Guidelines on implementing spill impact mitigation assessment (SIMA)

Transcription

1 Guideines on impementing spi impact mitigation assessment (SIMA) A technica support document to accompany the IPIECA-IOGP guidance on net environmenta benefit anaysis (NEBA) Oi spi preparedness THE GLOBAL OIL AND GAS INDUSTRY ASSOCIATION FOR ENVIRONMENTAL AND SOCIAL ISSUES

2 IOGP Report 593 IPIECA-API-IOGP 2017 A rights reserved. No part of this pubication may be reproduced, stored in a retrieva system, or transmitted in any form or by any means, eectronic, mechanica, photocopying, recording or otherwise, without the prior consent of IPIECA-API-IOGP. Cover photographs reproduced courtesy of the foowing: top eft, bottom eft and bottom centre: Pixabay.com (reproduced under Creative Commons CC0 1.0 Universa); centre: Petronia Consuting Limited. This pubication has been deveoped to support the impementation of IPIECA s, API s and IOGP s mission and vision. Whie every effort has been made to ensure the accuracy of the information, it is intended to provide genera guidance ony. It is not designed to provide ega or other advice, nor shoud it be reied upon as a substitute for appropriate technica expertise or professiona advice. A attempts have been made to ensure the information is correct at of the date of pubication. This pubication does not constitute a mandatory commitment which members of IPIECA, API or IOGP are obiged to adopt. The views and concusions expressed herein do not necessariy refect the views of a IPIECA, API or IOGP members or the individuas, companies and institutions that contributed to this pubication. Whie reasonabe precautions have been taken to ensure that the information contained in this pubication is accurate and timey, this pubication is distributed without warranty of any kind, express or impied. Neither IPIECA, API nor IOGP endorses or accepts responsibiity for the content or avaiabiity of any website referred to, or inked to, in this pubication. The responsibiity for the interpretation and use of this pubication ies with the user and in no event wi IPIECA, API or IOGP or any of their members past, present or future regardess of their negigence, assume iabiity for any foreseeabe or unforeseeabe use made thereof, which iabiity is hereby excuded. Consequenty, such use is at the recipient s own risk on the basis that any use by the recipient constitutes agreement to the terms of this discaimer. This discaimer shoud be construed in accordance with Engish aw. Acknowedgements This document was prepared under contract by Peter Tayor (Petronia Consuting Limited) under the supervision of an IPIECA-API-IOGP member taskforce. The additiona contributions of Marty Cramer (ConocoPhiips) are gratefuy acknowedged.

3 Guideines on impementing spi impact mitigation assessment (SIMA) A technica support document to accompany the IPIECA-IOGP guidance on net environmenta benefit anaysis (NEBA) The goba oi and gas industry association for environmenta and socia issues 14th Foor, City Tower, 40 Basingha Street, London EC2V 5DE, United Kingdom Teephone: +44 (0) E-mai: info@ipieca.org Website: The American Petroeum Institute 1220 L Street NW, Washington, DC , USA Teephone: Website: Internationa Association of Oi & Gas Producers Registered office 14th Foor, City Tower, 40 Basingha Street, London EC2V 5DE, United Kingdom Teephone: +44 (0) E-mai: reception@iogp.org Website: Brusses office Bouevard du Souverain 165, 4th Foor, B-1160 Brusses, Begium Teephone: +32 (0) E-mai: reception@iogp.org Houston office Westheimer Road, Suite 1100, Houston, Texas 77042, United States Teephone: +1 (713) E-mai: reception@iogp.org

4 Contents About this report 3 Section 1: Introduction 5 SIMA process summary 7 Who is invoved in the SIMA? 8 When SIMA might be used 9 Pre-spi panning 9 Incident response 10 Section 2: The SIMA process 11 Stage 1: Evauate data 12 Defining the scenario 12 Determining potentia response options 13 Stage 2: Predict outcomes 14 Determining resource compartments 15 Assessing the potentia reative impact 15 Predicting the effectiveness and impact 16 modification potentia of the various response options Stage 3: Baance trade-offs 17 Aocating the impact modification factors 17 Determining the tota impact mitigation 18 scores and ranking of response options Gossary 23 References and further reading 27 References 28 Further reading 29 Appendix 1: Reative impact eves 32 Impact rankings and threshods 32 Ranking resource impacts 32 Water coumn impacts 33 Water surface impacts 34 Shoreine impacts 34 Socio-economic and cutura impacts 34 Appendix 2: Impact modification factors 36 Appendix 3: Exampes of comparative matrices 38 Marine termina reease 39 Subsea offshore reease 40 Tanker reease 41 Shoreine oiing 42 Stage 4: Seect best response options 20 Documenting the SIMA 21 Reguatory issues 22 2 Guideines on impementing spi impact mitigation assessment (SIMA)

5 About this report The term net environmenta benefit anaysis and its acronym, NEBA, have been used extensivey over the years. It describes a process used by the oi spi response community for guiding seection of the most appropriate response option(s) to minimize the overa impact of spis on the environment and other shared vaues. In 2015, IPIECA and IOGP jointy pubished a Good Practice Guide (GPG) that conceptuay describes the incorporation of NEBA into oi spi response strategy deveopment (IPIECA-IOGP, 2015a). In the wake of this pubication, the deveopment team fet that a more detaied how to guideine was aso required, and has cooperated with the American Petroeum Institute (API) to produce this report. Concurrenty, the oi and gas industry began a debate on the appropriate use of the acronym, NEBA. Given that the seection of the most appropriate response action(s) has in practice been guided by more than just environmenta considerations, the industry is seeking to transition to a term that better refects the process, its objectives, and the suite of shared vaues which shape the decisionmaking framework, incuding ecoogica, socio-economic and cutura aspects. Industry has consuted directy with non-industry stakehoders who have expressed support for transitioning to a more appropriate term. The oi and gas industry is thus introducing the term spi impact mitigation assessment (SIMA) as a repacement for NEBA. The industry recognizes that the transition from NEBA to SIMA wi take some time, but beieves that it is important to begin the process of more accuratey describing this ong-standing practice and its objectives. For the purposes of this document, a references to SIMA shoud be understood to mean NEBA in its broader context. At appropriate points in time, other pubications wi be updated to repace the term NEBA with SIMA. The aim is that other stakehoders wi adopt a simiar approach to institutionaize this more accurate and descriptive term over time. 3 Guideines on impementing spi impact mitigation assessment (SIMA)

6 This page is intentionay bank

7 Section 1 Introduction OSRL The spi impact mitigation assessment (SIMA) process has been deveoped to hep faciitate the seection of the most appropriate response options to effectivey combat an oi spi. 5 Guideines on impementing spi impact mitigation assessment (SIMA)

8 Section 1 Introduction Minimizing the ecoogica, socio-economic and cutura impact of an oi spi through the deveopment of a safe and effective response strategy is the primary aim of those responsibe for contingency pans and incident management. Strategy is defined as the utiization of a singe response option, or combination of options, to effectivey combat an oi spi. The seection of the most appropriate response option(s) typicay invoves the consideration of various factors and trade-offs, which can be compicated and overwheming. Therefore, a structured spi impact mitigation assessment (SIMA) process has been deveoped to hep faciitate response option seection and support strategy deveopment. The SIMA process is described in this document and was informed by the 2015 IPIECA-IOGP GPG on oi spi response strategy deveopment using NEBA (IPIECA-IOGP, 2015a). In some jurisdictions, the oi spi response strategy is argey determined or prescribed by nationa poicy, reguation or guidance. In others, the operator of the individua asset or activity is required to deveop a strategy that minimizes oi spi impacts. For the atter, the SIMA process described in this document can be used to identify and compare the potentia effectiveness and coatera impacts of candidate response options, enabing a quaitative and transparent determination of the most appropriate strategy. For the former, this SIMA process can simiary be used to dispute prescriptive or predetermined response strategies if the operator beieves aternative strategies are more protective of the environment. Given the broad range and scae of oi spi panning scenarios, diverse perceptions of the vaue of ecoogica, socio-economic and cutura sensitivities and the innate reaities of oi spi response fied operations, no singe SIMA methodoogy is suitabe, or indeed appropriate, for appication in a situations. It is important to note that the SIMA process described herein is primariy appicabe to arger or higher consequence oi spi incidents or scenarios where mutipe spi response options are being considered. For smaer, ower consequence spis where ony one or two response options are contempated or feasibe, a forma SIMA is generay not warranted. Beow: it is essentia that a personne engaged in cean-up activities observe the necessary safety requirements and are equipped with appropriate persona protective equipment. Safety first Protecting the heath, safety and wefare of responders and the oca community underpins the consideration of a response activities. Operations shoud have due regard for the safety of responders in carrying out depoyments, and for the potentia exposure of both response personne and the wider pubic to spied oi and associated hazards. There are situations where the safety benefits or concerns associated with a response option may become the dominant driver of strategy deveopment. If a response option coud not be safey undertaken in the context of a particuar scenario, it woud not be considered feasibe and woud therefore be excuded from that scenario s SIMA. OSRL 6 Guideines on impementing spi impact mitigation assessment (SIMA)

9 Section 1 Introduction Additionay, in actua incidents where response strategy decisions must be made under time-constraints, an abbreviated SIMA process may be required that reies primariy or soey on the best avaiabe professiona judgement/expert opinion. An abbreviated SIMA may generay foow the process described herein, or a different process, depending on the incident s circumstances. The methodoogy described in this document has the potentia to be used within any nationa framework. SIMA PROCESS SUMMARY The SIMA process is described in detai in Section 2 but can be summarized in four stages: 1. Compie and evauate data for reevant oi spi scenarios incuding fate and trajectory modeing, identification of resources at risk and determination of feasibe response options. 2. Predict outcomes/impacts for the no intervention (or natura attenuation ) option as we as the effectiveness (i.e. reative mitigation potentia) of the feasibe response options for each scenario. 3. Baance trade-offs by weighing and comparing the range of benefits and drawbacks associated with each feasibe response option, incuding no intervention, for each scenario. 4. Seect the best response option(s) to form the strategy for each scenario, based on the combination of techniques that wi minimize the overa ecoogica, socio-economic and cutura impacts and promote rapid recovery. NOTE: The use of SIMA for more than one scenario is ony appicabe during contingency panning. In a rea incident there wi ony be one reease scenario, i.e. the actua spi, for which this SIMA or a simiar process wi be used. This SIMA methodoogy is not a process that quantifies the potentia impacts of an oi spi. Rather, it assesses the reative impact mitigation potentia of candidate response options, to choose those that wi most effectivey minimize the overa consequences of a spi. A SIMA wi often incude a ist of sensitive ecosystems and areas considered vunerabe to impacts, such as shoreines. The guideines in this document focus primariy on the Predict outcomes and Baance trade-offs stages of a SIMA, as they are generay the most compex and are often emotive within the wider community due to misunderstandings about the effectiveness of response options and potentia drawbacks. There may aso be differing or conficting stakehoder opinions of the reative vaue of ecoogica, socio-economic or cutura resources at risk. SIMA provides a transparent framework to consider and baance these vaues as we as the consequentia trade-offs of using the feasibe response options recognizing their potentia benefits, imitations and drawbacks compared to no intervention. Figure 1 on page 8 identifies the four stages of SIMA and summarizes their primary components. OSRL 7 Guideines on impementing spi impact mitigation assessment (SIMA)

10 Section 1 Introduction Figure 1 Summary of the SIMA methodoogy described in this report WHO IS INVOLVED IN THE SIMA? SIMA presents the opportunity, within imits depending on the context, to buid consensus-based response strategy among industry, government authorities and key stakehoders from the wider community. The personne who may be activey invoved in the SIMA, or be consutees, wi vary greaty depending on the spi scenario circumstances and ocaity. Where SIMA is undertaken in support of contingency pans, a variety of subject matter experts (SMEs) may be engaged in the process (e.g. modeers, environmenta and other speciaists, and experienced responders). Consutations may aso take pace with key representatives of potentiay affected stakehoder groups (e.g. fishing, tourism and oca community) and reevant authority representatives, incuding reguators and resource trustees (e.g. nature conservation agencies). The specific make-up of the peope invoved in the diaogue wi depend on the spi scenarios, the oca setting and the ecoogica, socioeconomic or cutura resources threatened. Shoreine sensitivity assessment exercise in the UK as part of an effort to deveop a shoreine response strategy. OSRL 8 Guideines on impementing spi impact mitigation assessment (SIMA)

11 Section 1 Introduction ITOPF IPIECA Oi spi incidents often attract significant interest from the media and the pubic; those directy affected by a spi shoud be prompty and propery informed. Shoreine sensitivity assessment being carried out in Tanzania during a sensitivity mapping workshop supported by IMO/IPIECA and managed by the Tanzanian Nationa Environment Management Counci. Where possibe, appropriate stakehoder groups shoud be consuted over the identification of resources at risk to hep assess the reative potentia for impacts from a spi. The wider community is aso ikey to have an active interest in how the abiity of each response option to modify impacts and promote recovery is determined. The engagement of stakehoder group representatives in choosing response options has been practiced through panning approaches such as the Consensus Ecoogica Risk Assessment (Aurand et a., 2000), with which the methodoogy described herein is aigned. In the case of incident response SIMAs carried out during actua spis, the group of peope invoved is ikey to be streamined due to time constraints and consist of a sma cohort of SMEs. The SIMA process wi be undertaken through the existing emergency management structure and wi consider stakehoder and community concerns to the extent practicabe. Aignment and iaison with authorities may be required, where the response is ed by an industry team, but a diaogue and decision making wi need to be expedited. The dynamic nature of incidents is such that undue deays coud resut in both a SIMA s concusions and the resuting strategic decisions having itte practica vaue. WHEN SIMA MIGHT BE USED The SIMA process can be used during pre-spi panning and/or incident response as foows: Pre-spi panning When SIMA is used during the contingency panning process, it provides an unhurried, consensus-based approach incorporating diaogue with reevant stakehoders. SIMA conducted during contingency panning not ony deveops the most effective response strategy for each panning scenario; it aso heps to determine the subsequent provisioning of suitabe response equipment and supporting ogistics. The SIMA process brings transparency and credibiity by documenting and demonstrating how potentia response options have been anaysed and incorporated into each strategy. This faciitates community/stakehoder engagement and heps set reaistic expectations for the effectiveness of response options. Further information and guidance on contingency panning is avaiabe in the IPIECA-IOGP GPG entited Contingency panning for oi spis on water (IPIECA-IOGP, 2015b) and the API Guidance on offshore oi spi response pans (API, 2013). 9 Guideines on impementing spi impact mitigation assessment (SIMA)

12 Section 1 Introduction Incident response For responses to incidents where a scenario is covered by contingency pans that incorporate SIMA as described above, the foowing process can be used: Seect the panning scenario that most cosey matches the incident circumstances, aong with its associated response strategy, as a starting point. Vaidate or adjust as needed the assumptions and considerations used in the panning SIMA to account for actua incident conditions (this can be a dynamic use of SIMA throughout the response). Confirm the appicabiity of the pre-determined response strategy or adjust as necessary. For some incidents, parameters may not match a scenario where a SIMA was competed as part of the contingency panning process (e.g. a passing shipping casuaty). To avoid deays that may resut in greater impacts, an abbreviated version of the process outined in this document can be foowed. This wi generay invove reduced reiance on stakehoder consutation and empirica data aong with a greater reiance on expert opinion and professiona judgement whie maintaining the same SIMA principes. Unike the more consensus- oriented SIMA undertaken during contingency panning, the process is ikey to be embedded into the emergency response and impemented through an incident management system. In abbreviated cases, as the incident progresses, subsequent cyces of the SIMA process can incorporate data derived from monitoring the effectiveness of chosen response options and from sources either unknown or unavaiabe in the previous stages. The amount of stakehoder engagement aso increases and becomes more forma. As the resoution of the SIMA increases, further ayers of detai are created and the response strategy is adjusted. 2012MediaBakery OSRL In-situ burning is just one of a variety of potentia at-sea response options that may be identified for incusion in the contingency pan during the SIMA process. When responding to an offshore incident it is essentia to remember that high seas conditions have the potentia to present a significant hazard to vesse operations. 10 Guideines on impementing spi impact mitigation assessment (SIMA)

13 Section 2 The SIMA process This section describes the four stages of the SIMA process: Stage 1: Evauate data Stage 2: Predict outcomes Stage 3: Baance trade-offs Stage 4: Seect best response options USDA 11 Guideines on impementing spi impact mitigation assessment (SIMA)

14 Section 2 The SIMA process STAGE 1: EVALUATE DATA Defining the scenario It is fundamenta practice within contingency panning to identify a suitabe seection of credibe potentia accidenta oi reease scenarios. In accordance with the tiered response approach, panners aim to define a group of scenarios that coectivey represent the range of spi risks and response chaenges for a particuar asset or operation. Typicay, ony a worst credibe case discharge wi be considered; this ensures that adequate response capabiities are avaiabe across a response tiers and are abe to dea with the risk assessment s most significant event. Smaer event scenarios may aso be chosen to refine response capabiities and tactics at ower response tiers. Additionay, for operators with mutipe faciities, assets or operations in a reativey sma area, a singe scenario or set of scenarios may be deveoped that is representative of a potentia sources in the area. Further information on scenario panning is avaiabe in IPIECA-IOGP, 2013a. Incident and oi information A number of parameters define each panning scenario: ocation; oi type and properties; voume of reease; duration of reease; and prevaiing hydrodynamic and metroogica conditions. For some ocations it may be suitabe to consider separatey the same reease parameters at different times of year or seasons. Oi fate and transport Oi fate and trajectory modeing, incorporating the above parameters, is typicay used to identify the potentia geographica area of impact for each chosen scenario. Stochastic (or probabiistic) modeing is particuary usefu for SIMA, as it uses hydrodynamic and historica meteoroogica data to provide ikeihoods of particuar areas being oied. Stochastic modeing can aso be used to identify coasta areas with a greater ikeihood of being impacted by significant quantities of oi. The baseine for modeing is the no Intervention case (aso caed natura attenuation), in which no response actions are undertaken. Deterministic (singe run) modeing can, if conducting a more quantitative SIMA, aso be used to predict the migration path of the foating oi, its surface thickness, inwater oi concentrations and/or shoreine oiing (time to shoreine and extent of oiing) for a specific spi scenario, under a specific set of prevaiing conditions. This can support a SIMA s stochastic outputs or be used for predictions during incident response. In both cases, time to shoreine impact is hepfu for determining the feasibiity of impementing shoreine protection measures prior to impact and/or possibe ocations for response capabiity. Identification of resources at risk Oi spis have the potentia to impact a variety of ecoogica, socio-economic and cutura resources. These resources may have varying degrees of sensitivity to oi spis and vaue to the oca community. Information on sensitive resources and their ocations is typicay found in the iterature and may have been consoidated within environmenta and socia impact assessments (ESIAs) and oi spi sensitivity mapping projects. Input from the oca community is generay required to identify their most vaued resources. Further information on identifying and mapping sensitive resources for oi spi panning and response purposes can be found in the IPIECA-IMO-IOGP Good Practice Guide entited Sensitivity mapping for oi spi response (IPIECA-IMO-IOGP, 2012). Oi spi trajectory modeing is used in conjunction with sensitive resource maps to identify the ocations and resources that are at risk of being impacted, or are vunerabe to impacts, for each scenario. In some cases, resources may be isted in the SIMA even if there is itte or no ikeihood of their becoming oied. 12 Guideines on impementing spi impact mitigation assessment (SIMA)

15 Section 2 The SIMA process This wi either be because the oca community needs reassurance that the resource has been considered due to its perceived high vaue, or because another scenario may be under consideration which risks impacting the resource. Note that a resource may be sensitive to oi impacts but it may not be vunerabe. The atter takes into account possibe exposure pathways, i.e. whether a resource is ikey to be affected by spied oi. Ecoogica resources are often assessed at the broad habitat eve (rather than at the species eve), and socioeconomic and cutura resources assessed in simiary broad compartments (for exampe maritime recreation, commercia fishing and tourism can be combined into the socio-economic compartment) rather than evauating each component individuay. Where there are particuar concerns about specific resources (e.g. endangered species, important breeding areas or sites of widife aggregations), these can be incuded coectivey in the high vaue resource compartment, or may contribute individuay to the SIMA process. However, increasing the compexity of the SIMA can become timeconsuming; anaysing resources at greater detai shoud ony be undertaken when it is reiaby expected to bring significant change to the SIMA s outcome and ater strategy deveopment. The ist of agreed resource compartments wi be sefevident within the SIMA matrix. However, it is usefu to summarize discussions that took pace concerning the diaogue to reach agreement, incuding the organizations invoved. This information can be annexed to the SIMA matrix as part of the supporting documentation. Determining potentia response options The potentia at-sea response options are typicay: no intervention (natura attenuation); on-water containment and recovery; subsea dispersant injection; surface dispersant appication; controed in-situ burning; and shoreine booming (used as anchored excusion, diversion or defection barriers). These options shoud be evauated against each scenario s incident circumstances (oi type, voume and characteristics, prevaiing wind and wave conditions, avaiabe ogistica support, etc.) to determine their depoyment feasibiity. A shortist of the feasibe response options is then prepared for each scenario and carried forward in the SIMA process. It is emphasized that the at-sea response strategy is ikey to comprise a suite of the avaiabe options, depoyed variousy at different ocations and times through the incident. The SIMA assists in prioritizing which options to use where and when. It does not automaticay ead to choosing one option with the mutua excusion of others. Separate SIMAs may be conducted for shoreine ceanup and possiby shoreine protection operations. These are inherenty different from the other on-water response options, and it may be necessary to address specific questions within a particuar scenario, i.e. which techniques shoud be used at a specific beach or sensitive area. In these cases, the response options wi be adjusted to incorporate the most appropriate techniques, with the SIMA methodoogy otherwise remaining the same. Existing pubished guidance can be used when assessing the ways in which different shoreine ceanup techniques can mitigate impacts across the range of different shoreine types (NOAA, 2010; POSOW, 2013). The SIMA methodoogy can aso be used for freshwater or inand spi scenarios wherein a different set of response options woud be evauated. ITOPF Oi spis have the potentia to impact a variety of ecoogica, socio-economic and cutura resources, such as this aquacuture site, which may be especiay sensitive to smothering and oi toxicity. 13 Guideines on impementing spi impact mitigation assessment (SIMA)

16 Section 2 The SIMA process STAGE 2: PREDICT OUTCOMES The next stage in the SIMA process is to predict the outcomes i.e. the reative impacts on resources at risk for each scenario, using the no intervention case as a baseine. The feasibe response options are then evauated, based on the extent to which they mitigate, exacerbate or do not ater the no intervention outcome. Athough each response option may individuay ater the outcome to varying degrees, no singe option is ikey to be fuy effective. Combinations of different options, utiized in different geographic ocations and possiby at different times are usuay necessary. The comparative matrix shown beow can be used to faciitate the evauation of individua candidate response options; it is not feasibe to aggregate the outcomes of mutipe options using this methodoogy. It may be beneficia to engage reevant stakehoders at this stage of the process, though it is more usua to undertake this during the next stage Baancing trade-offs. A hypothetica offshore surface oi spi has been used to deveop the exampe matrix shown in Figure 2. The use of subsea dispersant is not, therefore, feasibe for this scenario. Figure 2 The formuation of a comparative matrix used to faciitate the evauation of candidate response options for a surface spi The orange abes denote the different processes invoved in buiding the matrix each process is discussed in detai on the foowing pages. 14 Guideines on impementing spi impact mitigation assessment (SIMA)

17 Section 2 The SIMA process The processes invoved in constructing the exampe matrix shown in Figure 2 incude: 1. Determining resource compartments. 2. Assessing the potentia reative impact. 3. Predicting the effectiveness and impact modification potentia of the various response options. This predictive process provides the basis for the aocation of the impact modification factors for each response option and resource compartment combination during the next stage. 4. Aocating the impact modification factors. 5. Determining the tota impact mitigation scores and ranking of response options. These five points are discussed in detai beow and under Stage 3: Baance trade-offs on pages They are individuay abeed on Figure 2 for easy reference. Determining resource compartments It is recommended that the foowing resource compartments are incuded in the matrix for this scenario (note that these compartments may be amended or expanded as discussed under Assessing the potentia reative impact, beow): Seabed reativey deep water so no benthic impact expected. Water surface considerabe foating oi is present aong with a moderate number of seabirds and marine mammas being threatened. Water coumn minima naturay-dispersed oi in the water coumn and few sensitive aquatic receptors present in the area. Air moderate concentrations of VOCs in the air above the sicks, which poses a potentia threat to responders and marine mammas and birds. Shoreines significant shoreine oiing is anticipated which incudes severa environmentay-sensitive marshes and estuaries. High vaue resources high amenity sand beach near town is not environmentay sensitive but is of particuar importance to the sma oca community. Socio-economic significant oiing of boat harbour is anticipated. Cutura no cutura or historica resources are present. Figure 3 on page 16 shows the initia deveopment of the comparative matrix, incorporating the above resource compartments, Assessing the potentia reative impact The initia task in SIMA Stage 2 the Predict outcomes stage is to assess the impact of the no intervention option for each panning scenario. This serves as the reference or base case, against which the benefits or drawbacks of the candidate response options are assessed. Drawing on the data compied in SIMA Stage 1 Evauate data the reative eves of impact of each spi scenario s no intervention option on ecoogica, socio-economic and cutura resources at risk are determined. Broad resource compartments (as discussed previousy) are preferred and generay provide adequate detai for a SIMA. Compex scenarios coud require further breakdown and evauation of additiona compartments. Where a scenario has the potentia to impact specific resources which may be of particuary high ecoogica significance or vaue to the affected community, these resources can be combined under the high vaue resources compartment to faciitate additiona consideration in the comparative matrix. Aternativey, they can be isted as sub-compartments under the high vaue resources compartment, or under an associated genera resource compartment. However, if mutipe individua resources/sub-compartments are isted under one of the genera resource compartments, their reative impact and impact mitigation rankings/scores shoud be averaged to avoid the tota impact mitigation scores being disproportionatey biased toward those resources. For most SIMAs, reative impact eves of none to insignificant (short form none ), ow, medium and high may be used. Compex scenarios may assign more refined eves (e.g. none, ow, medium, high, extreme) or may use more quantitative metrics. Additiona eves shoud ony be considered where there is a reiabe expectation that this refinement wi make a significant change to the SIMA s outcome, i.e. if doing so woud resut in a materia ateration to strategy deveopment. A further discussion of how reative impact eves may be assigned can be found in Appendix 1. It is usefu to summarize saient factors reating to assessment of potentia reative impacts, incuding any use of the techniques described in Appendix 1. This becomes an integra part of the SIMA documentation process. 15 Guideines on impementing spi impact mitigation assessment (SIMA)

18 Section 2 The SIMA process The reative impact eves are then aocated a score (coumn A in Figure 3). These may be scores of 1, 2, 3 and 4 for none, ow, medium and high impact, respectivey. If there is significanty eevated concern for resources that experience greater impacts, it may be preferred to weight the scores of the higher impact eves, for exampe increasing the medium and high impacts scores to 4 and 6, respectivey. Predicting the effectiveness and impact modification potentia of the various response options A preiminary prediction is made of how each feasibe response option wi modify the impact when compared with the no intervention case. This invoves consideration of the probabe effectiveness of each response option. Effectiveness shoud be considered in the context of the specific scenario and each resource compartment s exposure routes. It is a function of various factors, incuding the oi type, weathering and spi voume, sea state, encounter rate (i.e. the rate at which a response option can treat spied oi) and ogistica considerations. These are discussed further in Appendix 2, where the isted benefits of a response option tend to incude the factors eading to higher effectiveness and, conversey, the isted drawbacks reduce it. This preiminary prediction provides the basis for the aocation of impact modification factors for each response option and resource compartment combination during the next stage (see the foowing page). In some cases, it may be beneficia to identify preiminary or draft impact modification factors as a starting point, prior to engaging with reevant stakehoders during the baance trade-offs stage. Figure 3 Assembing the comparative matrix begins with the incusion of the seected resource compartments; a potentia reative impact and associated score is then assigned to each resource in the case of no intervention 16 Guideines on impementing spi impact mitigation assessment (SIMA)

19 Section 2 The SIMA process STAGE 3: BALANCE TRADE-OFFS Aocating the impact modification factors An impact modification factor is used to indicate the degree to which the no intervention impacts are atered by each response option. Figure 4 shows the impact modification factors now added to the comparative matrix in coumns B1, B2, B4 and B5. If a response option mitigates the impacts on a particuar resource compartment, then a positive number is entered. Conversey, if the response option exacerbates the impacts or creates a new impact, a negative number is entered. These numbers refect the degree of impact modification according to Tabe 1, i.e. if the degree of change reative to no intervention is minor, moderate or major then a positive or negative 1, 2 or 3 is entered, respectivey. Impact modification factors are further discussed in Appendix 2. Tabe 1 Impact modification factors IMPACT MODIFICATION FACTOR DESCRIPTION Major mitigation of impact Moderate mitigation of impact Minor mitigation of impact No or insignificant ateration of impact Minor additiona impact Moderate additiona impact Major additiona impact Depending on the anticipated eve of stakehoder engagement, it may be appropriate to canvass their inputs at this point in the process. This coud hep avoid protracted discussions with stakehoders ater in the process. Figure 4 Deveopment of the comparative matrix continues with the addition of the impact modification factors these are now incuded in coumns B1, B2, B4 and B5 17 Guideines on impementing spi impact mitigation assessment (SIMA)

20 Section 2 The SIMA process It usefu to summarize diaogue reating to the aocation of impact modification factors. This may incude reference to how the operationa and technica benefits and drawbacks of response options were aocated. In some cases, there may be technica features of a response option that are not intuitive and require expanation. For exampe: (1) burning fresh oi can destroy voatie compounds that woud otherwise present an air poution hazard, and woud need to be baanced against the creation of a visibe smoke pume; and (2) chemicay dispersed oi dropets may be ess ikey to adhere to suspended sediment, compared to naturay dispersed ones. The summary woud aso note the organizations invoved in the discussions, and woud form part of the SIMA documentation process. Determining the tota impact mitigation scores and ranking of response options The potentia reative impact score (coumn A in the exampe matrix) for each resource compartment under the no intervention option is mutipied by the associated impact modification factor for each response option (coumns B1, B2 etc.) to create a reative impact mitigation score for each combination of resource compartment and response option. These scores are entered in coumns A x B1, A x B2, A x B4 and A x B5 of the matrix (see Figure 5) and represent the reative change that each response option is ikey to have in the eve of impact on each resource. Since the reative impact mitigation score is derived from a quaitative ranking of impacts, the score shoud not be taken as a quantitative measure of impact. It is recommended that scores are rounded to units in cases of averaging (such as the shoreines and socio-economic rows in Figure 5. Figure 5 The reative impact mitigation scores are cacuated and entered in the matrix (coumns AxB1, AxB2, AxB4 and AxB5); a coour scheme may aso be introduced to provide a visua reference for the reative scores of impact mitigation (see egend above) 18 Guideines on impementing spi impact mitigation assessment (SIMA)

21 Section 2 The SIMA process To provide a visua reference of the potentia impact mitigation associated with each response option, and to emphasize that the process is not quantitative, users of the matrix may wish to adopt a coour code for the reative scores of impact mitigation. This provides an intuitive scae of impact mitigation, from major impact mitigation (dark green) through to major impact increase (red): Figures 5 (page 18) and 6 (beow) show how such a coour scheme woud be appied to the reative impact mitigation scores in the matrix. The scores for each response option are then totaed at the base of the matrix, as shown in Figure 6. These totas are quaitative predictions of the degree to which each option mitigates the scenario s overa impact (i.e. compared to no intervention). The tota scores can then be used to rank the reative abiity of each response option to mitigate impacts and enhance recovery. This ranking promotes an objective comparison of the options when baancing trade-offs. It is important to note that the tota scores do not have a direct mathematica reationship (i.e. a score of +20 does not mean an option wi achieve twice the mitigation as one scoring +10). Totas shoud ony be used for comparative purposes within each specific SIMA. Furthermore, the ecoogicaybased compartments outnumber the socio-economic and cutura ones in the exampe given. This skews the tota towards ecoogica concerns. In many scenarios this may be appropriate but it shoud be taken into account when interpreting the matrix to seect the best response options. Figure 6 Finay, the reative impact mitigation scores are totaed aong the base of the matrix for each response option to provide a ranking of the abiity of each response option to mitigate impacts and enhance recovery 19 Guideines on impementing spi impact mitigation assessment (SIMA)

22 Section 2 The SIMA process The baancing of trade-offs can be the most contentious eement of the SIMA. Diverse or conficting opinions may arise concerning a mutitude of questions surrounding the importance of impacts on differing resources, such as fisheries versus tourism, shoreines versus water coumn or widife versus community recreation. SIMA aims to mitigate the overa impacts of the spi, and this invoves baancing the trade-offs of impacts between the various resources. A fundamenta principe is that if a response option increases the impact on a resource, it wi ony be depoyed if this impact is more than outweighed by the mitigation of the impacts on other resources. The reative impact mitigation scores generated previousy aready incorporate the reative benefits and drawbacks of each option and, as such, shoud precude the need to further baance trade-offs. This is particuary true if the concerns and vaues of potentiay affected stakehoders were incorporated in the Predict outcomes process (SIMA Stage 2). In some cases, additiona diaogue may be needed with key stakehoders and government authorities to better expain the trade-offs aready incorporated into the comparative matrix, or to obtain new inputs on resource sensitivities or vaues. This wi either vaidate the outcomes or may ead to reevauation and adjusting the inputs to the matrix. Pressures can aso be fet, both during contingency panning and during the course of an incident, to either undertake or avoid certain response options. Such pressures are ikey to be driven by pubic perceptions and poitica considerations, rather than technica understanding. Typicay, they resut in cas for actions that may be unreaistic, such as the excessive use of shoreine protection booms, possiby in areas not under threat from spied oi, and an anti-dispersant or anti-burning position that is not based on factua considerations of the abiity of these options to mitigate the overa impacts. SIMA is designed to hep overcome these perceptions by presenting a transparent case for appropriate and technicay vaid response options, through the baancing of trade-offs. The comparative matrix provides a transparent representation and record of how resources and response options have been assessed and prioritized. can then be used to determine whether, and to what extent, inputs to the matrix (e.g. amendments to either the potentia reative impact or the impact modification factors) need to be atered to adequatey address each concern. In some cases, additiona resource compartments or individua resources may need to be added to the matrix and evauated/scored in the same manner as the others. STAGE 4: SELECT BEST RESPONSE OPTIONS The finaized comparative matrix deveoped in the Baance trade-offs stage is used to objectivey seect the best response option(s) to be impemented for each scenario. This generay invoves seecting the option or options with the argest impact mitigation score. In some cases, the choice may be obvious whie others may require further diaogue between the invoved parties, as described previousy for the Baance trade-offs stage. The proposed depoyment of chosen options can be described in various ways. An approach bringing carity to the tactica optimization and impementation of strategy is the concept of operations (see Figure 7 on page 21), indicating zones or ocations where specific response options are to be used (e.g. at the source, in the vicinity of an offshore reease, further from reease in open waters, nearshore and shoreine) and when they are ikey to be depoyed. Diaogue with stakehoders can be emotive, so maintaining objectivity must be emphasized. The discussions shoud be pragmatic and initiay focus on the reative significance of any stakehoder s concerns raised by the matrix s outputs. The resuts of those discussions Dispersant spraying from a vesse-mounted spraying arm. OSRL 20 Guideines on impementing spi impact mitigation assessment (SIMA)

23 Section 2 The SIMA process Figure 7 Optimized response options sometimes referred to as the concept of operations In the exampe scenario represented by the matrix on the previous pages, the surface dispersant option receives the argest mitigation score (+32) and woud be expected to provide the greatest reduction in the overa impact on resources at risk. The strategy woud therefore egitimatey consider surface dispersants as the primary response too. In the concept of operations, dispersants woud be used to treat the spi where the oi is fresh and forms reativey coherent sicks i.e. cose to the source to maximize effectiveness and minimize net impacts. The remaining response options woud be positioned to remove oi that may escape dispersant treatment and migrate beyond the appication area. This woud incude protecting sensitive areas shoud any remaining oi threaten nearby shoreines. The tactica practicaities of where these other options might be effectivey depoyed woud need consideration by contingency panners or incident managers during strategy deveopment. Once a scenario s strategy is defined in space and time, the panning process serves to identify the equipment, trained personne, ogistics and incident management system that wi be required to impement the reevant tactics and operations. This wi be integrated within the tiered preparedness and response mode to ensure timey and effective capabiity that is commensurate to the risk and can evove to meet an incident s needs (IPIECA-IOGP, 2014a). DOCUMENTING THE SIMA The SIMA methodoogy invoves various discussions among the participants, to achieve consensus on the seection of resource compartments, assessment of potentia reative impact and aocation of impact modification factors. The agreed outcomes are represented by the matrix in a cear and transparent manner. However, organizations and individuas who have not been directy invoved in the SIMA process may question or chaenge some of the matrix inputs. Questions may be anticipated and addressed through the provision of expanatory notes annexed to a SIMA matrix. The notes are ikey to focus on those inputs to the matrix that generated the most diaogue in order to reach consensus. The notes woud aso reference scenario detais, spi modeing used, sources of environmenta data, any use of sub-matrices to assess potentia reative impact, non-intuitive technica issues that infuenced aocation of impact modification factors and the identification of those organizations invoved in the discussions. 21 Guideines on impementing spi impact mitigation assessment (SIMA)

24 Section 2 The SIMA process REGULATORY ISSUES In some countries, seected response options are cosey reguated to ensure that they are ony used during appropriate circumstances and with suitabe equipment and support. It is recommended that any SIMA utiizes the fu response tookit, so that the recommended response strategy is grounded in the best avaiabe technica approach. The authorities may subsequenty deny approva to use certain response options but may aso grant waivers based on the impact mitigation potentia determined in the SIMA. In some jurisdictions there may be either an absence of existing reguations or ack of reguatory carity with regard to certain response options. This coud affect the feasibiity of their impementation, authorization for use, or their effectiveness. Gaps in reguation may incude: approva of dispersant products and authorization of their use (IPIECA-IOGP, 2014b); procedures for permitting controed in-situ burning; approva of herding agents and authorization of their use; requirements reating to monitoring the operationa effectiveness of response options; and rues regarding the decanting of oiy water, to maximize at-sea storage of recovered oi (IPIECA-IOGP, 2013b). In the unusua case that the reguations in a particuar jurisdiction unequivocay rue out the use of a particuar response option, that option shoud be excuded from the SIMA process. However, the defaut case is that a feasibe options shoud be evauated, i.e. options shoud not be screened out uness the reguations state unequivocay that they cannot be used. Where cear reguation does not exist for a response options, it is recommended that engagement with reguators ensues. This engagement woud not ony promote the best response options for a given scenario but aso the deveopment of suitabe reguation. Thus the SIMA process can become a driver of an improved egisative framework for future oi spi preparedness. 22 Guideines on impementing spi impact mitigation assessment (SIMA)

25 Gossary 23 Guideines on impementing spi impact mitigation assessment (SIMA)

26 Gossary BTEX Effectiveness Feasibiity No intervention PAH Resource compartment Acronym representing Benzene, Touene, Ethybenzene and Xyene; these are voatie aromatic components present to varying degrees in different ois. They raise both human heath and environmenta toxicity concerns. The degree to which a response option wi achieve the desired resuts. A consideration of which response toos and techniques are viabe and safe given the expected cimatic and operationa conditions. The situation whereby no response is undertaken and the theoretica consequences of a scenario are estimated to create a baseine for comparison. The remova of oi from the environment and its recovery is eft to natura attenuation in this case. Poycycic aromatic hydrocarbons The categorization of threatened ecoogica, socio-economic and cutura resources for the purposes of the SIMA assessment. Compartments may be taiored and subdivided to refect specific scenarios but typicay incude the foowing: Compartment Seabed Lower water coumn Upper water coumn Water surface Air Shoreines High vaue resource(s) Socio-economic Cutura Description The benthic zone comprising the seabed and the ife dweing on or within it The body of water extending from above the seabed to within around 10 m of the surface The top few metres of the water, typicay extending to 10 m depth The surface of the water and the marine ife that reguary resides on it or uses the top few centimetres as its habitat The atmosphere above the water Different beach types, typicay divided into ten categories (from rocky to sedimentary) based on sensitivity to oi Specific species, habitats or features that warrant particuar weighting or concern in the SIMA process The combination of varied socia and economic factors that may be affected Resources that have archeoogica, reigious or broader cutura reevance to the community 24 Guideines on impementing spi impact mitigation assessment (SIMA)