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PORT OF AUTHORITY FEEDBACK ON THE INFORMAL PUBLIC CONSULTATION ON THAMES LOCAL KNOWLEDGE ENDORSEMENT OPTIONS FOR ASSESSMENT MARCH - APRIL 2014

For / Against Consultee/Organisation Summary of Feedback FOR Kevin Boyd – As you may be aware we operate up to . Due to the tonnage / size/ bollard pull of Svitzer our vessels we cannot operate them under the BML. Therefore our crews are STCW95 certified. This has caused an issue regarding LKE not “bolting on” and the fact that we had to do the full area up to Putney. We have had to take the PEC route, again not ideal as we do not regularly 1 transit through the area and it will be difficult for all masters to complete enough trips per year. We would welcome a stand alone LKE from Margaretness to London Bridge that would be recognised alongside our existing STCW95. Thank you for your supportive response. Your comments have been noted.

AGAINST Roger Flitter – The majority of our Members operate in both areas and as such the status quo is most Passenger Boat Association appropriate for them. From inception there have been various applications for restricted LKEs to reflect the circumstances of individual operators. Such applications have been refused on the grounds of maintaining one consistent LKE with all holders having equal knowledge of the river. Boat Masters holding a restricted LKE would be limited in employment options unless they were to

convert to a ‘full’ LKE. Employers advise that they would much prefer to employ a full LKE holder

over a restricted LKE holder. Noted, but other employers would prefer to employ a restricted Local Knowledge Endorsement (LKE) Holder. In addition, the proposal is simply offering applicants and 2 employers a choice, and does not force applicants to apply for one or the other restricted LKEs.

How will the PLA be in a position to ensure that restricted LKE holders will not infringe the area for which they are qualified? The PLA currently has a wide range of procedures in place to confirm compliance with the

LKE requirements; including through River Works Licensing, Vessel Licensing, Event

Management, during incident investigation and ‘ad-hoc’ spot checks. We are particularly looking to widen the scope of the spot-check regime.

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Increasing traffic (both passenger and freight) will not be well served by the operation of a restricted LKE. The interaction between traffic above and below London Bridge dictates a need for awareness and appreciation of all activities irrespective of being Master of a passenger vessel or a tug propelled 800 tonne barge. The proposal includes an overlap between and Wappingness and, as with the

existing LKE; the exams will include questions about the area above and below the defined limit to address this point.

The Consultation briefing implies that a restricted LKE will contribute to improved safety standards. Given our comment above we are at a loss to see how this can be achieved. The benefits of the restricted LKE regime are seen as a short term solution only from which we see no legacy benefits to be gained once the major civil engineering projects are complete. Future and proposed engineering projects are all located to the west of London Bridge and BML holders supporting these projects will be required to hold the full LKE. This proposal is not linked in any way to any current or future infrastructure projects.

The only suitable LKE for the tidal is the current established LKE of Putney to Margaretness. The PLA has demonstrated through risk assessment, the requirement remains for an LKE from Putney to Margaretness for masters of vessels that navigate from Putney to Margaretness.

The PBA have not demonstrated why a whole area LKE must apply to the masters of vessels that cannot navigate or do not ever trade above London Bridge.

AGAINST Rob Hart The enforcement of local knowledge endorsement is not very effective now, let alone with the confusion of segmenting the area. The PLA currently has a wide range of procedures in place to confirm compliance with the LKE requirements; including through River Works Licensing, Vessel Licensing, Event 3 Management, during incident investigation and ‘ad-hoc’ spot checks. We are particularly looking to widen the scope of the spot-check regime. We currently receive reports of non LKE holders and welcome further reports from anyone who is aware of such an occurrence.

AGAINST Alexander Hickman Firstly, I would question the statement that the local knowledge endorsement is an onerous one to obtain. Where is the evidence to support this? Currently, the LKE is onerous in the sense that applicants operating in a limited part of the

LKE area or on vessels that are physically unable to navigate above the bridges are assessed on the full LKE area, including those parts where they never navigate.

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4 In 2005, London was the target of a terrorist attack which led to the transport network being paralysed. Operators evacuated Central London with some success. If the local knowledge area were to be divided up then this ability could be compromised. The vast majority of Class V passenger vessel operations extend from Westminster to Greenwich and those masters will therefore hold a full LKE. Offering a choice of LKE to

candidates is highly unlikely to impact on a national security incident as you suggest.

Within the BML regime all local knowledge areas have been established around the UK as individual areas and are not zonal. The reason for this is that this meets the necessary safety standards whilst retaining the notion of a mobile workforce. Finally, I welcome the review and would ask in my absence that the PLA consider a proposal to extend the local knowledge area with lower reaches to be included in an extended LKE area. Furthermore, the upper tidal reaches, while less obvious, are an area where passage planning is more problematic. The PLA has considered this matter as part of a Navigational Risk Assessment Working Group, which established that there is currently no case to extend the LKE area beyond the existing limits.

The only addition I would make would be that the PLA should seek an independent risk assessment be undertaken to ascertain the areas of risk as was carried out by Marico Marine over a decade ago. This way there is no question of confirmation bias to skew the process. The PLA has a demonstrable record in the last 15 years of being more than capable of undertaking fully objective, robust and thorough navigational risk assessments.

FOR John Hogan – Only the and the Twin Star will not transit through both the proposed areas. I fully PLA understand that a BML/LKE is for a person and not a vessel, but generally the masters of these vessels do not work elsewhere. Why the skippers of the Woolwich ferry need to be tested above the barrier, or the Twin Star's tested above Cuckolds Point and below Greenland dock could also be questioned. The only other vessels it currently affects would be the sail barges and the Prior fleet. Now this may have changed, but last year there was some doubt over whether Prior skippers did in fact have LKE's. There are other current operations that operate locally. The PLA has always maintained 5 that it does not support local LKE endorsements for specific, restricted operations, such as the Woolwich Ferry or London Duck Tours.

If it is, my only concern would be the area designated as a cross over, according to the consultation notice this would be between London Bridge and Wappingness. This area can be very busy especially during the summer months. If this is going to be a handover area for barges, then careful planning and management will be paramount and subsequent LKE assessments should reflect that.

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The PLA would not accept the changeover of barges in this area. Such operations would be considered under the requirement for a risk assessment under General Direction 12. It would be expected that the masters of vessels operating in the whole LKE area would hold a full LKE in order to fulfill the operators’ requirements.

FOR Peter Hugman – We are pleased with the proposal to give BML Local Knowledge Endorsement holders the CBOA opportunity to choose from the three options for a LKE and would support this proposal. However we are concerned that the consultation paper does not include any information on any changes to the current assessment procedures and therefore have to assume that these will not change. Hopefully you can confirm this? The BML LKE regime is administered by the MCA. There will be no change to the administration of the BML LKE system that we are aware of.

We are especially concerned with the statement ‘This flexibility will also allow candidates to be more rigorously examined on the area in which they will normally operate, rather than on an area

where they never operate, so raising standards’.

Current LKE holders may operate mainly in one of the ‘restricted’ areas but are able to retain certification for the whole area despite marginal on-going operational experience in other areas. This is very important for continued labour mobility/retention and is a realistic system which 6 should continue.

It is important that the new proposals do not force someone in this position to ‘choose’ a restricted area which would then tie them to one type of employer.

We also question the intention to more rigorously examine LKE as the standards required should stay the same even if the examiner has more relative time per mile of river.

Can you please give further details on how you see this working in practice and confirm that though PLA intend to raise standards this will not mean LKE holders will need a greater detailed knowledge than at present. The LKE assessment process will essentially remain unchanged; the only difference being that candidates will be offered a choice of LKE area to be examined on. The choice of LKE area always remains with the individual, and therefore the responsibility to ensure sufficient experience and knowledge of the area of choice (full or restricted) remains entirely with the BML holder.

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FOR Chris Livett – It is my view that this could assist in employing people however I do have a number of Livett’s Launches reservations, as follows: 1. Administration – by who, how often and how? 2. Policing – by who, how often and what are the penalties? The BML LKE regime is administered by the MCA. There will be no change to the administration of the BML LKE system that we are aware of. 3. Upgrading – how, by whom and how often? Candidates will be assessed on their experience and knowledge when they submit for examination. The choice of LKE remains with the candidate. 4. Will there be an additional cost? As now, there will necessarily be a charge for any LKE examination. 5. Will grandfather rights apply at transition? Yes – subject to agreement by the MCA. 7 6. Will current BML/LKE holders be able to scale down? The choice of LKE will remain with the applicant, so in principle, yes. 7. Will there be any equivalent i.e. Rhine Ticket, RYA? The status of the BML LKE will not change. The proposal simply offers the candidate a choice. 8. How many awarding bodies will there be? Only 1 – PLA? 9. If so, will they have the power to delegate? The BML is administered by the MCA. We do not believe this will change. 10. Where is the curriculum for LKE areas proposal? There are no changes to the syllabus – See MGN 334. 11. Is there any funding for training LKE’s? The PLA is not aware of any funding being available. 12. If not, what will the cost be? The PLA’s proposal does not change the training regime. It simply offers a choice to the candidate, depending upon his/her area or potential area of employment. 13. For existing LKE/BML holders who currently ‘trade inside’ the LKE areas i.e. Svitzer and Priors, will there be grandfather rights? Any person not holding a BML LKE and wishing to work in charge of a relevant vessel in the LKE area will be required to sit either a restricted or full LKE examination. Thank you for your supportive response. Your comments have been noted.

AGAINST Daniel Ludwig I am of the opinion that anymore flexibility in the LKE requirements can only be a detriment to safety standards on the river as a whole. As stated on the consultation notice, passenger and freight traffic has surged and will continue to do so in the future with regards to the tideway tunnel and any other proposed projects. I believe that these facts alone are a reason to examine more rigorously any candidate wishing to ply their trade in any area of the LKE limits. By sectioning the

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LKE requirements would also limit candidates to any future work outside the areas they operate. 8 I have 20 years experience working on the river and believe that over the past 7 years since the introduction of the BML the standard of knowledge and experience of new employees has dropped considerably. The standard of young people learning the trade has also dropped due to fact that they can obtain their license by the age of 18 through examinations on paper and then

obtain their full licence with age and not with knowledge and experience afloat.

I also believe that the proposals will be taken advantage of to uphold licenses and by employers to employ under skilled labour for positions they are not qualified for, the result of this will certainly be a reduction in safety. Therefore I do not agree with this proposal. I do agree with a more rigorous test, but for the whole area. The BML requires a minimum of 240 days experience in 2 years and consists of oral and practical examinations exceeding that of the previous regime. The quality of the new BML examination regime is reflected in a consistently high standard set for the examinations evidenced by the current poor pass rate of candidates.

The PLA is actively supporting a number of initiatives to improve training standards, including considerable financial and other support to the Thames Training Alliance. AGAINST Mark Macpherson It is my opinion that there cannot be more flexibility over the LKE requirement without there being a detriment to safety. Having stated that the expected standards of safety have risen. With the increase in traffic the standards should be raised again and not lowered. From my experience I do not believe safety on a whole a risen, and there are more incidents occurring now than from 10 years ago.

Knowledge and experience generally speaking is at its lowest it has ever been on the Thames and I feel that by sectioning the LKE area will only make this worse. It is also human nature that some people will use this as a loophole to uphold licenses and use them in areas which they should not 9 ply their trade. How will this be policed? This would make the workforce less flexible to do more work in the future as the infrastructure of the River and London itself evolves. I agree with a more rigorous test, but for the whole area.

It has now become possible to achieve their qualifications in terms of paperwork and examinations by the age of 18. It is in some of their characters that because of this they feel that they do not need to continue learning and it has just become a question of time for them before they receive their full license.

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The employers are taken advantage of loopholes and employing under skilled people for roles that they are not ready for, thus reducing safety. The BML requires a minimum of 240 days experience in 2 years and consists of oral and practical examinations exceeding that of the previous regime. The quality of the new BML examination regime is reflected in a consistently high standard set for the examinations evidenced by the current poor pass rate of candidates. The PLA is actively supporting a number of initiatives to improve training standards, including considerable financial and other support to the Thames Training Alliance. AGAINST Ben Mann Would these changes not just be making it a whole lot easier for those abroad etc. to come over such as the Dutch and get an easy local knowledge endorsement for the upcoming tunnel work? I understand this may have been brought about because of worries about not enough men and vessels to fulfill the large amount of work needed. 10 Current proposed engineering projects are principally located to the west of London Bridge and BML holders supporting these projects will be required to hold the full LKE. This proposal is not linked in any way to any current or future infrastructure projects.

AGAINST Scott Neicho – In my opinion the proposed creation of the shortened LKE areas is a bad idea and will lead to Capital Pleasure Boats abuse and, possibly accident or loss of life. The current system is already unpoliced and it has been exposed that the current licenses are unchecked. If the licenses are unchecked then the system is open to abuse at all levels, from unqualified crew to uninsured vessels or companies. This cannot be good for the Thames. I refer to MSN 1808 (M) and I agree we do need to facilitate trade but we need to do this in the safest way possible. I am of the strongest opinion that what the PLA is proposing will not enhance the river or its core safety. The PLA currently has a wide range of procedures in place to confirm compliance with the LKE requirements; including through River Works Licensing, Vessel Licensing, Event Management, during incident investigation and ‘ad-hoc’ spot checks. We are particularly looking to widen the scope of the spot-check regime.

11 I would ask the PLA to once again look externally to have risk assessments conducted as to the amount of current traffic and that proposed over the next decade to see if a split LKE would be even be considered. The PLA has a demonstrable record in the last 15 years of being more than capable of undertaking fully objective, robust and thorough navigational risk assessments.

As a practitioner I believe the split would be abused by those without the qualification to pass between all areas just to ‘get the job done’ as it is now with ‘Svitzer’ and ‘Priors’ without PLA enforcing the current bylaws upon them. The PLA is content that through the existing procedures and additional spot checks that offering candidates a choice of LKE will not lead to an increase in risk in non-qualified BML holders.

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I would like to ask once again who examines the PLA BML/LKE examiners to ascertain their credibility to be able to issue commercial endorsements on the Thames as every examiner in any other industry will have to hold examining qualifications to rubber stamp a pupil. As previously stated there is currently no requirement for LKE examiners to hold any qualification other than a valid Thames Local Knowledge Endorsement or higher standard of Local Knowledge.

AGAINST R.A. Prentice – I attended the meeting at Bakers Hall to discuss the PLA proposal to change the existing LKE requirement. As a boat operator I made several comments which I trust were minuted and which I stand by. I see no benefit in your proposal to offer three options, as to which area between Margaretness and Putney someone wishes to operate. This would just dilute a very small LKE area even more. I must disagree with your comment that your proposal would allow candidates to be more rigorously examined, in my experience I doubt this would ever happen. These are areas within the LKE that are small and very congested. I believe is even more important to keep the LKE area at least there it is now. 12 Finally, a major concern of mine is that with the limited resources that the PLA have, they cannot police the existing area if it is changed to three different areas and it will be impossible. The PLA currently has a wide range of procedures in place to confirm compliance with the LKE requirements; including through River Works Licensing, Vessel Licensing, Event Management, during incident investigation and ‘ad-hoc’ spot checks. The PLA is content that through the existing procedures and additional spot checks that offering candidates a choice of LKE will not lead to an increase in risk in non-qualified BML holders.

AGAINST G.W. Rutland In 2007 the river community witnessed the end of what had proven to be a reliable and exceptionally high of standard training and licensing system, The Waterman and Lightermans licenses. The PLA played no small part in this and you, as a body, were warned at the time that this would lead to a general decline in safety and competency standards across the board. The fact that you deemed "Local Knowledge" only applicable above Margaretness, and below Putney is quite frankly unacceptable. Below Margaretness, as you know, is the commercial hub of

the port with large ships entering/leaving Tilbury Dock, shipping arriving/departing berths and abnormal tidal effects around broadness (which can easily cause trouble for those that are 13 unaware). Above Putney you have reduced depths and limited room to manoeuvre, increasing the need to know every kink, bend, shallow spot and tidal set so as to ensure safe passage of craft. It hardly seems in keeping with the modern day culture of accountability that you, as a port authority would allow someone to work in these areas without some form of accreditation.

I would like to have recorded that as an experienced tradesman i consider that if we are to have a Local Knowledge Exam it should be one exam and be for the whole of the tidal Thames! That

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would provide a labour force with a deeper understanding of our river and produce skilled men able to work upon the entire length of the river. Thank you for your comments. In December 2013, the PLA recently completed a detailed risk assessment into the requirement for a Local Knowledge Endorsement across the entire length of the tidal Thames, which included an analysis of incident data. This risk assessment was conducted with a range of practitioners and concluded that a Local Knowledge Endorsement was not required outside of the area from Margaretness to Putney Bridge.

FOR J Spencer– For once I am pleased to say that the proposed changes have my whole hearted support. I GPS Marine consider that they will make commercial operations easier as people who need to operate above Margaretness but have no desire to work above bridges will now be able to do so without having to learn about something they have no with to, and never will, do. Similarly, those who do not work 14 below Wappingness will not be required to learn about the Barrier and a World they don’t encounter either. The winner will definitely be operational flexibility but I can see no possible scope for any deterioration of the standards of safety in the LKE areas. Thank you for your supportive response. Your comments have been noted.

FOR John Stafford – This is a welcome and long overdue change. It has several advantages. For those that have not PLA Pilot and do not wish to work the whole area this would remove the requirement to become familiar and retain familiarity in the unused part. Splitting the area would allow people to take the examination in two parts. At the moment it is a huge amount of learning, which is OK to the academic amongst us but is a mountain to climb others. It will allow a more in depth search, at examination, of a candidate's understanding of the navigational challenges.

At present all LKE holders are able to transit the whole LKE area. For many of them their whole 15 work pattern restricts them to one part. So at present it could be that a holder could spend 4 years or so in one area, losing any familiarity with another, and then being able to switch areas. In fact to make his/her re validation this may be actually a more likely event.

At the moment the Port makes very little attempt to monitor who is working on the river at any one time. The most we do is inspect a master's certification following an incident. Speaking with a number of Thames operators they have never heard of the HSL stopping them to inspect their BML. This is something that the PLA should address. I cannot see why we do not make a master report to VTS with his identity and BML number on request. This could then be checked against a database. Thank you for your supportive response. Your comments have been noted.

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FOR Mark Tower – I have been working on Thames sailing barges in the Pool of London for the last 27 years and I Thames Leisure would like to support the proposal sent round in your consultation notice. I currently operate and crew on Sailing Barge Will which does not, cannot, operate above London Bridge and therefore the option to have an LKE requirement ‘below bridges’ for Thames Barge skippers would be most 16 welcome. I cannot speak for other Thames sailing barge owners or skippers but I would be very surprised if they did not also welcome such an approach. Thank you for your supportive response. Your comments have been noted.

AGAINST Colin Window – I was apprenticed in 1970 and served a 6 year apprenticeship to gain my licenses. I had to gain Woolwich Ferry full knowledge of the River and be aware of all movements of other vessels and would calculate that into any work we were partaking in at that time. Since then our licenses have been altered to the BML with LKE endorsement from Margaretness to Putney. In my experience, working with some of the recently licensed men, their knowledge and skill set is not at an acceptable level. If the LKE area is reduced again then in my opinion this will lead to a less capable workforce and a higher risk of accidents. I can also see a problem with how these different licenses will be policed. Circumstances may exist where an unlicensed man is working in an area where they 17 have zero knowledge at all. The BML requires a minimum of 240 days experience in 2 years and consists of oral and practical examinations exceeding that of the previous regime. The quality of the new BML examination regime is reflected in a consistently high standard set for the examinations evidenced by the current poor pass rate of candidates.

The PLA is actively supporting a number of initiatives to improve training standards, including considerable financial and other support to the Thames Training Alliance. AGAINST Colin Middlemiss – No mention is made of any risk assessment after 2006/7. Has there been one and if so, what are Company of Watermen & the results? Lightermen Yes, in December 2013, the PLA recently completed a detailed risk assessment into the requirement for a Local Knowledge Endorsement across the entire length of the tidal Thames, which included an analysis of incident data. This risk assessment was conducted with a range of practitioners and concluded that a Local Knowledge Endorsement was not required outside of the area from Margaretness to Putney Bridge.

18 It is not clear what basis the PLA are using for their “expected” standards. The Consultation offers no proof of any rise of safety standards. If the PLA argument is accepted (and the Company does not do so) that standards have exceeded expectation, why is it necessary to alter assessment of the Thames Watermen’s LKE. The proposal to split the LKE has been put forward to offer a choice to BML holders that only operate in a restricted part of the existing LKE area.

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There is still no firm evidence of what effect the Thames Tideway Tunnel (TTT) will have and the suggested figures coming from a variety of courses including TTT, for example likely skippers needed, are still dramatically changing. This alone suggests no change to the existing regulatory regime until at least the picture is clearer. Current proposed engineering projects are principally located to the west of London Bridge and BML holders supporting these projects will be required to hold the full LKE.

This proposal is not linked in any way to any current or future infrastructure projects. We have nearly seven years practical and administrative experience of the current national BML on the tidal Thames, together with the associated LKE.

This statement does not offer any evidence for a change. What does the seven years experience tell the PLA? After seven years practical implementation of the BML, the PLA is able to identify the positives and negatives of the current regime and address the negative issues. There is a requirement for more flexibility over the LKE requirement without any detriment to standards of safety.

Why is there a requirement for more flexibility and if it is not to be detrimental to standards of safety, why will it maintain or improve such standards. Which of the current LKE area reaches is causing the PLA to suggest a change. The PLA seeks to provide BML holders with a choice on LKE areas as many BML holders only work in limited areas but are forced to be assessed for the whole area under the current regime. The PLA had made no suggestion that any particular reaches of the river have prompted this proposal.

It is the Company’s strongly held view that the PLA and MCA cannot properly enforce the current requirements for Thames Watermen’s LKE. Unless coordinated and proper enforcement is introduced any change to assessments is meaningless. The Company sees no sign of this enforcement situation changing for the better. It is proposed that candidates seeking to obtain the Thames LKE in support of the BML be offered three options as to which areas of the LKE area they are assessed, i.e. either the whole area as now, from Margaretness to Putney or Margaretness to London Bridge, below bridges.

Why London Bridge? The waters between Tower Bridge and London Bridge are surely one of the most congested with some of the most crossing traffic on the river. London bridge is a physical barrier for many operators and is a natural break point for the LKE.

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The choice for an assessment “above” or “below the bridges”, or for the whole area, enables the LKE to be more tailored to meet actual operational needs.

Whose operational needs? If “others” is to be taken to mean others’ operational needs then exceed the responsibilities of the PLA for navigational safety. The PLA’s responsibilities extend beyond navigational safety to promoting and encouraging use of the port. This proposal seeks to address a current barrier to increased use of the Thames without impacting on safety.

This flexibility will also allow candidates to be more rigorously examined on the area in which they will normally operate, rather than on an area where they never operate, so raising standards.

“Never” is a very strong word, in an emergency, vessels and crew maybe required to operate outside their normal area. Restricting a license severely reduces individual’s opportunity to work elsewhere. This might be accepted if a proper safety risk assessment case is made. Given the earlier unproven assertion in this consultation that “expected standards of safety have risen”, please explain why there is a need for a more rigorous examination. Can the PLA explain how the criteria set out for assessing Local Knowledge are met by the PLA’s proposal to change assessments? PLA is not proposing to change assessments other than to allow BML holders the choice to be assessment for a full or restricted LKE.

Can the PLA explain how the proposal to have a more complete system for LKE requirements on the Thames, assists the delivery of “underpinning of safety standards whilst helping facilitate trade and movement of labour on the UK’s inland waterways, and on those in other EC countries (see MSN 1808 above). The PLA has demonstrated through risk assessment, with input from operators that offering a choice of LKE will not impact on safety. A choice of LKE will address a current barrier to BML holders working in a confined area of the Thames, encouraging further growth and trade as supported by a number of operators

The Company believed that with the consent of the Authority (PLA) the name of the local knowledge for the Thames was agreed as “Thames Watermen’s Local Knowledge Endorsement. This does not seem to have been reflected in the current consultation. The PLA has always maintained the LKE should be called the Thames LKE area, but has not challenged the MCA’s use of Thames Watermen.

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The Company has previously argued in the earlier consultations on the BML and LKE that the present limits of the Thames Watermen’s Local Knowledge Endorsement are insufficient to maintain safe passage. The Company believes the arguments for LKE below Margaretness have been strengthened by the Medway being allocated an LKE which confirms the difficulties of navigating these Thames estuarial waters. Yes, in December 2013, the PLA recently completed a detailed risk assessment into the requirement for a Local Knowledge Endorsement across the entire length of the tidal Thames, which included an analysis of incident data. This risk assessment was conducted with a range of practitioners and concluded that a Local Knowledge Endorsement was not required outside of the area from Margaretness to Putney Bridge.

The Company wants to see local industry practitioners utilised for local knowledge endorsement examinations on the examining panels with MCA examiners. Most MCA examiners are more than appropriately qualified Master Mariners, but they may lack the necessary detailed knowledge and the addition of some expertise on the local knowledge area seems highly desirable. The MCA utilise industry practitioners to examine local knowledge in support of MCA examiners.

Local industry practitioners should be utilised as examiners for local knowledge endorsements, as they have in depth knowledge of local conditions and should be appropriately remunerated. This is a matter for the MCA.

There are no arrangements in place for assessing the suitability of industry practitioners to undertake any BML examination duties. In the same way as MCA examiners are undoubtedly trained, arrangements should be introduced for the training and assessment of industry examiners to ensure consistency of methodology, process and standards. This is a matter for the MCA.

Summary of Feedback

FOR the Proposal Organisations - 5 Individuals - 2 Total - 7 AGAINST the Proposal Organisations - 4 Individuals - 7 Total - 11

Total Responses - 18

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