Facility Response Plans

On July 28, 2015, the National Wildlife Federation (NWF) informed the U.S. Department of Transportation (DOT) of its intent to sue for violations of the Clean Water Act (CWA) § 311(j) and Executive Order 12777 (which guides federal implementation of the Oil Pollution Act of 1990).
Continue Reading Environmental Group Threatens To Sue U.S. Department of Transportation Over Spill Response Plans

Amidst public scrutiny regarding onshore oil pipeline facility response plans (FRPs) and an outstanding statutory mandate to make those plans public, PHMSA issued an Advisory Bulletin regarding FRP requirements at 49 CFR Part 194.  In the Advisory, PHMSA confirms that it will make FRPs publicly available and recommends that operators consider U.S. Coast Guard (USCG) oil spill response regulations when complying with Part 194.
Continue Reading Oil Spill Facility Response Plan Advisory: Plans to be Made Public Increased Reliance on USCG Regulations