency of 

operations. Three helicopters demobilize from Mobile, Ala., and Houma, La.

January 19, 2011 – Day 275: Power Sifters CD1 and CD3 are demobilized from Pensacola, Fla.

January 20, 2011 – Day 276: The Technical Advisory Group meets to discuss transition of responsibilities from the Wildlife Branch to the Natural Resource Damage Assessment (NRDA). The Hesco 

Basket Removal Project Plan is signed.

January 21, 2011 – Day 277: Marsh Island Refuge in Cypremort Point releases one rehabilitated 

white pelican and three brown pelicans. The Louisiana National Guard helicopter associated with the 

Louisiana National Guard barge demobilizes from the response. Dredging begins at Little Lagoon Cut 

on Dauphin Island, Ala.

January 22, 2011 – Day 278: Dauphin Island Sand Berm removal project completes, and equipment 

demobilization commences. Beach maintenance duties of Harrison County, Miss., beaches are transferred to the county.

January 23, 2011 – Day 279: The Orphan Anchor Pilot Program approves one location in Lake Borgne, St. Bernard Parish for use.

January 29, 2011– Day 285: Phase one of the Orphan Anchors Retrieval Program begins.

Sources of data:

Unifi ed Area Command Executive Summary daily reports from April 25, 2010, to December 14, 2010.

Unifi ed Area Command Executive Summary weekly reports from December 15, 2010, to January 24, 

2011.

Presidential Commission Report, January 2011, Chapter 5 “You’re in it now, up to your neck!”

BP Gulf of Mexico Response, Response Timeline located at http://www.bp.com/

Daily UAC and NIC reports located in the Homeland Security Information Network (HSIN).

Department of the Interior press releases.

State of Louisiana Offi ce of Governor Press Release located at www.gov.louisiana.gov/

Press releases and offi cial EPA letters contained at the EPA Response to BP Spill in the Gulf of Mexico 

website http://www.epa.gov/bpspill/index.html.

Department of Health and Human Services Press releases contained at the BP Gulf Spill Response 

website located at: http://www.hhs.gov/gulfoilspill/index.html.

Controlled Burns After Action Report for Burns for May 28, 2010 to August 3, 2010, dated August 

8, 2010.