For your convenience, we are providing some sample language for comments on the National Contingency Plan for oil spills. Customize it or feel free to copy and paste it directly.
To submit your comments, click here, then look for the green button in the top right hand corner that says “Submit a formal comment.” Enter your name in the field that says “Organization.” We all have the right to submit public comment.
If you want more in-depth information on our recommendations, visit our public comment page.
This comment is in regard to the proposed revisions to the National Oil and Hazardous Substances Pollution Contingency Plan (NCP).
[Take a few minutes to personalize your letter HERE as this will have more impact with EPA. YOU are NOT an organization or industry. YOU are a living breathing human being who will live with the consequences of this rulemaking. For example, are you a parent who is concerned about your health and the health of your children? Are you a fisherman who is concerned about safe harvest or personal consumption of safe seafood? How has an oil spill impacted your life – or how might one? What has been your experience? What are your concerns? Don’t forget about fresh water oil spills! Fresh water spills of Unconventional Oil and Gas have contaminated drinking water, incinerated people and homes, caused evacuations, and NOT been cleaned up. You want a strong PLAN to prevent spills in the first place and to minimize harm from oil spills when they occur. You want a PLAN that protects you and what you love.]
Human and environmental health are critical issues during oil spills, and we must address the hazards of dispersants and other chemical and biological agents used to “clean up.” We need to specifically:
- Have the right people in charge of decision-making — A) Clarify that the EPA has ultimate authority on product use, not the Coast Guard or the spiller B) Leave local people in charge of developing Area Contingency Plans to bring local knowledge into the planning process and C) Don’t put the spiller in charge of environmental monitoring of spill impacts!
- Expand the scope of Area Contingency Plans to include protection of public health and welfare, as well as wildlife.
- Create more Area Committees with companion Citizens’ Advisory Councils to protect communities at risk from oil activities.
- Use only non-toxic products that will do no more harm during oil spill response.
- Close the loopholes that negate the planning process.
- Establish general listing and testing and monitoring requirements for all agents and certain sorbents as a basic right-to-know if the product is non-toxic and effective.
- Require site-specific monitoring and testing to determine if the product might work as intended and if the product did work as intended during and after use.
- Reduce risk to the environment and people by ensuring readiness of quality products, recovering products from the environment, and timely notification of product use.
- Establish a public process for appeals and removal of products that don’t work as intended, and for transitioning to the new rules.
- Clarify definitions to ensure that we understand what we are dealing with and can plan to mitigate harm from oil and products.