FWS National Contingency Plan

8. Incident Command System (ICS) MANAGEMENT STRUCTURE
(See also Appendix C)

When responding to an oil spill incident, Service personnel and their duties should fit within the Incident Command System (ICS) or the overall spill response structure. Federal directives and some states mandate use of the ICS by their agencies as the emergency management system for oil and hazardous substance spill response. The ICS is a standardized on-scene emergency management system designed to adopt an integrated organizational structure equal to the complexity and demands of an incident without being hindered by jurisdictional boundaries. A simplified chart of the ICS response organizational structure follows:

Example: Response Organization

The ICS structure establishes and maintains an effective command and control environment with the flexibility to expand and compress based on incident situation needs. It provides a basic structure that is consistent for all incidents. The ICS provides this consistency by employing standardized nomenclature for job descriptions, common response language, and standardized Section requirements. (Reference Incident Management Handbook.)

Command

The Command or Unified Command, which includes the Federal On-Scene Coordinator and State On-Scene Coordinator, is responsible for authorizing and coordinating all incident operations. While the Command may include other entities such as a Responsible Party On-Scene Coordinator, only Federal and State On-Scene Coordinators have authority over natural resource response decisions. The Federal On-Scene Coordinator is usually either the U.S. Coast Guard for coastal areas or the EPA for inland areas. The FOSC will consult directly with the Service when Service trust resources may be impacted to determine appropriate response measures. For incidents that could significantly impact the Service’s trust resources such as endangered species or migratory birds, the FOSC may request that an agency representative become part of the Unified Command.

The Command Staff may include the following:

The FOSC is to be informed of all activities that are ongoing or being considered. No agency resource trustee actions are to interfere with cleanup/removal activities. Before any actions are taken by Service personnel on a discharge of oil, the FOSC should be notified of Service intentions. If the Service has not been invited to participate in a removal/response, it may be necessary for Service personnel to explain their responsibilities: why the Service is needed, and what it can offer to the FOSC. Once it has been determined that the Service will participate in the spill incident, the RSRC will request, through the DOI REO, a Pollution Removal Funding Authorization from the OSC, to access the Oil Spill Liability Trust Fund for reimbursement of removal costs.

Planning Section

The primary function of the Planning Section is to develop the Incident Action Plan to accomplish the Command objectives. To meet this goal the Planning Section must collect and evaluate all available incident information (i.e. identify resources-at-risk). They are also charged with maintaining updates on available resources (personnel, equipment, vehicles, etc.) and the incident situation status.

When Service trust resources may be affected by an oil spill, Service and other natural resource agency representatives will likely become involved in the response effort through the Planning Section. The representatives provide input on the protection of sensitive resources and how to minimize impacts to trust resources. Most natural resource response planning occurs within the “Environmental Unit” of the Planning Section.

The Planning Section identifies all natural resource response activities and describes those activities in the Incident Action Plan. Depending on the nature and extent of the spill, natural resource response activities may include:

• Protection strategies for fish, wildlife, and sensitive environments;
• Reconnaissance surveys to identify resources-at-risk;
• Carcass recovery;
• Wildlife deterrence measures and pre-emptive capture;
• Wildlife rescue and rehabilitation;
• Deterrence of invasive species, especially rats.

Service personnel serving in Planning Section may be required to:

• Provide information on trust resources-at-risk and location of sensitive environments;
• Assist in prioritizing response recommendations;
• • Assist the FOSC in identifying and obtaining appropriate permits, consultation and authorizations required by the provisions of the Endangered Species Act, the Migratory Bird Treaty Act, and Refuge Special Use Permits;
• Provide technical assistance in the development of shoreline cleanup and assessment plans;
• Request the initiation of wildlife rescue and rehabilitation operations;
• Coordinate with the NRDA liaison.

Operations Section

The Operations Section of the ICS is responsible for the management of all operations directly applicable to the primary mission. Operations Section develops all of the tactical objectives and conducts all of the tactical response field operations. They provide feedback to the Planning Section and assist in the formulation of the Incident Action Plan. All air operations and oil recovery tasks are managed in this Section. The Operation Section also includes the Wildlife Operations.

A Service representative or state wildlife agency representative may serve within the Operations Section, to provide oversight of the wildlife response activities. Wildlife response activities, including the operation of a wildlife rehabilitation center, are managed under the “Wildlife Branch” of the Operations Section. It is critical that all wildlife response activities be coordinated and communicated through the Planning Section. The responsibilities of the Operations Section related to natural resources include:

• • Coordinate early aerial and ground reconnaissance of natural resources in the vicinity of the spill and report the results to the Situation Unit Leader;
• • Implementing protection strategies to avoid and minimize oil impacts to fish, wildlife, and sensitive environments;
• • Coordinate and implement wildlife response strategies including carcass collection, wildlife deterrence, pre-emptive capture, and oiled wildlife rescue and rehabilitation consistent with Appendix D, “Best Practices for Migratory Bird Care During Spill Response;”
• Deploy Shoreline Cleanup Assessment Teams for the evaluation and monitoring of shoreline cleanup techniques.
• Coordinate with NRDAR liaison.

Logistics Section

The Logistics Section is responsible for providing facilities, services, and materials in support of the incident response. Services and support needs are identified in the Incident Action Plan and acquired within the Logistics Section. Service personnel may work with Logistics to acquire supplies, equipment, waste disposal services, and space for wildlife sampling and rehabilitation. Costs of these must be coordinated through the Finance Section as to which costs should be billed to the Service under its PRFA and which, if any, are being borne as part of the general response directly under the FOSC.

Finance Section

The fourth and final section under the Unified Command is the Finance Section. The primary function of the Finance Section is monitor all costs related to the incident response. They provide accounting and procurement services, time keeping, cost analysis, and maintain adequate documentation for cost recovery. The Service needs to work with the Finance Section to establish a PRFA for response activities and then provide them with updates on the level of expenditures under the existing PRFA and any anticipated needs for amending the PRFA authorization amount or scope of activities.