Making U.S. Ports Resilient as Part of Extended Intermodal Supply Chains (2014)

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89 6.1 Introduction This chapter of the report draws from the material presented in previous chapters to synthesize a series of high-level rules of thumb that could help public agencies respond to significant disruptions to a seaport’s cargo throughput activities. The multi-stakeholder complexity associated with seaport disruptions, as well as the dynamic— and often unique—nature of the situation in the immediate response stage, make the development of specific action plans a significant challenge. One is reminded of the military maxim, “All plans are great until the first shot is fired.” Yet, even though the unexpected often occurs, the two case studies in this report support the value of pre-planning and plan-based exercising of both logisti- cal and informational protocols, as ways to mitigate some of the worst effects of a disruption to a port’s operations. The case studies also suggest that regulatory protocols could be useful in recovering from future disruptive events. Once an event takes place, the practicalities of the situation appear to dictate an immediate response phase, leading into a more protracted recovery effort. The initial goal is to resume port operations as soon as possible, although a return to pre-disruptive operational status may take longer to achieve. This present study focuses on one aspect of a broad objective of port recovery, getting cargo throughput back to pre-event levels within the port as quickly as possible and using, as required, multiple modes and multiple ports to achieve this goal. The literature on this topic indicates that this task is a business continuity challenge, with the implied need to keep the additional costs of freight loss, damage, and delay to a minimum. Doing so in some more extreme cases of port disruption, such as that resulting from Superstorm Sandy (Chapter 4) has to be accomplished in the context of much broader safety and damage issues, and also in the context of simultaneous impacts on multiple adjacent seaports. And as with all transportation-system-related actions, the safety of people must come first. The specific actions recommended in the literature for mitigating the effects of a disruption cover three distinct phases associated with any disruption event, as follows: 1. Prior actions geared to avoiding or limiting a disruption’s impacts (preparedness); 2. Actions geared to dealing with the immediate impacts of the disruption (response); and 3. Actions geared to getting the port back up and running again as soon as possible (recovery, and eventually resumption, of pre-incident operating levels). Collectively, these three sets of actions seek to increase a port’s resilience to threats through greater pre-planning and plan exercising, asset redundancy, and flexibility in the use of existing assets (see Chapter 2 for details). Although the focus of this present research has been on the C H A P T E R 6 Synthesis of Findings

90 Making U.S. Ports Resilient as Part of Extended Intermodal Supply Chains second and third actions in this sequence, it is clear that the success of any actions taken will depend, in many instances, on the effectiveness of prior planning, which requires the establish- ment of effective working arrangements between both the public agencies and private-sector stakeholders involved. Such arrangements were demonstrated in recent disruptions by the roles played by MTSRUs and in the multimodal movement of diverted cargos. The research also demonstrated that delays in recovery can occur when such arrangements are not fully in place. One example was the need to arrange for and use U.S.-flagged vessels or alternative modes when there was no Jones Act exemption provision for the handling of diverted containers after Superstorm Sandy. With a Jones Act exemption, some of the organizations interviewed noted that the diverted containers would have been handled by the next vessels in the rotation, as is apparently done in Europe and Asia. Instead, alternative arrangements had to be made and these additional costs were passed on to the BCOs. Based on the many expert interviews carried out by the project team, it is also clear that disruptions to cargo movement at our nation’s seaports represent costly delays to product supply chains. That is, ports are key supply chain nodes whose functionality is dependent on the efficiency of not only within-port cargo handling activities, but also on the upstream and downstream efficiency with which freight comes into, and subsequently moves beyond, the port complex. The more significant the disruption, the greater the pressure placed on both landside and waterside transportation modes to respond. As the precursor study to this present report demonstrates (Georgia Tech Research Corporation, et al., 2012), if protracted outside-the-port mode shifts are required, the economic costs to shippers, carriers, and customers of returning to pre-disruption conditions can be significant. Therefore, port disruptions need to be viewed in this context of broader network supply chain impacts, and all supply chain stakeholders impacted need to be kept up to date on the status of port-inclusive cargo movements. Where multiple ports are impacted, either directly (e.g., by widespread bad weather) or indirectly (by being asked to handle a short-notice surge in demands to handle cargo diverted from adjacent ports), the supply chain adjustments require considerable cooperation. 6.2 Influences of Prior Warning and Severity of Port Disruptions As noted in Chapter 2 of this report and confirmed by the study’s expert interviews, the evidence from past disruptions to seaport activities clearly indicates that the character of resilience enhancing activities can be significantly influenced by stakeholders’ awareness of the nature, timing, and severity of a forthcoming disruption. In cases of severe and geographically widespread disruptions, such as Superstorm Sandy, there is a need to plan for, and execute, some significant cargo diversions on both the waterside and landside activities associated with cargo deliver- ies. On the landside, modal flexibility is an important asset, one that means being able to shift from one mode to another (e.g., from truck to rail or barge, or vice versa) as conditions dictate. On the waterside of port operations, the ability to re-direct inbound shipping to other ports also requires knowledge of both container and non-container cargo handling capabilities at adjacent ports—which themselves also may be under duress. Throughout all of this temporary (if sometimes protracted) coping activity, it is also clear that a significant break at any point within the multimodal landside-within port-waterside connections discussed in Chapter 2 can have costly negative consequences on a stakeholder’s entire supply chain. Treating ports as key nodes in trade-based supply chains therefore seems to warrant further attention and to offer a productive perspective to adopt in seeking greater freight system resiliency. And even when both the timing and nature of a cargo-handling disruption to port activities is anticipated with a high

Synthesis of Findings 91 degree of confidence, as in the Columbia River case study described in Chapter 5, unanticipated events may occur, and return to pre-event operating conditions can still be difficult and costly. A third type of disruption, not covered by a case study in this report, involves an event for which little or no prior warning is possible, such as sudden chemical spill or a terrorist attack, and which may create an immediate level of confusion that adds uncertainties in responding to issues of humanitarian logistics as well as commercial supply chains. In the Columbia River and New York–New Jersey port disruptions described in Chapters 4 and 5, some degree of prior warning (if not of the exact nature and true severity of the event in the Sandy case) was avail- able. As noted by one of this project’s panelists, human emotions will play a far greater role in the nature of stakeholder response and resilience activities because of the heightened fear and uncertainty associated with an entirely unanticipated disruption. With these thoughts in mind, the following observations are presented as a high-level frame- work from which to consider the key points identified by the project. These rules of thumb are arranged around the report’s three major themes 1. Actions dealing with utilization of physical and logistical assets; 2. Actions to ensure adequate and timely communication of critical information; and 3. Actions that address and, where necessary, seek temporary waivers to, prevailing government regulations. 6.3 Protecting and Using Physical/Logistical Assets Identify the type and potential severity of the supply chain disruption, and the level of resources needed to deal with it, including its • Geographic scope, • Facilities disrupted, • Modes impacted, • Commodities and characteristics of the shipments disrupted, and • Likely timeframe needed for service resumption. Know the current condition, location, and available cargo handling capability of the port’s major physical assets, and determine the safety of these assets, including • Seagoing vessels; • Landside modes (truck, rail, barge) serving the port and associated equipment; • Indoor and outdoor storage and dock capacities; • Cargo including full and empty containers; • Cargo handling equipment (cranes, forklifts, etc.); • Channel clearing vessels and equipment; • Size of the normal and temporary, event-activated labor force (by job type); and • Water, fuel, and power supply. Identify the need to move port assets to safer locations—terminal equipment, containers, IT equipment, rail and truck equipment, and even vessels may need to be moved off site given sufficient forewarning of an event. Identify, as early as possible, any anticipated cargo handling shortfalls and the key logisti- cal options available for responding to the situation. • Identify regulatory options to support cargo handling (e.g., Jones Act, size/weight, and other temporary regulatory exemptions); • Identify the options for landside mode-shifting (or “mode flexing”) with respect to cargo types and their inland origins (outgoing) and destinations (incoming);

92 Making U.S. Ports Resilient as Part of Extended Intermodal Supply Chains • Quantify all available cargo handling resources and explore willingness of stakeholders to share resources during response and recovery periods; • Identify the current condition, location, and availability of cargo handling capacity at ports suitable for cargo diversions, again with respect to cargo types and their inland origins (outgoing) and destinations (incoming), and recognizing: – Size of diversions expected (e.g., number of vessels and containers diverted); – Timing of diversions and expected vessel arrival times at alternative port; and – Potential impacts on, and limitations imposed by, alternative landside (truck, rail, barge) as well as oceanside, modal options at the alternative port 6.4 Maintaining Frequent Communications and Information Flow Monitor and maintain the workings of the port’s real-time communications technologies • This includes communications between port management; emergency responders; port labor; local, regional, and federal enforcement and planning agencies; port supply chain stakeholders (carriers, shippers, receivers, brokers); the media; and (as warranted by event extent and severity) the public at large. • Employ, as needed, the redundancy offered by alternative communication technologies (GPS, cellular phones, land lines, online Internet and Intranet websites, and in some cases paper copies). Each can become essential to an effective recovery as well as response phase in cases of severe or widespread disruption events. Note that some of these IT assets may have been moved offsite for safety reasons (see 6.3) or functions may be running through back-up data and communication systems. • Establish daily conference call arrangements for disruption situations. Maintain regular, two-way communications with all stakeholders—report regularly on status of port and terminal operations, damages and current and potential delays to cargo movement, as well as any proposals or plans to handle such delays. Consider using all forms of available communication necessary, including hard copy. The ability of carriers and shippers of cargo, or their agents, to quickly assess freight delivery problems, identify supply chain alternatives, and communicate this information with their customers significantly impacts supply chain resilience. Early communication with customers minimizes economic costs and supports business retention. Monitor and maintain the condition of the port’s data, computer, and telecommunications online and back-up systems in case of cyber system failures—resilience through redundancy, in the form of back-up information (data storage and retrieval, rapid communication) technology systems is becoming/has become a necessity in today’s business world. 6.5 Dealing with Regulatory Compliance Issues Determine the institutional and regulatory context of the event with respect to • Port operational command and emergency response authority; • Control over within-port asset utilization; • Public/private-sector asset ownership; • Financial resources/availability and authority to use; and • Legal and insurance issues with respect to labor credentialing, cargo inspection, and clearance, safety, security and environmental compliance. Understand both specific agency and specific individual roles and responsibilities—Know who to contact on specific issues, from the role of the USCG’s Captain of the Port to that of

Synthesis of Findings 93 other federal, state, and local government agencies, port officials, vessel and intermodal inland freight carriers, terminal operators, etc. In particular, who makes the key port operating decisions, and who sets response priorities? Also, how and when do such priorities change during the immediate response phase, in the immediate post-response period, and during the subsequent port recovery phase? Understand and seek temporary waivers to appropriate cargo, labor, and fuel regulations as port operating conditions change—Monitor and seek modifications to a port’s personnel access conditions, as needed, for effective labor notification, credentialing, and limitations on exposure. • Labor credentialing associated with port entry, re-entry and (if needed) on-site or near site temporary housing; • Labor safety, including roles assigned to workers and first responders unfamiliar with a specific port’s operations; and • Other workforce policy issues (see TSIP, 2011, and Section 2.4 of this report). Monitor and seek modifications to a port’s electrical and fuel supply systems, as needed for effective power generation for buildings, vehicles, and cargo handling equipment. Monitor and seek temporary modifications to a port’s cargo, intermodal, and vessel hand- ling rules and regulations, as deemed necessary. This applies to cargos being diverted to ports that are asked to handle a sudden surge in the demand for its freight handling capabilities due to a major disruption at another port. 6.6 Example Port Disruption Rules of Thumb Table Table 6.1 presents a sample rules of thumb template. The table is used here to demonstrate the type of high-level incident response activities that the interviews suggest are required of port preparedness and response leading up to, during, and both immediately after and during any long-term incident recovery period. Entries in the table are organized around the physical, informational, and regulatory dimensions of the problem. They are based on the use of a centralized, EOC approach to incident response that brings together the various public and private stake- holders involved. The specific make-up and operating authorities of such an EOC will vary on a case-by-case basis, but the general concept of an “all hazards” and multi-stakeholder-informed approach to the problem seems valid. 6.7 Possible Next Steps Based on the research undertaken for this study, the following may merit further investigation: • Identify and assess the challenges associated with handing surges in diverted vessels and shipments in response to a significant single- or multiple-port disruption event. This includes: – Existing and potential roles of regulatory, physical, and information flows to expedite handling of diverted containers; and – Mode shifts or other means of gaining flexibility in post-disruption modal transportation services, notably on the inland movement of cargo to and from affected ports. • Articulate and provide rules of thumb for balancing resiliency/system infrastructure hardening with the potential increases in the cost of maintenance. • Identify the interactions among humanitarian, recovery, and revenue cargo logistics, notably during no-notification disruption events.

1. Before Disruption (Pre-Planning) 2. During Disruption (Response Phase) Immediate Response Longer Term Recovery Emergency Operations Center Establish and regularly exercise a multi-stakeholder group EOC.Train all port staff on response procedures and regularly update staff telephone contact information. Include power utilities and inland modes in planning. Activate first responders and notfy stakeholder groups. Identify staffing needs, call-in appropriate first responders and law enforcement agencies along with key port personnel. Coordinate and track progress of contingency response plans associated with emergency responders and affected stakeholders. Determine and report on when conditions within the port have come back to normal and respond to requests from stakeholders for assistance in the interim. Workforce/ Responders Develop a port response and recovery plan, including a temporary housing plan, with input from police, first responders, industry, etc. to ensure that truck drivers, barge, ship and railroad workers moving cargo or carrying FEMA supplies can access the port when needed, and when safe to do so; and that both port workers and emergency responders are aware of and trained in safety issues when clearing debris and handling containers and cargo. Encourage individuals to top-off personal vehicles with fuel and store vehicles outside potential disruption area. Inform port labor force of port conditions and whether to stay home, or travel to port as usual/via designated emergency routes. Contact first responders, including any medically trained personnel deemed ncessary on-site. If applicable, utilize reverse 9-1-1 for port staff. Arrange on-site housing as needed for critical staff. Establish report-to-work areas and temporary housing and medical treatment locations, as needed for first responders and key personnel. Monitor port access for port personnel and responders and seek modifications to protocols as needed for effective response efforts, while maintaining port security. Consider needs of the families of on-site workers (provide provisions so that on-site staff can focus on work, knowing families taken care of). Coordinate with labor unions regarding labor needed, working hours and locations. Power & Fuel Supply Identify location and condition of power supply components and capabilities necessary to operate the port. Store fuel for generators and priority personnel vehicles. Locate generators above flood levels. Investigate alternatives for accessing/bringing emergency power to the port (e.g., use of solar power; possibility of reversing cold ironing during extended grid outages). Consider micro-grid technologies. Utilize EOC and stakeholders to identify power outages. Notify local power company of loss of and immediate needs for power to port facilities. Immediately repair or replace power equipment as conditions permit. Ensure continuity or quick recovery of power supply to port operations. Identify liquid fuel needs, location of resources, and best available shipment mode/route. Provide fuel to key personnel vehicles. Consider using shipboard power to assist in port operations where feasible. Re-establish and where necessary add robustness to the port’s existing power supply, including the addition of possible alternative sources of power to the port. Water Supply Maintain a list of vendors and contractors that can quickly respond to water and sewer disruptions, and if feasible, maintain on-call contracts to ensure quick response to emergencies. Collaborate with port water/sewer users and incorporate their needs into the emergency response plan. Maintain and regularly verify an emergency contact list of terminal operators and other port water/sewer users. Identify, and if feasible quickly repair, any losses of water supply, especially losses that may hamper the immediate response phase. Ensure continuity or quick recovery of water supply to port operations Re-establish and where necessary add robustness to the port’s existing water supply, Cargo Handling Equipment Prepare for bad weather to impact equipment access/utilization: Move chassis to higher ground out of the danger/any flooded areas. Stabilize cranes and protect other cargo loading equipment (e.g., fork-lifts) against high winds, water damage, or other threats as needed. Stabilize/protect container stacks. Maintain list of parts and repair vendors, with locations of off-site parts and supplies. Identify locations of closest back-ups and coordinate potential asset sharing arrangements and responses. Coordinate with port stakeholders to identify equipment damage and inmmediate needs. Monitor and quickly repair/replace faulty/damaged equipment where feasible. Stabilize/protect container stacks Seek temporary replacements/resource sharing arrangements for damaged equipment. Stabilize/protect container stacks. Coordinate with other ports/entities to seek temporary replacements/resource sharing arrangements for damaged equipment. Replace damaged equipment on a priority basis. 3. After Disruption (Recovery Phase) A. Physical/Logistical Asset Utilization Table 6.1. Sample rules of thumb.

1. Before Disruption (Pre-Planning) 2. During Disruption (Response Phase) Immediate Response Longer Term Recovery Terminal Activities Consider operational changes to facilitate moving cargo off terminal and/or limiting the amount of cargo arriving at the terminal prior to a known event. Examples include early delivery and re-routing of goods to warehouse/ distribution centers not impacted by the disruption. Identify safer (e.g., higher ground) cargo storage locations. Establish procedures for securing equipment and personnel prior to a known event. Stabilize/ protect cargo such as container stacks. Establish evacuation and recovery plans for unanticipated events. Monitor cargo handling and storage space assets. Coordinate appropriate response with port operators for the specific event as impacts become better known. Stabilize/protect cargo. Coordinate with port operators to establish working condition of port terminals and warehouses. Quantify damage to facilities, including terminals, roadways, railways, warehouses, etc. Stabilize/protect cargo. Identify costs, and if necessary, initiate funding aid requests through FEMA and other available resources. Arrange for additional labor to assist with cargo movements, if needed. Consider extending gate hours of operation. Clear debris and repair damaged structures/cargo storage areas. Establish working condition of terminals with their owners/operators. If necessary, clear debris and repair damaged structures/cargo storage areas, roadways, railways, etc. Collaborate with terminal operators and labor to establish emergency working procedures necessary for business continuity. Channels & Docks Implement MTSRU and Coast Guard coordination with port working group on equipment and steps for channel and waterways inspections. Identify equipment, personnel, and alternative resources. Establish rules for communicating disruptive event specifics with both at- dock and at-sea vessel operators. Implement response plan. Identify any channel blockages or restrictions on dockside vessel use and notify all impacted stakeholders through established communication protocol. Close impacted channels and/or docks and clear blockage Provide status updates on channel blockages or restrictions on dockside vessel use. Continue to clear channel and on-dock debris and repair navigational aids. Channel and berth dredging may be needed to address a storm-related siltation. Schedule and process vessels utilizing a pre- planned yet dynamic prioritization system capable of revising priority queues as needed until recovery is complete. Continue channel dredging as needed. Vessels Establish a Recovery Advisory Unit to prioritize vessel processing and storage berths during a disruption, and for handling containers originally destined for another port (surge planning due to cargo diversions). Consistently monitor status of disruption, and if necessary, alter delivery options (i.e., divert to another port, speed up or slow down to avoid disruption, etc.) Consistently monitor anchored vessels, and where necessary, assist at-risk vessels with loading, unloading, and securing cargo. All vessels moved from berths and secured by carriers per rules and regulations established for port operations. Continue to monitor conditions of vessels at port. Implement and monitor vessel arrival/departure prioitization plan. Once the USCG declares the port to be reopened, establish the priority order for vessel calls or diversions to alternative ports. Carriers are responsible for vessel decisions. Maintain or modify vessel arrival/departure prioritization plan during recovery period, as needed. Landside Intermodal Establish procedures for securing and/or repositioning equipment and personnel prior to a known event, including potential services and shuttles to/from alternative ports. Establish evacuation and recovery plans for unanticipated events. Coordinate with landside operators (truck/rail/barge) to develop cargo diversion plan for potential shift of services to/from alternative ports. Develop and maintain a list of on-call contractors capable of quickly repairing damaged infrastructure. Identify affected personnel, cargo handling and storage space, and inland transportation (truck, rail, barge, pipeline) assets at the port. Monitor conditions of off-terminal roadways and railways. If the disruption causes vessel diversions, coordinate with intermodal industry to respond. Assist stakeholders in searching for alternative transportation options, including potentially shared truck/rail/barge assets. Coordinate with public agencies to prioritize roadway repairs and identify funding needs. Monitor railway facility repairs. Continue diverted container services as needed and fully re-establish inland connections. Determine long term capital investments needed to restore and further harden inland connection facilities. Port Security Implement security plan and review existing condition of port boundary/fences utilizing port surveillance devices and field checks by security personnel. Check, and if necessary, repair inoperable surveillance devices. Secure port facilities and personnel. Establish perimeter security when port is closed. Continuously monitor working condition of surveillance equipment. Repair major gaps in port boundaries/fences and damage to port surveillance devices. Maintain a careful watch on port assets for safety reasons, and to prevent theft. Provide access to port workers/personnel and truck drivers aiding in recovery efforts. Possibly assist with port traffic until traffic signals repaired. Ensure that port boundary/fences and port surveillance devices are in pre-event working condition (or better). A. Physical/Logistical Asset Utilization (continued) 3. After Disruption (Recovery Phase) (continued on next page)

1. Before Disruption (Pre-Planning) 2. During Disruption (Response Phase) Immediate Response Longer Term Recovery Emergency Operations Center Ensure EOC has up-to-date stakeholder contact information for terminal operators, labor unions, law enforcement agencies, etc. involved in emergency planning and emergency preparedness and recovery drills. Contact and collaborate with private companies that use impacted shipping channels prior to anticipated disruptions. Identify alternative EOC locations where emergency correspondences can be exchanged by affected parties if need arises. Develop an access plan and communication protocol with input from law enforcement agencies, first responders, industry, etc. to ensure that truckers moving cargo or carrying FEMA supplies can access the port after a natural disaster. Maintain back-up copies of important documents in both electronic and hardcopy formats. Develop media plan for processing press releases. Contact first responders and law enforcement agencies as needed, along with key port personnel. Assist private sector stakeholders in searching for potentially shared/loaned cargo loading and transportation assets. Maintain back- up copies of important documents in both electronic and hardcopy formats. Inform/solicit input from regulatory agencies about ongoing response activities. Maintain real time contacts. Assist private sector stakeholders with recovery needs, such as searching for potentially shared/loaned cargo loading and transportation assets. Use press releases to communicate regular port operational status updates. Keep a record of lessons learned. Continue to update and solicit input from all stakeholders about on-going recovery activities. Assist stakeholders in searching for needed, including loaned assets. Update lessons learned. Terminal Activities Develop an emergency preparedness and recovery plan. Establish off-site back up locations for communications and information systems, along with procedures for continual operations during and after disruptions. Train terminal staff/workers or provide detailed information about the terminal's emergency plans to workers or their representatives. Maintain a list of employee contact information. Coordinate terminal response plans with labor unions. Provide status updates to impacted port operators via the EOC and established port communication protocol. Engage in conference calls with other organizations to expedite recovery efforts. Coordinate with labor for workforce needs. Engage in calls with suppliers and repair organizations as needed. Provide detailed information to carriers regarding conditions at and around terminals. Track status of private port and terminal operators and their needs for asset/financial assistance. Vessels Coordinate information between vessel and terminal operators to protect against cargo losses (e.g., by adjusting vessel schedules to avoid event, diverting, etc.). Before a pending natural disaster, continuously monitor weather and coordinate with USCG to secure vessels. Monitor vessel status and media reports on an event status. Monitor and update vessel priority queue as needed. Determine availability of at-dock berths and whether specific vessels should be re-docked, delayed entry, or diverted to another port. Provide regular status updates to regulatory agencies responsible for inspections to allow them to identify and provide resource needs. During major events that disrupt vessel loading and unloading, coordinate with USCG and industry to prioritize vessel calls. Check vessel priority queue and location of available dock-side vessel loading/unloading points. Landside Intermodal Communicate with key landside operators via established stakeholder coordination process, including railroad and trucking operators. Utilize media to solicit truck drivers before the event. Provide regular status updates to all impacted intermodal operators, including obstructions, damage, and closures. Provide regular status updates to key stakeholders. Communicate with media to ensure truckers and other stakeholders are aware of any changes in gate hours and other terminal operations impacting them. Utilize media to solicit truck drivers after the event. Inform railroads and drayage truckers of potential schedule changes. Communicate via industry organizations, port groups, and social media to ensure truckers, railroads, and other stakeholders are aware of any changes in gate hours and other terminal operations impacting them. Possibly utilize media to solicit truck drivers after the event. Inform railroads and drayage truckers of potential schedule changes. Inform carriers of resumption of normal operations or of any delays/changes in these conditions that may affect them. 3. After Disruption (Recovery Phase) B. Communications & Information Flows Table 6.1. (Continued).

1. Before Disruption (Pre-Planning) 2. During Disruption (Response Phase) Immediate Response Longer Term Recovery Emergency Operations Center Coordinate and collaborate with federal, state, and local agencies in advance to identify who may be impacted and how best to minimize impacts. Transmit any USCG condition-of-the-port messages to potentially affected stakeholders. Include all relevant regulatory agencies in any emergency preparedness activities. Identify the agencies and individuals to be contacted for regulatory waivers or exemptions. Establish draft language and requirements for such waivers and exemptions prior to potential events. Transmit Captain of The Port directions to activate contingency plans. Inform regulatory agencies about ongoing issues that require their attention. Identify the need for additional security/law enforcement/emergency response actions and notifications. Request waivers and/or exemptions to transport of fuel and/or diverted cargo as need identified. Include all regulatory agencies involved in goods movement through the port in appropriate recovery planning activities. Track any significant inland supply chain based modal shifts (e.g., truck to rail or vice versa). Add additional port partners as needed to coordinating group. Vessels Coordinate information between vessel and terminal operators to protect against cargo losses (e.g., by adjusting vessel schedules to avoid event, diverting, etc.). If vessel diversion to a nearby port is anticipated, develop plan for avoiding access impacts due to regulatory processes/procedures. Apply both national and international regulations to ship operations while in port during the event. Communicate and coordinate with regulatory agencies to begin identifying recovery needs. Apply both national and international regulations to ship operations while in port immediately after the event. Follow regulatory agency guidance regarding reopening of ports and waivers/exemptions for diverted cargo. Apply both national and international regulations to ship operations while in port after the event. Identify any regulations or regulatory processes that could be altered to improve recovery. Landside Intermodal Where needed, consider regulatory actions needed to establish temporary barge and rail shuttle services, as well as truck driver credentialing at alternative ports. Coordinate with regulatory agencies to identify potential access impacts that existing regulations (e.g., TWIC, port truck registration, etc.) might create. Review truck weight restriction rules; identify scenarios that may warrant temporary relief from regulations in specific port access and egress corridors. Avoid repair delays to public infrastructure by minimizing contracting time (e.g., maintain a list of on-call contractors). Follow established regulations regarding modal operations during disruptions. Establish temporary truck driver credentialing requirements to fit short-term port needs. For disruptions that create significant backlog, consider temporarily lifting the restriction on truck driver hours of operations and initiating temporary truck driver credentialing requirements to fit short-term port needs. Consider implementing temporary modification of truck weight restriction rules on specific port access and egress corridors. Work with regulatory agencies as needed to clear diverted cargo for inland movement from alternative ports (if cargo is not traveling "in bond.)" Review rail, barge and pipeline operating procedures for possible avoidable cargo handling delays. Monitor recovery and determine when to end temporary regulatory relief of port access, hours of operation rules, and/or vehicle weight restrictions. Port Security Implement pre-planned law enforcement procedures to protect port cargo and facilities from damage or theft. Coordinate with regulatory agencies and terminal operators. Coordinate with CBP to develop protocols to handle potentially diverted shipments. Use law enforcement to clear at-risk port areas and facilitate access by first responders. Maintain a careful watch on port assets for safety reasons, and to prevent theft. Work with ports and transportation providers on temporary driver credentialing and shuttle services as needed. Coordinate with CBP to expeditiously handle diverted cargo. Maintain necessary port security patrols and protocols, applying any lessons learned. 3. After Disruption (Recovery Phase) C. Regulations

98 Making U.S. Ports Resilient as Part of Extended Intermodal Supply Chains • Examine the benefits of, and models for, extending stakeholder participation to include inland transportation modes, and how different types of disruption events might benefit from differ- ent response team configurations. • On a methodological note, and given the complexities involved, the use of an agent-based micro-simulation tool suggests itself as one means of exploring alternative multi-stakeholder, supply-chain-oriented response and recovery scenarios. 6.8 References Georgia Tech Research Corporation, Parsons Brinckerhoff and A. Strauss-Wieder, Inc. (2012) NCHRP Report 732: Methodologies to Estimate the Economic Impacts of Disruptions to the Goods Movement System. Transporta- tion Research Board, Washington, D.C. http://www.accuweather.com/en/weather-news/timeline-of-events- surrounding/2665639