Revision of the National Preparedness for Response Exercise (PREP) Guidelines

Dear Mr. Jonathan Smith, Thank you for the opportunity to comment on the Revision of the National Preparedness for Response Exercise (PREP) Guidelines, Docket No. USCG–2011–1178. The American Petroleum Institute (API) is a national trade association that represents over 625 members involved in all aspects of the oil and natural gas industry, including exploring for and developing oil and natural gas resources in the outer continental shelf. While the March 2015 revised draft PREP guidance included great flexibility in designing and taking credit for PREP exercises, we believe there is further opportunity for improvement. Industry has demonstrated its commitment to continuous improvement to response exercises and drills through the creation of the oil industry-chartered Joint Industry Oil Spill Preparedness and Response Task Force. Detailed information on this JITF can be found at www.oilspillprevention.org. Specific API comments are listed in Attachment 1 for your consideration. Several members have pointed out inconsistencies between organizations, the Federal Register notice and the March 2015 draft PREP guidelines, and the attached comments are focused in that direction. We believe that a meeting on these issues, and others of particular interest to you, your colleagues and API members, will help to inform and add value to the guideline review and any subsequent revisions. Please contact Ray Bradley, Senior Policy Advisor, to coordinate such a discussion. Thank you for your consideration of these comments. Best regards, Robin Rorick Director, Midstream & Industry Operations See attached file

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