PREMIAM – MCA Viewpoint • EIA history examples in the UK: ESGOSS and SEEEC • Management and Coordination • NCP – the current review • PREMIAM and the NCP EG • PREMIAM across the devolved administrations and civil contingencies • Funding and cost recovery • Exercising PREMIAM EIA history in the UK: ESGOSS and SEEEC – prior to EG Braer - Shetland, Scotland -1993 Sea Empress – Milford Haven Wales -1996 Braer Incident – Shetland 1993 - ESGOSS Ecological Steering Group on the Oil Spill in Shetland (ESGOSS) Report of Lord Donaldson’s Inquiry into the prevention of pollution from merchant • No formal UK EIA mechanism in placeshipping at the time ‘Safer Ships, Cleaner Seas’ • Instigated and funded by Scottish Office • Donaldson Enquiry 1993 • Baseline studies extrapolated • Studies covered: •Inter/sub tidal habitats •Benthic macro and meiofauna •Sand eels, otters, seals •Fish and shellfish monitoring programme SEA EMPRESS – Milford Haven, Wales – 1996 - SEEEC • SEA EMPRESS Environmental Evaluation Committee • No formal UK EIA mechanism in place at the time • Instigated and funded by Welsh Office • 200km shoreline impacted – SEEEC set up to evaluate environmental impact – 2 years, 100 projects – 3.5$ spend Post SEA EMPRESS and Prior to PREMIAM •UK NCP Environment Groups •MCA STOp Notice brief EIA section •EG’s activated up 2-3 times annually •Minor incident – “virtual” group •Major incident – Formal EG with ELO’s to all response cells •EIA involvement but not in the complete sense of PREMIAM •PREMIAM can fill that gap EIA - PREMIAM: Management and Coordination • Robust management and coordination essential – not least cost recovery. Management to design and coordinate studies. – Which key individuals/organisations to oversee the process? Across the Administrations? – Best practise monitoring, scientific rigour and objectivity – Technical reasonableness, proportionate/relevant – Avoid duplication – Involve compensation bodies with planning and methodology – Importance of documentation UK NCP current review • • • • • Presently considering consultees comments Likely a shorter doc – detail via weblinks New STOp notices: for SRC and EG Shoreline response in line with CCA EG and PREMIAM words unlikely to change PREMIAM and the NCP EG • Should run in parallel? • EG first responsibility to advise all response cells – but also: EG local knowledge feeds in to PREMIAM • Once NCP finalised – we need words for the STOp Notice? • Is the STOp Notice the best platform to describe how the Administrations will adopt PREMIAM? PREMIAM across the UK Administrations and Civil Contingencies • PREMIAM delivers overall game plan but….. – Differences in how to adopt across UK Administrations – PREMIAM position with civil contingency committees – leading shoreline operations – Issues of funding and cost recovery across the Admins? – Incident affecting 2 or more Administrations – Coordination Management? – Wales EIA to sit with SEG – Each Administration wishes to maintain overall control – Opportunity to explore ways to resolve, deconflict here at Conference Funding and Cost recovery • Initial funding agreed for England – other administrations? • Establishment of “reasonableness” for EIA • View of all potential funding orgs – including P and I Clubs wrt initiating funding for EIA • View of Govt may differ from P and I? • Who decides reasonableness wrt cost recovery? Both before initiation of PREMIAM and during the project? • Where is the shortfall picked up? • Will risk of shortfall influence the EIA scope? • Again… Across the Administrations Funding and Cost Recovery • Not all spills require EIA as automatic • Success rate of EIA cost recovery not always good • Studies fundamentally fully appropriate and proportionate • Documentation quality and appropriateness • Repetition of work already carried out? • Nature and extent of env damage all covered • EIA sufficiently objective? • No formal guarantees wrt quality and objectiveness Exercising PREMIAM • MCA involved with many Spill exercises • Some major exercises may be useful test for PREMIAM – – – – – Cross border working Central management mix with local expertise Response Cells interaction with PREMIAM EG and PREMIAM Exercise DRAGON – Liverpool Bay, Sept 2014? Considerations…. • • • • PREMIAM and the NCP EG protocols NCP words STOp Notice words Involvement of compensation bodies in EIA design • Administrations definition of reasonableness • Cross Administration adoption of PREMIAM Contact details: Kevin Colcomb MCA - Counter Contact details:Pollution & Salvage Tel: +44(0)2380 329411 • Kevin Colcomb e-mail: [email protected] Thank you for your attention • MCA - Counter Pollution & Response • Tel: +44(0)2380 329411 • e-mail: [email protected] • MCA web site: www.mcga.gov.uk – for UK National Contingency Plan – Environment Group STOp notice MCA web site: www.dft.gov.uk/mca/ – Shoreline Response Centre STOp notice • UK National Contingency Plan • Environment Group STOp notice