Evaluation of the R&T Plan Content
This chapter discusses the committee’s assessment of the effectiveness of the development process described in Chapter 2 in terms of (1) the adequacy of the end product, that is, the final list of priority Research Needs contained within Chapter 9 of the Interagency Coordinating Committee on Oil Pollution Research (ICCOPR) Oil Pollution Research and Technology Plan (R&T Plan) and (2) adherence to the congressional requirements. The chapter ends with the committee’s conclusions and recommendations regarding the adequacy of the 2022 R&T Plan (hereinafter referred to as the R&T Plan).
ADEQUACY OF RESEARCH PRIORITIES IDENTIFIED
The committee’s assessment starts with general observations of the adequacy of priority Research Needs, as applied across all four research Classes. Overarching concerns stem from the R&T Plan development process described in Chapter 2 and can be summarized as lack of transparency about or justification for Research Need prioritization, loss of context or meaning due to consolidation of Research Needs, and inaccurate placement of Research Needs within the Standing Research Areas (SRAs) or Subcategories. The committee believes that the adequacy of the priority Research Needs in all research Classes will improve if the ICCOPR revises the R&T Plan development process as recommended in Chapter 2. This section also presents committee findings specific to each of the four research Classes.
Assessment of the Prevention Class
The Research Prevention Class (Series 10000)1 has 10 SRAs, 10 Subcategories, and 45 research priorities. The Prevention Class is focused on process safety (as opposed to personal safety
1 The Research Numbers correspond to the “Series” numbers included in Chapter 9 of the 2022-2027 R&T plan. The Series numbers correspond to Class, SRA, and Subcategory. For example, the Response Class is labeled Series 30000. Within the Response Class, SRA “Oil Spill Detection and Surveillance” is labeled 30300. Within that SRA, the Subcategory “Remote Detection” is labeled 30301. Then within the subcategory, priority Research Needs are assigned “A,” “B,” or “C.”
or industrial hygiene under the Injury Assessment & Restoration Class), based on the integration of three topics: human factors, equipment and gadgets, and work processes. Although many potential Research Needs fall under each SRA, the committee is concerned that the level of coordination among the SRAs is insufficient and that research in the specific areas described may not result in a significant improvement in oil spill prevention because of work completed and/or duplication of effort. For example, for the Human Error Factors SRA, numerous recommendations from the Deepwater Horizon incident addressed decision-making under stress, and the United States Navy and United States Coast Guard are the recognized experts for the development of programs for training under realistic conditions. Missing from this Class is research on the development and use of fool-proof backups, such as artificial intelligence or automation, which are less explored and deployed but could result in a giant leap forward in terms of safety and oil spill prevention.
Assessment of the Preparedness Class
The Preparedness Class (Series 20000) is the smallest of the four Classes, with only three SRAs, three Subcategories, and 15 priority Research Needs. Preparedness may have the largest impact on decision-making during a spill, although whether more research or more data collection is needed is unclear. Information, especially about long-term, high-volume spills that cover a large area, is a critical need. The Research Needs in the baseline (Subcategories 20001 “Habitats and Species Baselines,” 20002, “Oceanographic and Geologic Baselines,” and 20003 “Environmental Baseline Planning”) do not develop a common characterization or format and tend to focus on the Gulf of Mexico and the Arctic. Any area with offshore energy production and transportation is an area of concern, including inland areas.
Some of the Research Needs listed in the other two SRAs (20100 “Response Management Systems” and 20200 “Renewable Energy Systems”) border on response and in some cases have been subject to previous work. Research Need 20100C, “Develop spill planning and response management tools based on gap analysis of the availability of countermeasures in Arctic and other remote locations,” offers no details to provide focus. Furthermore, the meaning of Research Need 20100B, “Evaluate existing virtual oil spill response systems and make recommendations for improvements and best management practices,” is unclear. Although Renewable Energy Systems is a new Class, its three Research Needs are very similar. For example, Research Need 20200B, “Develop effective spill response mitigation strategies specific to the risks associated with discharges from wind farms and offshore renewable energy facilities,” and Research Need 20200C, “Identify the potential types, sources, and volumes of oil and fluid discharges from renewable energy systems and associated infrastructure, and how the layouts of these systems may necessitate altering spill response strategies and techniques,” both address developing strategies for responding to discharge from renewable energy systems.
These examples reflect the issues in the R&T Plan development process discussed in Chapter 2, specifically, insufficient information about the work completed to date, a lack of appropriate specificity in Research Need descriptions, and failure to include desired endpoints.
Assessment of Response Class
The Research Needs in the Response Class (Series 30000) are divided into 11 SRAs, with 2 SRAs having six Subcategories, 2 having two or three Subcategories, and 6 having no Subcategories. As a result, this Class accounts for 75 of the total 171 priority Research Needs in the R&T Plan. Because each SRA or Subcategory of the SRA includes the top three priority Research Needs, the identification of Subcategories in an SRA provides an opportunity to increase the number of priority Research Needs within the SRA. Although this approach seems appropriate for
indicating importance of the research (there may be strong justification for including more priority Research Needs in one Class over another), the criteria for determining when a Subcategory should be established within an SRA are unclear.
The R&T Plan identifies three primary sources for identification of Research Needs: subject-matter experts (SMEs), literature and data calls, and public listening sessions. The listing of published references for Research Needs generated by literature and data calls in Appendix B of the R&T Plan is helpful.
The priority Research Needs included in the Response Class represent a good distribution of sourcing for the final priority Research Needs. However, within this research Class, there are some inconsistencies among final priority Research Needs, report discussion, and the Research Needs articulated in the raw data. These inconsistencies can be grouped as follows:
- Several of the priority Research Needs in the Response Class cannot be found in the raw data or in the recommendations from the Noteworthy Spills. Of the nine priority Research Needs listed in Subcategories 30301 (Remote Detection), 30302 (Monitoring), and 30303 (Submerged Oil Detection), only two are somewhat reflected in the raw data; the other seven appear to be consolidations of multiple recommendations. Examples of priority Research Needs not reflecting the raw data are 30203A (“Improve subsea oil detection systems so they are readily deployable and produce reliable input variables for three-dimensional oil spill trajectory models”), 30204A (“Develop and improve nonproprietary algorithms for oil spill models based on the current state of science”), 30204B (“Improve reliability of modeling systems or methods that can scale down from the ocean to coastal environments”), and 30204C (“Evaluate the near-surface ocean velocity structure and interfacial stresses between air, oil and water under different wind, wave and current conditions to improve oil spill models”).
- Research on oceanographic models not directly related to oil transport does not belong in the R&T Plan; more precise SRA or Subcategory descriptions would clarify their purpose.
Lastly, as discussed in the 2022 R&T Plan, public perception is a barrier to the success of the R&T Plan; the addition of “Science/Technology Communications and Outreach” as an SRA under the Preparedness and Response Class could help to tackle this barrier.
Assessment of Injury Assessment and Restoration
The Injury Assessment and Restoration Class (Series 40000) has four SRAs and 10 Subcategories, resulting in 33 Research Needs. This Class provides another example of the need to more clearly describe Research Needs. Because the priority Research Needs within the Environmental Effects and Ecosystem Recovery SRA are similar and overlap, the difference between Subcategories 40001 (Species Impacts) and 40002 (Toxicological and Sub-Lethal Impacts) is unclear. Therefore, one could argue that the Research Needs belong in the same Subcategory and should be combined. Similarly, some of the priority Research Needs may fit better within other Subcategories within the SRA. As noted in Chapter 2, improved descriptions of both Subcategories and priority Research Needs in this Class would enhance placement of Research Needs within appropriate Subcategories and, in turn, assessment of the adequacy of this Class.
For some of the Research Needs within this Class, especially those that call for studies and/or syntheses for habitats, communities, and species, a phased approach that reviews the existing literature to identify those habitats, communities, and species with the greatest need for further study, including a regional component, would be beneficial.
Regarding the adequacy of the Research Needs within this Class, none address the need for models that can translate results to possible field impacts in order to assess the effects of oil on organisms. This was a recommendation in the National Academies report The Use of Dispersants in Marine Oil Spill Response (NASEM, 2020), and it aligns with the Research Needs of Subcategory 40002 (Toxicological and Sub-Lethal Impacts). Similarly, none of the Research Needs under SRA 40200 (Environmental Restoration Methods and Technologies) on the “development of methods and technologies to facilitate and accelerate the recovery of resources following an oil spill” specifically addresses any identified restoration methods or technologies. Instead, this Subcategory appears to be focused on monitoring the effectiveness of long-term restoration and the factors that influence it.
ADHERENCE TO CONGRESSIONAL REQUIREMENTS
Every 2 years, ICCOPR has the responsibility to submit a report on its activities to Congress, and every 10 years, ICCOPR must submit an updated R&T Plan that reviews the state of oil discharge prevention and response capabilities. As stated in Box 1.2, ICCOPR’s congressional charge lists eight requirements for the R&T Plan. This section presents the committee’s assessment of the 2022-2027 R&T Plan with respect to adequacy in capturing, interpreting, and addressing each congressional requirement. The R&T Plan does not include ICCOPR’s interpretation of the requirements under the 2021 National Defense Authorization Act (NDAA); therefore, the assessment reflects the committee’s interpretation of the requirements.
(i) identifies current research programs conducted by federal agencies, States, Indian tribes, 4-year institutions of higher education, and corporate entities;
This requirement is met by the 2022-2027 R&T Plan; however, outreach to Indigenous communities could be improved.
Considering the scope of this requirement, and the level of logistical support and the timeline available, the 2022-2027 R&T Plan provided a relatively comprehensive overview of the research programs and activities conducted by the federal agencies and other federal stakeholders and entities, which included their research laboratories and testing facilities, coastal and ocean research vessels, and spill of opportunity research sites. In addition, the R&T Plan describes the oil spill research performed by non-federal oil spill pollution research entities, such as state organizations, industry organizations, academia, and independent research groups, as well as international programs and global oil pollution testing facilities.
In terms of research programs that address the needs of Indigenous tribes, with the exception of Section 3.3.5 (“The Native Village of Eyak”) and a statement that tribal experts were included in the 2020 data call, ICCOPR’s efforts to include environmental and cultural concerns of Indigenous groups and the potential application of their traditional knowledge in oil spill research programs could be strengthened.
(ii) assesses the current status of knowledge on oil pollution prevention, response, and mitigation technologies and effects of oil pollution on the environment;
This requirement is met by the 2022-2027 R&T Plan; assessment of response technologies could be expanded on in future revisions.
The R&T Plan provided an overview of the current status of knowledge on oil pollution prevention and response and the potential effects of oil pollution on the environment. The committee
acknowledges the challenges to comprehensively covering the topic of response technologies under this remit, considering the time available. However, the level of detail describing the various response strategies and technologies and their mode of action and operational limits was deemed sufficient for the intended R&T Plan audience (i.e., members of Congress, their staff, and the public). Examples of technological advances were largely limited to those produced by ICCOPR agency members. Thus, there is concern that the results of cutting-edge academic research and proprietary private-sector research may not be captured in the report. Future R&T Plan revisions would benefit from careful consideration of an effective strategy to address this new section of the plan, for example, by incorporating guidance and input from agencies, leveraging summaries of technological advancements included in ICCOPR’s biennial plans to Congress (per 7001(e) of the Oil Pollution Act of 1990), and encouraging timely literature and synthesis reviews of specific technologies.
As stated in Chapter 2, the 2022-2027 R&T Plan did not clearly define the term “mitigation.” Such a definition in the context of the ICCOPR objectives would enhance future R&T Plans.
(iii) identifies significant oil pollution research gaps, including an assessment of major technological deficiencies in responses to past oil discharges;
This requirement is sufficiently met by the 2022-2027 R&T Plan; improvements could be made.
As described in Chapter 2, the R&T Workgroup developed a rigorous process to identify and describe Research Needs that included defining four research Classes (Preparedness, Prevention, Response, and Injury Assessment and Restoration) comprising 28 SRAs (see Figure 2.3). This process enabled the consolidation of 2,350 research gaps into a list of 737 Research Needs that were subsequently condensed into 171 priority Research Needs. The process for identifying and prioritizing Research Needs could be improved, as recommended in Chapter 2.
In addition, the 2022-2027 R&T Plan emphasizes the data calls and public listening sessions as methods to elicit research publications from experts in the field. Little detail is provided about formal interaction with major national and international funded research programs on oil spills to solicit information about their identified knowledge gaps and priorities. Examples include the National Academies’ Gulf Research Program (NASEM, 2022a), the Canadian Multi-Partner Research Initiative (Government of Canada, 2021), and the European Union Horizon 2020 research project GRACE (NASEM, 2022a). ICCOPR member interaction with such programs (i.e., serving on program advisory committees) would help ensure incorporation of this knowledge into future plans. The committee recognizes that this effort may have been hampered by the limited time frame (1 year) for the literature review.
(iv) establishes national research priorities and goals for oil pollution technology development related to prevention, response, mitigation, and environmental effects;
This requirement is sufficiently met by the 2022-2027 R&T Plan; the process to establish national research priorities could be improved.
The R&T Workgroup established a final list of national research priorities and goals for oil pollution technology development related to prevention, preparedness, response, and environmental effects and ecosystem recovery by engaging SMEs with knowledge and expertise in each of the SRAs and Subcategories in its processes, described in Chapter 2. Details on the process used to prioritize Research Needs are not provided in the R&T Plan.
The committee expressed some concern that the 2022-2027 R&T Workgroup agreed to identify only the top three suggested priority Research Needs for each SRA and Subcategory, because some subject areas may need more research than others to become operational tools or to provide the level of data needed to support spill response decision-making. The research prioritization process could benefit from a careful evaluation and implementation of recommendations included in Chapter 2.
(v) assesses the research on the applicability and effectiveness of the prevention, response, and mitigation technologies to each class of oil;
This requirement is not sufficiently met by the 2022-2027 R&T Plan.
Chapter 7 of the 2022-2027 R&T Plan provides a description and an assessment of the applicability and effectiveness of various prevention, response, and mitigation technologies as well as a short description of the various oil groups. An assessment on the applicability and effectiveness of each of the technologies specific to each oil group was not provided. Information on the operational window for the application of response technology options to the different oil groups would help fulfill this requirement. In support of decision-making following a spill, selection of the optimal mix of spill response technologies would benefit from an overview of the secondary potential detrimental effects of the various spill response technologies described and decision tools.
(vi) estimates the resources needed to conduct the oil pollution research and development program, and timetables for completing research tasks;
This requirement is not met by the 2022-2027 R&T Plan.
The R&T Plan does not estimate the resources needed to conduct the prioritized projects. Although the R&T Plan identifies priority Research Needs, in most cases, it does not specify whether the goals and objectives of the prioritized projects would be completed within the 2022-2027 time frame.
(vii) summarizes research on response equipment in varying environmental conditions, such as in currents, ice cover, and ice floes;
This requirement is partially met by the 2022-2027 R&T Plan.
The influence of environmental conditions on the effectiveness of various types of response measures and equipment is discussed briefly in Section 7.3 of the 2022-2027 R&T Plan. The potential impacts of a limited number of environmental factors (e.g., sea ice, high winds, cold temperatures, limited visibility, and sea state) on spill response options are outlined in a table in Appendix D. The window of opportunity to apply various types of oil spill response equipment is site specific because of the interaction of multiple environmental factors, as well as the physical and chemical properties of the oil following its release. The R&T Plan would benefit from holistic treatment of environmental challenges associated with response options.
The committee noted that some real-world process interactions and variables in the field cannot be replicated in the laboratory and mesocosm test facilities, and therefore experimental open-water field trials are needed. In this regard, the call for experimental field trials in the 2022-2027 R&T Plan (Section 5.1.3, Field Testing) and the previous 2015 Plan states that ICCOPR should work with policy makers and permitting authorities to explore field testing opportunities. This requirement
could also be met through international collaborations with countries with an established formal authorization process for field testing.
(viii) includes such other information or recommendations as the Interagency Committee determines to be appropriate.
It is not appropriate for the committee to assess whether this requirement was met. However, the committee notes that economic, social, and health sectors (and risk communication) were not well covered in the plan despite being identified as important in national publications (NASEM, 2020, 2022b; NRC, 2003) and in Chapter 7 of the 2022-2027 R&T Plan. The existing ICCOPR representation does not include advocates for those Research Needs. Representation from social scientists and public health experts would help to fill this gap.
CONCLUSIONS AND RECOMMENDATION
Conclusion: Adequacy of R&T Plan Research Priorities. The committee raised several concerns about the clarity, completeness, and defensibility of the final list of priority Research Needs listed in Chapter 9 of the R&T Plan. Descriptions of the SRAs and specific Research Needs are unbalanced and, in many cases, lack sufficient detail to clarify the intent. Ultimately, the adequacy of the R&T Plan content is largely a reflection of the development process and will be enhanced as that process is improved. In addition, the R&T Plan does not meaningfully cover economic, social, and health sectors (and risk communication). Inclusion of social scientists and public health experts on ICCOPR would help to fill this gap.
Recommendation 2: Future revisions of the R&T Plan should provide sufficient and appropriate descriptions for each priority Research Need, including the general research that should be addressed, followed by the goals and objectives of the research. Recommended metrics, desired outcomes, and timelines for completing the research agenda should also be included.
Conclusion: Adherence to Statutes. The 2021 National Defense Authorization Act (NDAA) lists eight requirements for the R&T Plan. The committee determined that the R&T Plan addressed five of the requirements and did not adequately address the following three requirements:
- An assessment of the applicability and effectiveness of each of the technologies identified to the oil groups.
- Estimates of the resources needed to conduct the prioritized projects.
- Review of the influence of environmental conditions on the effectiveness of various types of response measures and equipment.
Dedicated funding is needed to support ICCOPR in fully addressing the congressionally mandated requirements of the R&T Plan, thus ensuring a robust development process and successful implementation.
Incorporating the committee’s guidance on future plan development, particularly the guidance to streamline and expand the information-gathering process, would strengthen compliance with all 2021 NDAA requirements.
Future revisions of the R&T Plan would benefit from a section that specifically addresses ICCOPR’s interpretation of the congressional requirements as well as metrics for measuring success.
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