MORPAG Status

Jim Calhoun / T&T Salvage, LLC

On April 4, ASA’s president distributed to the membership Federal Register Vol. 88, No. 61 dated March 30, 2023. This notice requests comments from the public, which were due to the docket June 28, on the “Maritime Oil-spill Response Plan Advisory Group” (MORPAG) recommendations for changes to the Coast Guard’s Vessel Response Plan (VRP) program and policies. These recommendations were provided in response to an audit from the U.S. Government Accountability Office. The recommendations center on the Vessel Response Plan program, specifically OSRO classification, equivalence, enforcing National Planning Criteria, Alternative Planning Criteria, compliance, and staffing to manage the VRP program.

The MORPAG group was composed entirely of federal employees. Its recommendations and comments on the VRP program were extensively discussed in the Federal Register “Background” and ten questions were posed to the public to assist the Coast Guard in making changes to the VRP program. The Federal Register goes on to state that any regulatory or policy changes, as a result of the comments, will be “separately announced in the Federal Register.” These recommendations, depending on which are adopted, may have an impact, operationally and financially, on the industry.

Regarding ASA’s comment on these recommendations, the decision was made to focus on the section that addressed resource availability (Page 19161- Coast Guard interpretation that resources must be dedicated), an issue of importance to the Association and for which there is member consensus. Any other comments on these recommendations were left to the ASA member companies, as each may have its own position on any particular issue.

ASA’s Regulatory Affairs committee will continue to track further Coast Guard action on this initiative.