US Coast Guard must change its policy to allow OSVs to respond in disaster recovery efforts, says John Snyder
Almost instinctively, mariners respond in emergency and rescue situations. I witnessed it first hand on 9/11 when approximately 500,000 people were evacuated by an impromptu flotilla of commercial and recreational vessels from Manhattan. It was the largest maritime evacuation since Dunkirk.
Which is why it is downright counterintuitive that US OSV owners would be prevented from responding to one of the deadliest natural disasters to ever hit the Caribbean because of the rigid enforcement of US Coast Guard regulations.
Sadly, that was exactly the case two years ago in the aftermath of Hurricane Maria, which caused some 3,000 fatalities and destroyed property and infrastructure valued at more than US$91Bn.
Looking to help in the hurricane relief effort, several US OSV owners and operators sought emergency approvals from the US Coast Guard to allow them to deviate from the services identified on their vessels’ Certificates of Inspection (COI).
OSVs would seem to be tailor-made for recovery efforts. Designed to service offshore drilling rigs, platform supply vessels can haul tonnes of cargo, equipment and supplies on their large open decks or carry fuel, drill water or liquid mud in their tanks. Crew boats and fast supply vessels (FSVs) can carry passengers and smaller amounts of cargo at high speeds.
But OSV owners who did try to help in the hurricane recovery and relief effort were turned away.
“Due to an assortment of circumstances, this volunteer effort encountered a variety of challenges,” wrote the US Coast Guard in a letter – called a task statement – to the National Offshore Safety Advisory Committee (NOSAC), which sought recommendations for using OSVs and other non-purpose-built vessels to assist in restoration and recovery efforts in response to natural and man-made disasters.
In a welcome move, an industry panel made up of offshore energy members, NOSAC and the Offshore Marine Service Association (OMSA) are working with the USCG to rectify the issue.
Most OSVs engaged in the offshore energy market in the US are regulated under 46 CFR (Code of Federal Regulations) Subchapter L. “This regulatory distinction could prevent a perfectly capable OSV from performing disaster relief operations,” wrote OMSA president Aaron C Smith in a letter to USCG Rear Admiral Peter J Brown, District Commander, Sector Miami. “Said another way, it may be legal for an OSV to pump fuel or water to a rig in 3-m seas, but illegal for the same boat to pump water or fuel into Puerto Rico while tied to a dock.”
OMSA’s solution to the problem is elegant. It suggests endorsing the use of the policy letter, “Temporary Emergency Berthing Vessels,” issued by the Eighth Coast Guard District Commander in 2016 as “a foundation for your permitting use of OSVs as hurricane response personnel berthing vessels for all of the ports within the Seventh District’s area of responsibility.” Mr Smith also states that US-flagged OSVs should be authorised to carry food, water and fuel in relief efforts and that sailing from Louisiana to Puerto Rico or the US Virgin Islands is a domestic and not an international voyage requiring SOLAS certification.
The result of NOSAC and OMSA’s efforts is that the USCG is now considering a new response, restoration and recovery vessel (Triple R Vessel or TRV) COI endorsement, which would allow vessels to be pre-approved for disaster response operations.
The US Coast Guard needs to get this problem solved quickly before the next hurricane season starts in the Caribbean. Adopting the industry’s path forward makes perfect sense. When it comes to recovery, relief and restoration efforts, it should be all available OSVs to the rescue.