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500 Fifth Street, NW Phone: 202 334 2934 Washington, DC 20001 Fax: 202 334 2003 www.TRB.org A Review of The HS SEDI Buzzards Bay Risk Assessment Report October 24, 2013 Ms. Elise DeCola Nuka Research and Planning Group, LLC 10 Samoset St. Plymouth, MA 02360 508-746-1047 office firstname.lastname@example.org Dear Ms. DeCola, In March 2013, representatives of the Commonwealth of Massachusetts Department of Environmental Protection (MassDEP) contacted the Transportation Research Board (TRB) of the National Academies (TNA) and requested that it conduct an independent technical evaluation of the Buzzards Bay Risk Assessment (BBRA) that had been performed by Homeland Security Systems Engineering and Development Institute (HS SEDI). TRB appointed a committee (see Enclosure B) and charged it with reviewing the scope, methods, and data of the BBRA. (See Enclosure D for the committeeâs statement of task.) On August 5â6, 2013, the committee held a public meeting at TNAâs J. Erik Jonsson Conference Center in Woods Hole, Massachusetts, and received presentations from Nuka Research and Planning Group, MassDEP, the United States Coast Guard (USCG), and the MITRE Corporationâs HS SEDI federally funded research and development center. At the meeting, the TRB committeeâs statement of task, the HS SEDI statement of objectives for the risk assessment, and the BBRA itself were discussed. The committee then held a series of closed-session teleconferences to deliberate. The members of the committee are pleased to provide this letter report containing their review, findings, and conclusions. This letter report, a brief document prepared over a short time, has been reviewed by a group other than the authors according to the procedures approved by a Report Review Committee consisting of members of the National Academy of Sciences, the National Academy of Engineering, and the Institute of Medicine. (See Enclosure A for a list of the reviewers.) The format of this letter report is well suited to the task at hand in view of the urgency perceived by MassDEP in providing input that it can incorporate in response to the USCG advance notice of proposed rulemaking in the Federal Register (dated July 8, 2013) with respect to how best to enhance environmental protections and navigation safety outlined in the special Buzzards Bay regulations. Specifically, USCG is considering revising current pilotage, escort tug, and Vessel Movement Reporting System Buzzards Bay requirements for barges carrying 6,000 or more barrels of oil or other hazardous materials.
500 Fifth Street, NW Phone: 202 334 2934 Washington, DC 20001 Fax: 202 334 2003 www.TRB.org In response to its statement of task, the committee found significant limitations with regard to the BBRA that bring into question its scope, methods, and data. The committee believes that choices made in the formulation and execution of the study bring into question the conclusions of the risk assessment on technical grounds (e.g., use of a âchange analysisâ approach without clearly defining a base case, application of qualitative measures without defining the scales, reliance on experts who were neither independent nor representative of the expertise needed, failure to include any uncertainty or sensitivity analyses, and the âblack boxâ application of economic methods). Because of these concerns, the committee believes that the ranking of the risk mitigation options in the report (i.e., additional pilots, conditional escorting based on weather, and escorting at all times) are not justified and could be reversed with slightly different and more defensible methods or assumptions. Policy decisions should not be based on this assessment. Sincerely, Paul Fischbeck, Chair Committee to Review the Buzzards Bay Maritime Risk Assessment Cc: Richard Packard, MassDEP Oil Spill Prevention and Response Program