Preliminary Business Case j 1

PPM DOCUMENTATION

PRELIMINARY BUSINESS CASE

MCA Clyde

PPM

Author:John Morphew

Owner: BillMcFadyen

Client: Maritime and Coastguard Agency

Document Number: [0.07]

Release: [0.11

Date: 10/07/2012 ca Preliminary Business Case I 2

Preliminary Business Case History Document Location

• This document is only valid on the day it was printed.

• The source of the document will be found at TBC.

• The approved master copy of this document will be found within the relevant registered file for the project. Revision History • Dateofthisrevision: 07/01/2012

• Date of next revision: N/A

. Previous Revision. Date Summary of Changes Changes Marked Revision Date

. Initial working draft identifying First Draft operational input requirement

Updated working draft following initial 17/11/11 29/9/11 discussions Clyde

Update following receipt of clarification 07/02/12 17/11/11 responses from Clyde, including draft Team Leader Base (TLB) needs

Update to incorporate Team Leader 07/06/12 07/02/12 Base requirement, options analysis and financial evaluation

Update following on site review with

, staff. Includes additional space for CPSO,update on analysis of IBMand 10/07/12 Clydebank sites. Feedback from initial finance review and evaluation of the impact of excess fares.

inca Preliminary Business Case I 3

Approvals . This document requires the following approvals:

. Date of Document Name Signature Title Issue Version

S Ketteridge Director of Strategy & Finance

B. McFadyen AD Future Programmes and Support

Peter Dymond Acting Chief Coastguard

Jane Jackson AD Finance

Paul Coley AD Ship Standards

John Morphew AD Asset Management

National Director: Business Delivery Tom Borland (S&l)

Director Maritime Safety and Philip Naylor Standards

Richard Parkes Director of Maritime Operations

Mark Stockwell Head of CT Case 4 Preliminary Business I

Distribution

. This document has additionally been distributed to:

Purpose of Document • To document the justification for the decision to retain an operational site within the Clyde area on expiry of the Navy Buildings Greenock property MOTO from December 2012. • The Preliminary Business Case is used to say why the forecast effort and time will be worth the expenditure. It should confirm that the business justification is robust, and in principle the proposal meets the business need, is affordable, achievable, explores appropriate options for delivery, and is likelyto achieve value for money. • The on-going viabilityof the project will be monitored by the Project Board against the Business Case. • The Preliminary Business Case is used to enable the progression of a project to the key decision stage for OGC Gateway Review 1: Business Justification.

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I. Strategic Fit

This aspect of the business case explains how the scope of the proposed project fits within the existing business and operational requirements of the organisation, and the case for change in terms of the existing and future operational needs of the organisation.

1.1 Executive Summary

1.1.1 The MCAhas a requirement to retain an operational facility in the Glasgow area to accommodate the following business units: Glasgow Marine Office Stability Unit Enforcement unit Deputy to SoSREP Counter Pollution Team Leader Base Coastal Safety Manager

1.1.2 This business case has been developed on the principle that optimum Value for Money will be achieved through co-location of MCAoperational business units. It is assumed that the business need will endure for a 10 year period, although it is recognised that the review of Survey and Inspection, may have an impact on business need during the life of any solution.

1.1.3 The operational review of options discounted the Orpington model for Surveyors operating from home as this arrangement is to date a one off solution, developed to meet a specific need in that area. Time is required to develop and agree an Agency wide operating from home policy, which may influence future space planning and opportunities for rationalisation of floor space in the future.

1.1.4 The financial appraisal has considered market rate rents based upon initialdiscussions with landlords, agents and the MCA Estate advisors. All indications are that detailed negotiations for the final solution would identify further benefits from incentives, such as rent free periods and a reduction to the headline rent rate per square foot. The preferred option is affordable in future years based on current financial planning assumptions.

1.1.5 Noting that there are strategic decisions to be made on Survey and Inspection activity, this document identifies option 5, West Point Business Park as the solution which best serves the needs of the MCAover the 10 year term.

1.1.6 This business case also recommends that excess fares are offered to eligible staff, for a minimum 3 year period. Over the 10 year term, this has a negligible impact upon the Net Present Value and affordability of the solution, but is considered a risk mitigation measure to retain administrative staff supporting the Marine Office, Stability Unit and Coastal Safety Team. Preliminary Business Case I 6

1.2 Business Need

1.2.1 Business Objectives

1.2.1.1 The high level business objectives proposed for this project can be summarised as:

• BO I Operational Response: Maintain the same level or better of surveyor operational response and an operational capability for the Team Leader Base.

• BO 2 Administrative Support: Maintain the same level of administrative support to the collocated operational functions.

• BO 3 STCW Frontline Functions: Maintain the same level or better service to front line customers in all aspects of STCW examination of candidates.

• BO 4 Stability Unit Functions: Maintain the same level or better service to all customers in all aspects of Stability Survey and the ship stability and subdivision policy development support.

1.2.2 Common Standards

1.2.2.1 The physical building architecture and data network must comply with the MCA Information Security Policies, in particular the Information Security Statement and Manual (ISMS 5), Asset Management (ISMS 7), Physical and Environmental security policy (ISMS 9), Software and Data control (ISMS 10) and Access control (ISMSI1).

1.2.2.2 To comply with the Cabinet Office controls, the business case has assumed that the floor space can be reduced to 8 sq.m. per person, operating in an open plan environment. It is recognised that the bespoke requirements of the Stability Unit (SU), Marine Office (MO) and Team Leader Base (TLB), will influence attainment of this assumption. Any variances to the assumption will be detailed under requirements for each business unit. The small numbers of staff with bespoke requirements in the SU, MO and TLB, effectively negate any potential to plan for 1.2 FTE per work station within the available space.

1.2.2.3 There is a common requirement for a large meeting space, to host up to 25 delegates. This space should be configurable and provide capability for local reconfiguration between meeting room and conference style.

1.2.2.4 The future solution should allow sufficient space for secure and air controlled storage of ICT equipment, as a minimum this would_require rack space for 2 admin and operational system servers, a Telephone Management system and UPS to allow controlled power down in event of electrical mains failure.

1.2.2.5 The planned Full Time Equivalent complement for the site is 36, including the provision of space for an additional Enforcement person, the TLB and an internship student. This equates to a minimum space requirement of 288 sq.m., excluding welfare facilities and storage space for Personal Protective Equipment (PPE). There are additional needs for storage of evidence items, operational equipment together with the TLB meeting room and training facilities. Making an allowance of 120 sq.m. of space to mca Preliminary Business Case 7

meet this additional operational requirement, provides a minimum requirement for options analysis of approximately 410 sq.m, equating to approximately 4400 sq.ft.

1.2.2.6 The following paragraphs provide additional information on each business unit’s needs.

1.2.3 Glasgow Marine Office requirement

1.2.2.1 The operational response and administrative support roles are provided through the Glasgow Marine Office. This complement consists of: AOMxI TPM x 1 Surveyors x 14 Admin Staff x 4 Total staff Full Time Equivalent 20

1.2.2.2 Glasgow Marine Office Surveyors cover the mainland area from the Solway Firth to Cape Wrath, all the islands of the West coast of Scotland, Shetland as well as fishing vessels south of Edinburgh to the Scottish border.

1.2.2.3The following list summarises the work completed by Glasgow Marine Office staff (based on 2010/2011 unless otherwise stated)

• Port State Control Inspections — 100; • Oral exams: total 870 (BML= 93; Engineer = 268; Deck = 509) • Customer Service Management of 11 companies, located mainly in Glasgow city centre • Surveys = 526 • Enforcement follow up 12

1.2.2.4 The Administrative team complete the daily and weekly forecasted ships list, input all survey & inspection forms, carry out administrative functions for: examinations, financial reporting, travel arrangements, seafarer documentation and provide support to collocated business functions.

1.2.2.5 The geographic area covered by Glasgow Marine Office requires a location that has good transport links in a central location with easy access to the M8, Erskine Bridge, airport and public transport links to minimise the impact upon the customer base in terms of travel time and cost. This would also be desirable for staff access to site.

1.2.2.6 The new location willrequire provision of a customer reception counter for dealing with the leisure and seafaring community.

1.2.2.7Surveyors are a mobile work force attending a central office for work flow allocation, preparation and completion of certification documents, prior to travelling to outports within the service area for ship inspections or surveys. They utilise a large amount of heavy & expensive equipment such as PPE and IT, during these ship inspections and surveys. Removal of this equipment from vehicles on each visit to the office would be inefficient, whilst leaving the equipment at remote car parks, could expose the Agency jca Preliminary Business Case I 8

to an unacceptable risk of loss, through theft. A minimum of 16 car park spaces are required to service the Marine Office surveyors, with close proximity to the office to mitigate security and manual handling risks.

1.2.2.8 Surveyors require the capability to carry out plan approval. Whilst some work can be carried out electronically, the ability to review AD drawings on a flat surface is a requirement. This facility should ideally be provided adjacent to extant networked workstations and reference material. In addition to this space it should be available to house an appropriate electronic plotter to support printing of electronic plans.

1.2.2.91n 2010/2011 there were approximately 900 exams completed in Glasgow Marine Office. Each exam takes approximately 90 minutes to complete, equating to approximately 175 days of exam room occupation per annum. Deck/Engineering examinations may be held simultaneously, therefore 2 similar sized rooms are required. Whilst exam rooms may be dual purpose, they should allow for secure storage of examination equipment during other use and sufficient sound insulation to prevent disturbance of candidates during examination.

1.2.2.10 The Admin support team maintain the Daily/Monthly cashbook in accordance with MCA Procedures for the operation of Bank Accounts and Cash Handling, receive and forward the “completed ships” official log books and crew agreements as agreed with the Public Record Office (PRO). The Admin Support Team carry out functions that involve issuing Discharge Books, British Seamen’s Cards and Boatmaster’s Licences. These documents require secure storage and a controlled issue procedure is in place to avoid the possibility of fraudulent use.

1.2.2.11 The Marine Office staff require access to networked ICT systems and off network capability for surveyors’ laptops. The list of current ICT equipment is provided at Annex A.

1.2.2.12 Each Surveyor is provided with PPE; a total of 16 lockable PPE storage cabinets with changing room and drying facilities willbe required.

1.2.3 Stability Unit (SU) requirement

1.2.3.1 The SU complement is made up as follows: Grade7 Xl MSI X3 MS2 X2 EO Xl Graduate x I (Internship Development programme currently in discussion within DMSS) Total staff Full Time Equivalent 8

1.2.3.2 The SU’s primary function is the approval of ship stability information. The unit carry out plan approval work for the whole of the MCA.

1.2.3.3 The SU approval work relies heavily on computer hardware, software and relevant support equipment. Each member of the unit requires a dedicated workstation. Each workstation is to be provided with dual 22” monitor arrangement, for working across Preliminary Business Case I 9

multiple applications simultaneously. It is also essential that available working space on each workstation desk must be sufficiently sized to accommodate: • Active Consultative Marine (CM)files -including drawing pockets-, • Minimum of Al sized plan, • Telephone, • Keyboard and mouse, • Stationery tray

1.2.3.4 Design activity should consider traffic flow, to minimise noise disruption to the SU activity, where possible provision of special or physical segregation from high noise activity. The SU work stations should be isolated from each other with low level sound barriers.

1.2.3.5 The SU require specialised equipment in close proximity to the workstations by way of a digitiser, scanner and AC plotter, with associated dedicated workstation and plan approval table.

1.2.3.6 Provision of an additional training work station is a mandatory requirement, to support training of newly appointed surveyors. l.2.3.7SU surveyors may be required to support survey activity and inclining experiments. Provision of 8 PPE lockers and suitable changing facility required to support the unit.

1.2.3.8 The SU require Ad-Hoc access to a meeting room for meetings with customers, approval plan peer review meetings and business unit meetings. This could be dual function with other users on site.

1.2.3.9 The SU, holds around 100-120 cases at different levels in the process of approval; therefore for an effective management of the cases it is essential to have storage capacity for the “in hand” case CM files.

1.2.3.10 The SU require access to networked MCAsystems and a Fax machine.

1.2.4 The Enforcement Unit (EU)

1.2.4.1 The Enforcement unit is currently a Headquarters post located in the Glasgow Marine Office. It comprises one MS1 Grade Enforcement Officer with Ad-Hoc support of an Assistant Enforcement Officer occasionally seconded from HQ. The EU is developing a requirement to permanently position an Assistant Enforcement Officer in the Glasgow facility in 2012.

1.2.4.2 There are approximately 60 case files open at any one time requiring local storage, this equates to 1 x 2.1 m lockable roller locker or equivalent. In addition to this the EU require a secure store for evidence, including equipment and documents, not less than 2mx3m in size. Space to be provided with suitable racking and secure lock.

1.2.4.3 The EU require Ad-Hoc access to a plan approval table and meeting room for formal interviews and reviews of incident case information. Preliminary Busmess Case 10

1.2.4.4 The EU requires network access to a Colour printer and Ad Hoc access to a flatbed document scanner.

1.2.5 Deputy SOSREP (DSOSREP) and CPSO

1.2.5.1 The DSOSREP and CPSO posts consist of 2 FTEs and requiring workstations with access to MCA ICT network architecture. There is a limited on site storage requirement. Meeting room requirements could be facilitated through shared access to facilities on site.

1.2.6 Team Leader Base (TLB)

1.2.6.1 The TLB should have sufficient space to accommodate up to 4 individuals, the Coastal Safety Manager, Coastal Safety Team Leader and 2 x Coastal Safety Officers (CSOs). The TLB will be managing teams across the central Scottish belt and require easy access to the transport routes for the East and West coasts, with good public transport links, to support the Coastal Safety teams.

1.2.6.2 The CSOs and Team Leader will have an MCAfleet vehicle to support the operational activity, therefore secure parking is required for up to 3 operational vehicles. This provides security for the equipment housed in the vehicles and minimises the risk of manual handling injuryfor equipment moved between the vehicle and office.

1.2.6.3 The TLB requires an on site meeting/training provision sufficient to house up to 20 delegates, utilising a mix of audio visual aids, including white boards and/or projectors. Desirable requirement of provision of blinds, to minimise glare when utilising AV equipment. The meeting room should be flexible and allow separation into 2 separate smaller meeting rooms. Training room chairs/tables to be storeable, so that alternative configurations can be set up locally.

1.2.6.4 The TLB will require storage lockers for PPE for the CSOs and Team Leader and additional storage base for documentation facilitating the effective management of the CRS in accordance with MCAsecurity policies.

1.2.6.5 The TLB requires network access to MCA systems and network access to medium/high capacity colour printer and a fax machine.

1.2.6.6 The TLB should have suitable personal welfare facilities including showers and highly desirable provision of external cleaning facilities for equipment.

1.2.7 Additional Requirements

1.2.7.1 Glasgow is identified as a business continuity site for issuance of Seamans Documents and the Enforcement Branch and DSOSREP/CPSO. This together with additional frequent visits from Agency Senior management or business support teams, has identified a need for additional hot desking workstations. It is proposed to incorporate 4 additional workstations to the design layout.

1.2.7.2 Glasgow staff deal with a significant amount of mail containing customer applications and payments, which could involve up to 2 staff handling mail. The future solution mca Preliminary Business Case I 11

should provide a designated area away from the workstation for post handling and consider how this could be secured in the event of a fire or other event requiring building evacuation. This space could be dual function.

1.3 Organisational Overview

As an Executive Agency of the Department for Transport (DfT), the Maritime and Coastguard Agency (MCA) support the Department in developing and implementing the Government’s maritime safety and environmental protection strategy. This business case supports the requirement for a relocation of MCA facilities supporting the Organisational delivery themes by:

• Positively influencing people, their behaviour and their attitudes • Improving the safety of the maritime working environment itself • Efficient, effective and economic use of the resources which underpin our delivery capability 1.4 Contribution to Key Objectives

The principal assumptions which have been made are that in pursuing the MCAstated aims to enforce high standards of marine safety the business case for MCA Clyde contributes to the following key Operational and Thematic objectives:-

• OPI Supports SAR Coastal Rescue operations, through provision of a base for members of the Coastal Safety Management team. • 0P2 Ensuring that our ship surveyors can carry out inspection and certification capability meeting our domestic and international obligations. • 0P3 Is a visible presence in the Clyde area, working with the maritime industry to encourage quality ships to join the UK register, providing a base for the SU and examinations. • TOl Provides a facility to house the Team Leader Base of the future, fully compliant with the objectives outlined in the FCG consultation exercise. • T02 Provides a flexible solution that supports the Ship Survey and Inspection review and can be adapted to meet the output of future needs.

1.5 Stakeholders

1.5.1 The stakeholders identified for this Business Case can be clearly sub-divided into two categories: internal and external. Internal stakeholders within the MCA primarily sit within the staff currently sited at MCA Clyde and include the following business areas which are described below, along with business benefits and the nature of their potential influence on the contract:

1.5.2 Internal Stakeholders

1.5.2.1 Directorate of Maritime Safety and Standards Preliminary Business Case I 12

• Survey and Inspection: The staff on site support the operational themes 0P2 and will participate in the transformational objective T02.

• The Stability Unit: The staff on site support the operational theme 0P2 and 0P3.

• S&l Policy Branch: The facility must support the current needs and be adaptable to changing requirements driven by the S&l review T02.

1.5.2.2 Directorate of Maritime Operations

• Coastal Safety: The staff on site support OP1 and willin the future support the output of TOl in terms of the Team Leader Base.

• Estate Services: The primary focus upon this stakeholder is to ensure that suitable estate is provided to meet the needs of the collocated business units and that it is maintained as fit for purpose, adopting Cabinet Office controls in accordance with Government Property Unit and DfT Estate strategies.

• HR: This business area’s requirements primarily surround the impact of possible staff relocation, and or change in terms, which may involve Trade Unions negotiations.

• ICT Infrastructure: Provision and support of networked solutions to meet the operational needs as outlined in this business case and to meet defined security protocols to ensure the integrity of the data network infrastructure.

1.5.2.3 Finance & Strategy

• Finance & Procurement: the Business Case must be both economically viable and affordable within the current budget allocation to meet this stakeholder’s needs.

• Information Assurance: The delivered solution must meet this stakeholder’s requirements for the physical protection of the site, personnel and hard copy information held onsite and the logical protection of data held on site.

1.5.2.4 Office of the Chief Executive

• Enforcement Unit:- Responsible for following up enforcement activity arising from infringements of Maritime Law.

1.5.2.5 External Stakeholders

There are also a number of external stakeholders identified that have a vested interest in the outcome of the Business Case and the delivered solution.

• Fishing Industry: Owners, operators and crew within the fishing industry engage with the Clyde Marine Office to meet their individual requirements.

• Port AuthoritieslOil I Gas /Bulk Industry: Focal point for survey activity dealing with ports and specialist operations in the Marine Office service area. ca Preliminary Business Case I 13

• Merchant Shipping Industry: Owners, operators and crew within the Merchant Shipping industry engage with the Clyde Marine Office to meet their individual requirements. • Local Members of Parliament and Local Authorities: Any proposed relocation could raise a political concern with regards to employment prospects in the local area.

• MOD — HMNBClyde (Faslane) • Seafarers: Exam Candidates attending the facilityfor examinations. • Glasgow City College: Local liaison between the Marine Office and training facility. • CRS: Members of the volunteer Coastguard Rescue Service teams supported by the Team Leader Base and Coastal Safety Manager.

1.5.2.6 It is important to note that the list of external stakeholders above is not considered to be exhaustive, and external stakeholders have primarily been identified on a generic level. This list was constructed based upon the principal historic users of core MCA services and their relationship with the MCAfacility. It did not rely upon any proactive communication plan.

1.5.2.6 The communications strategy for engagement with both the internal and external stakeholders will be developed as part of a communications plan as the project progresses.

1.6 Existing Arrangements

1.6.1 The Marine Office is currently co-located with the MRCC in Navy Buildings Greenock with a number of MOD lodger units. MCA occupy one floor completely, together with storage space for the Enforcement unit on a separate floor, covering a total area of 1700 square metres.

1.6.2 The main office is not air conditioned and mostly open plan. However there is a

separate auditorium, meeting room , an exam room, lockers for PPE, 2 management offices, IT equipment room, recreational breakout area, kitchen, 1 dining area, shower facilities, 1 x male, 1 x female and 1 x disabled rest room. Under the MOTO the MCA has access to general parking, which consists of 45 spaces available for staff & visitors.

1.6.3 The facility at Clyde has an annual lease cost of £28.85K per annum, service charge including rates of £28.3K with additional proportionate costs recovered for major works, which equated to £45K in 2010/11. The rental rate is less than £3 per square foot, which is significantly below market rates in the area and is not considered to be viable in negotiations for future estate.

1.7 Scope

1.7.1 The potential business scope of the project and the resultant key services required to meet the identified business need have been reviewed, in consultation with the relevant stakeholders. This essentially can be summarised into three categories: “Minimum”,“Intermediate” and “Maximum”.These categories are defined as: ca Preliminary Business Case I 14

• Minimum: The minimum effort necessary to meet the business need. • Intermediate: The Minimum effort plus desirable elements, which will need to be evaluated on a cost / benefit basis. • Maximum: The Intermediate effort plus Optional elements, which will need to be evaluated on a cost / benefit basis.

1.7.2 In terms of this business case, options I and 2 are considered to be the maximum effort to achieve the MCAneeds. Options 4 and 6 are considered intermediate and options 3 and 5 are considered as minimum to achieve the Agency objectives.

1.8 Constraints

1.8.1 The solution must be in place at least 3 months prior to the expiry of the current lease to enable a smooth transition of services and support. This will also enable internal works to be procured and completed in a timely manner.

1.8.2 Any solution identified must be cost effective and affordable to the MCA.

1.8.3 Car parking is normally allocated against the area leased. This constraint is specific to each option and will be identified within the SWOT analysis of this business case. As a minimum MCAwould anticipate a constraint of no less than 4 spaces/I 000 sq.ft on site, as an acceptable constraint, with opportunities to negotiate on increased parking. Providing approximately 18 spaces would meet the MCAoperational requirement.

1.8.4 The facility should where possible meet Government Greening initiatives in terms of energy efficiency.

1.9 Dependencies

1.9.1 The main dependency for this case is the requirement to leave the property by December 2012.

1.9.2 There is an associated dependency with the current collocation of technical infrastructure supporting the MRCC. This willneed to be factored into discussions with the Future Coastguard programme, to ensure issues are de-conflicted.

1.9.3 The planned migration should where possible minimise the impact upon customer facing activity, taking into account survey/inspection cycles and oral examinations.

1.10 Strategic Benefits

1.10.1 Reviewing the estate requirements in line with MCAstrategic direction willensure that the outcome supports the longer term objectives of the Agency. Maximising the use of operational estate supports the Cabinet Office high performing property and DfT Estate strategy ensuring that the estate is fitfor purpose and capacity is managed to meet our needs.

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1.11 Strategic Risks

1.11.1 The organisation’s risk constant categories outlined within the Corporate Risk Register are discussed on a generic level where they are applicable to this business case under options analysis in section 2. Any applicable risk constant willhave corresponding risks detailed within the project’s Risk Log.

1.12 Critical Success Factors

Critical success willbe measured by the continued delivery of services.

• CSF I - Space planning meets the Cabinet office driver of 8 sq.m. per person. Measured through design and layout of office space, either assumed or available on the CivilEstate. Adapted where necessary to reflect the operational demand.

• CSF 2 — Meet Government Property Standards: Greening Government Commitment on Carbon emissions, DDA compliance and latest guidance on build standards.

• CSF 3 — Provides a Value For Money Solution: Financial options appraisal provides further details.

• CSF 4 — The solution optimises support to the MCA customer base: A location between Renfrew, Glasgow Airport and Erskine Bridge located conveniently for publictransport routes.

2. Options Appraisal

2.1 Options consideration

2.1.1 This paper details a review of the proposed options against the Agency’s CSFs and Business Objectives. Initialopportunities were identified, arising from the collation of individual business unit requirements and mapping the minimum space requirements against available civiland non-civil estate, prior to identifying options that could potentially meet the MCAneeds, for presentation to the Senior Executive Group.

2.1.2 The initiallist of options that fell within the scope of this review were: 1. Do Nothing 2. Procure NBG 3. Lease of CivilEstate in the Clyde area 4. Lease of non-Civil Estate in the Clyde area

2.1.3 Ideas excluded from the review, included lease of civilestate outside of the Clyde area, Surveyors working from satellite offices, either permanently or seasonally and Surveyors working from home, although it is recognised this may become an output of the S&l review. Each of these were not considered to be viable options at this stage and would not meet the current operational requirement.

2.1.4 Concerns arising from initialsite identification: Preliminary Business Case I 16

a. Limited space being marketed on ePIMS by other government departments. b. Poor quality stock available in the market place. The MCAestate advisors filtered out sites, that were not considered viable or consistent with MCAimage due to quality. c. The MCAHead of Estate identified that the former Marine Office location at Empress Park, was of low quality stock and high service charges. This site was therefore excluded from the review.

mca Preliminary Business Case I 17

2.1.5 Table of initial considered options:

Price Service Distance & Property Available Distance & Distance & Per Sq Charge Parking Time to Name & Space Time to Time to City Initial analysis Ft (ex Per Sq Ft Spaces Erskine Address (Sq Ft) airport Centre VAT) (ex VAT) Bridge

18 miles 30 miles 16 miles Current location not viable for Nil NBG 26 mins 40 mins 22 mins future.

The Europa Building, City centre location, insufficient 450 Argyle 9 miles 14 miles parking, high rent and service £13 2 2 Street, 8,000 £17 14 mins 17 mins charges. Space in excess of MCA Glasgow, needs. No further investigation. G2 8LG

Seaforth High rental costs. Industrial Estate House, location provides easy access to

— 9 miles 7 miles Barrie 2,663 44 for both 4 miles motorway, but has potential Road, £15 £2.94 mins 12 mins 15 mins 7,587 floors 9 reputation impact. Not Hillington, investigated further. G52 4PX

Aurora Limited parking on site, within House, 1 space £3 (ex 8 miles 8 miles 5 miles close proximity to local parking. 5200 £13 per 400 sq 4 Queen Electricity) 16 mins 18 mins 12 mins Minimum space requirement in Quay, excess of MCA needs. Clydebank Preliminary Business Case I 18

Price Service Distance & Property Available Distance & Distance & Per Sq Charge Parking Time to Name & Space Time to Time to City Initial analysis Ft (ex Per Sq Ft Spaces Erskine Address (Sq Ft) airport Centre VAT) (ex VAT) Bridge

Limited Parking, unable to meet Change 3 spaces House, £3 (ex 8 miles 8 miles 5 miles MCA minimum space 3900 £8 per 1,000 Clyde electricity) 16 mins 18 mins 12 mins requirements. No further Gate, sq ft Clydebank investigation.

Insufficient space to meet MCA DWP 3000 sq. None on 18 miles 30 miles 16 miles 6 needs, limited parking, no further ft. site 26 mins 40 mins 22 mins Greenock investigation.

Caspian House, 2 Marina Court, 8 Either Limited space, cost, limited South 2,550 or 8 miles 8 miles 5 miles parking, head lease expires 2016. Avenue, £15 TBC 12 2,650 on 16 mins 18 mins 12 mins North side of the Clyde. No Clydebank 1st floor further investigation. Business Park, G81 2NR Preliminary Business Case 19

Price Service Distance & Property Available Distance & Distance & Per Sq Charge Parking Time to Name & Space Time to Time to City Initial analysis Ft (ex Per Sq Ft Spaces Erskine Address (Sq Ft) airport Centre VAT) (ex VAT) Bridge

Listed building in need of space, — refurbishment. Limited Custom 3,000 which is not open plan, anticipate Offers 16 miles 25 miles 14 miles House, 3,800 N/A high refurbishment and running 8 over £10 22 mins 33 mins 18 mins Greenock sq.ft. costs. Unlikely to obtain permission :o open up space for flexibility. No urther investigation.

Westpoint Business Park, New build, Energy Performance 18 Certificate (EPC) B+, incentives Junction 28 Extra 9 miles 8 miles 4700 N/A include rent free period. 9 of M8, £12 £3.50 14 mins 12 mins sq.ft. spaces Limited fit out works to meet MCA Glasgow negotiable International needs. Airport, Paisley

Purpose built office space 10 Cirrus years old. EPC D. Space in 15 max 18 excess of MCA needs, could be Glasgow 6754 to miles 8 miles subject to 9 reconfigured for Fire escape 10 Airport 7372 £15 £3.50 N/A 14 mins 12 mins space access, subject to landlord’s Business sq.ft. taken. Park consent. Lighting refurbishment in progress. No further investigation.

jca Preliminary Business Case I 20

Price Service Distance & Property Available Distance & Distance & Per Sq Charge Parking Time to Name & Space Time to Time to City Initial analysis Ft (ex Per Sq Ft Spaces Erskine Address (Sq Ft) airport Centre VAT) (ex VAT) Bridge

Developer currently marketing 60000 square feet of refurbished space. Refurbishment excludes, raised floor, comfort cooling, replacement heating system, Over 20 miles 30 miles 17 miles blown window cassettes and Ample 11 IBM 10000 sq £6-10 30 mins 40 mins 24 mins external decorations. EPC G. ft. Internal viewing identified signs of water ingress to communal areas. Site assessed as not meeting MCA quality requirements excluded from further analysis.

Strathclyde Travel time excludes transit to off Partnership site parking. for City centre location with logistics Approx Ample off 9 miles 14 miles 12 Transport, TBC TBC support offered. 4500 sq ft site 14 mins 17 mins Queen Recent internal redecoration. Street, Limitation on flexibility due to Glasgow age/design of building.

xjca Preliminary Business Case I 21

1 Price Service Distance & Property Available Distance & Distance & Per Sq Charge Parking Time to Name & Space Time to Time to City Initial analysis Ft (ex Per Sq Ft Spaces Erskine (Sq Ft) airport Centre Address VAT) (ex VAT) Bridge

Concrete floors lack flexibility, EPC rating poor and no lift access I to first floor vacant space which raises DDA compliance issues. DWP 6000 13 miles 22 miles 10 miles Heating system in need of 13 Port £9 £4.50 10 sq.ft. 18 mins 29 mins 13 mins upgrade. Glasgow Head lease runs to 2017. Unable to split available space for Welfare/Fire escape routes. Insufficient parking on site.

NB:- Travel times are taken from AA Routemaster and assume optimum travel conditions. Sites 2, 3, 5, 6, 7, 8, 10 and 11 were excluded from further investigation. Sites 1, 4, 9, 12 and 13 have been reviewed in more detail under options analysis. Preliminary Business Case 22

2.2 List of Options

2.2.1 Provided below is the finalised list of options identified for consideration within the business case. These options have been subjected to a SWOT (Strengths, Weaknesses, Opportunities and Threats) analysis, which is provided on the following pages:

1. Do Nothing (stay at Greenock) 2. Procure NBG (stay at Greenock) 3. Lease of a space in the City centre (Strathclyde Partnership for Transport) 4. Lease of space at Port Glasgow (DWP building) 5. Lease of space at the Airport (Westpoint Business Park) 6. Lease of space at Aurora House Clydebank Case 23 Preliminary Business I

2.2.2 SWOT analysis of Option I — Do Nothing

Strengths Weaknesses

Maintains a presence in the Greenock area. No impact upon MO/Stab/TLB/Admin staff. The site is conveniently located for Fort Matilda station. Significant on-cost for rent and maintenance of the full Site security includes perimeter fence, security guards NBG facilityfrom Jan 13 onwards. and building security perimeter. MCA networks terminated in a secure room within the main building.

Opportunities Threats

Provides a significant risk to MCA meeting business objectives T04 and Spending Review. Significant reputation damage. Political criticism locally and nationally. Nil MoD disposal of the facility precludes any potential for agreeing a lease. Overcapacity in commercial estate in the Clyde area, provides no commercial sub letting opportunities.

2.2.2.1 In accordance with Treasury Green book guidance, the ‘Do Nothing’ option is included. Whilst recognising that this is not viable due to the MoD stated objective to dispose of the site, it considers taking on a long term lease (MOTO) from the MoD, including all liabilitiesfor maintaining the site in a habitable state from January 2013 onwards.

2.2.2.2 The financial analysis for this option identifies that there would be significant on-costs associated with this approach, including capital improvements to the infrastructure, identified previously as a driver for the MOD disposal of the facility, in the order of £15M over a 10 year period. The disbenefits include significant local and national reputation damage, arising from the rescue coordination closure from the site.

2.2.2.3 In the Glasgow area, there is an excess of large (in excess of 10000 sq.ft.) office based estate, in moderate to good condition, lying to the East of the site, which would provide easier access to the motorway and public transport links. In the current market this is unlikely toyield any revenue stream from third parties renting excess space. Preliminary Business Case j 24

2.2.3 SWOT analysis of Option 2 — Procure NBG

Strengths Weaknesses

Initial capital outlay. Significant ongoing capital investment required to Maintains a presence in the Greenock area. maintain site. No impact upon MO/Stab/TLB/Admin staff. Adoption of MoD risks on maintenance of the estate. The site is conveniently located for Fort Matilda station. Significant over capacity within the estate above MCA Site security includes perimeter fence, security guards needs. and building security perimeter. Lack of opportunity to utilise the space capacity. MCA networks terminated in a secure room within the Fails to support Government greening drivers on the main building. Civil Estate. Public transport minimum 45 minutes to airport. Local station approximately 2 miles from the site.

Opportunities Threats

Over capacity and vacant commercial office based estate in the Glasgow area, results in no commercial opportunities arising. MODlooking to achieve market rate return on asset Revenue stream from leasing under utilised space. disposal. Political criticism arising from the closure of the Rescue Centre Coordination capability. Criticism from Government Property Unit with regards to excess capacity.

2.2.3.1 This option considers the procurement of the Navy Buildings Greenock site in its entirety. Transferring the whole of the Estate at current market rates, which introduces an asset with significant maintenance issues, including asbestos management, concrete cancer and ageing plant, requiring significant further investment over a 8 year time frame. This transfer would result in an unacceptable level of downstream support costs transferring to the MCA.

2.2.3.2 There are no benefits associated with this option for improving liaison with our main customer base.

2.2.3.3 In the Glasgow area, there is an excess of large (in excess of 10000 sq.ft.) office based estate, in moderate to good condition, lying to the East of the site, which would provide easier access to the motorway and public transport links. In the current market this is unlikelyto yield any revenue stream from third parties renting excess space.

2.2.3.4 This option would attract the same disbenefits as option 1. This SWOT analysis is similar in most respects to option one. 25 Preliminary Business Case I

2.2.4 SWOT analysis of Option 3 — Lease space at SPT Glasgow

Strengths Weaknesses

The building design is inflexible, with concrete floors and a low suspended ceiling. Primary access to the proposed MCA floor space would be through the landlords area of demise. The SPT is the focal point of public transport hubs. Space utilisation is inflexible, with limited scope for The building is located centrally in Glasgow city centre. meeting/training/exam rooms in the MCA area of The site is currently vacant and refit works could be demise. commenced rapidly. Proposed meeting space in landlords area of demise has Secure parking would be provided adjacent to the Rapid no access to MCA secure networks. Transit system at Shields Street car park. Requires significant refurbishment to meet MCA Free annual passes would be provided for the Rapid standards. Transit system. Duration of journey approximately 35 minutes. A loading bay on site provides limited scope for Space is not easily subdivided, should the MCA equipment loading/unloading. requirement reduce arising from the S&l review. Public transport to Glasgow airport approximately every Additional works required to provide tiered layers of 15 minutes. physical security to the proposed area of demise. Additional works required to provide logical security of MCA data network.

Opportunities Threats

Annual rapid transit passes, could incentivise staff to migrate from Greenock. Staff may not wish to migrate to a city centre location. SPT prepared to install separate secure key card access Potential delays to support CRS and S&I activity, arising into fire escape for MCA Surveyors and Coastal Safety from remote vehicle locations. use out of hours. Remote parking increases manual handling risks. Meeting rooms are available within the landlords area of Building age realises few opportunities to improve estate demise subject to booking. greening capability. Offers proximity to many shipping companies, Collages and Universities.

2.2.4.1 The SPT building is a 1970s concrete office block, now owned by Strathclyde Partnership for Transport and hosts their Head Quarters functions. The building partially straddles the Queens Street station and is a short walk from the Buchanan Street Rapid Transit stop.

2.2.4.2 The proposed area of MCA demise is the first floor North Wing. This is accessed via internal SPT corridor layout, from the lift lobby to the front of the building. This could present a branding issue. A fire escape to the rear of the wing, has been offered as an optional secure fob, for controlled out of hours access to meet Ship survey, Inspection and Coastal Safety needs.

2.2.4.2 The proposed area of demise has concrete floors and a low suspended ceiling. A central service duct runs North to South along the central walkway reducing headroom further. The current rest room facilities require refurbishment and refit to meet MCAoperational requirements. jca Preliminary Business Case I 26

2.2.4.2 Light levels both natural and artificial appeared poor during the visit. Natural lighting is restricted to the East, as security gratings are attached to the windows to prevent access from the station roof. Windows to the West are suffering from ingrained concrete particles. SPT advised that this is due to concrete spooling on the exterior surfaces of the building. They have taken a strategic decision not to replace windows, as this is an ongoing maintenance concern.

2.2.4.2 The site is a focal hub for public transport systems, with Queen Street running train services to the North, Glasgow Central within I mile running services to the South, Buchannan Street Rapid Transit station a short walk away providing access to the Shields Road parking facility. The Shields Road car park is adjacent to the M8, providing easy access to the North, South, East and West.

2.2.4.3 The SPT is offering incentives by the way of free parking and open access passes for the use on the Rapid Transit system within the rental costs. This may limit the scope of incentives towards any rent free period or contribution towards refurbishment works.

jca 27 Preliminary Business Case I

2.2.5 SWOT analysis of Option 4 — Lease Space at DWP Port Glasgow

Strengths Weaknesses

Allocated parking limited tomaximum of 10 spaces for the maximum area of demise. Space availability is inflexible, due to the requirement for access to fire escape routes and access to welfare Vacant space available for MCA utilisation. facilities. Buy in from local staff to the location Building marketed as is and in need of significant Would meet GPU drivers on reutilisation of CivilEstate refurbishment. Good public transport links to Glasgow Central and Concrete floors limiting opportunities for flexibilityof Glasgow airport approximately every 15 minutes. utilisation. Energy Peformance Certificate rated G. Additional works required to provide tiered layers of physical security to the proposed area of demise. Additional works required to provide logical security of MCA data network.

Opportunities Threats

Potential criticism from GPU for renting overcapacity and underutilising the space. DWP head lease expires within 5 years, potential that Significant overcapacity to meet MCA needs. MCA could end up covering full service costs for site if Local unsecured public car parking for 30 spaces in DWP migrate out of the facility. close proximity adjacent to the facility. No liftaccess to MCA area of demise, criticism against DDA compliance. (Potential significant cost.)

2.2.5.1 The facility is an 80s built concrete office block and the structural area of demise is in generally fair condition. Significant works are required to replace carpeting, lighting and refurbishment of welfare facilities. The single heating system for the site cannot be split. Utilities’ costs would therefore be apportioned against floor space not utilisation.

2.2.5.2 The site is currently leased by DWP and the head lease is due to expire in 2017. The site is being commercially marketed for the owner and the MCAhas not been able to establish whether DWP has a long term commitment to the site.

2.2.5.3 The close proximity of a public car park, bus and train station, provides good logistics for visitors to the facility and survey/coastal safety staff travelling from the site.

mca Preliminary Business Case 28

2.2.6 SWOT analysis of Option 5 — Lease space at Westpoint Business Park

Strengths Weaknesses

The site is a new build and currently vacant The site has good logistics for access to public transport to Glasgow central Average train/bus connection every 10 minutes The office space achieved an excellent BREEAM assessment and has a B+ Energy Performance The off road parking is limited and attracts airport visitors certificate Space is not easily divided, should the MCA requirement The facility has cycle storage facilities on site be reduced as an outcome of the S&l review The proposed area of MCA demise has 18 allocated parking spaces Tiered layers of physical security at site, including parking area, main building entrance and to perimeter of area of demise

Opportunities Threats

The site managing agent has identified additional parking spaces are available subject to negotiation Local staff may not wish to migrate to the new location There is offroad parking adjacent to the site Site is being actively marketed Two shipping companies are located on site Government Property Unit may be critical of MCArenting Physical and logical security of data network can be non Civil Estate space. designed into primary fit out

2.2.6.1 This is a new development, with vacant space available to meet the MCA needs. The site is currently being marketed as a joint venture between the local authority and the developer. Westpoint Business Park is located within 5 minutes of the Airport arrivals/departures terminal and adjacent to the airport shuttle bus which runs between the airport and Glasgow Paisley station. The site has sufficient parking (subject to negotiation) adjacent to the office based estate to meet the MCA requirements.

2.2.6.2 The site is within 15 minutes drive of the city centre, Erskine Bridge and provides easy access to the Coastal Safety officers supporting East Coast CRS activity.

2.2.6.3 Non-Civil Estate may be leased to meet MCA operational requirements, in accordance with DfT’s dispensation. The operational drivers for S&l and the Team Leader Base, have driven a large parking requirement on site, countering potential criticism from GPU. Preliminary Business Case I 29

2.2.7 SWOT analysis of Option 6 — Lease space at Aurora House Clydebank

Strengths Weaknesses

Facility built in 2009. Limited allocated parking on site. (13 allocated spaces Site in close proximity to the Erskine Bridge and Airport. based upon floor footprint). Has good public transport links to Glasgow City centre Office transit to Airport via public transport 1h2Om via 20 minutes. every Glasgow centre. Energy Performance Certificate C. Quirky office footprint increases fit out costs. Tiered layers of physical security at site.

Opportunities Threats

Local unsecured public parking within 1 mile. Local staff may not wish to migrate to the new location. Development is part of the Clyde Waterfront Site is being actively marketed. regeneration scheme. Government Property Unit may be critical of MCA renting Physical and logical security of data network can be non Civil Estate space in excess of minimum operational designed into primary fit out. requirement.

2.2.7.1 This is a new development built in 2009 and being actively marketed under the Clyde Waterfront regeneration scheme. Whilst not directly civil estate, the regeneration partners include the Scottish Government, Scottish Enterprise and local Clyde and Glasgow local authorities, which could attract less interest from GPU.

2.2.7.2 The facility meets MCA needs for minimum space requirements but would require fit out for data and welfare facilities. The available layout does not lend itself to a standard fit out.

2.2.7.3 The site is within walking distance to public transport links to Glasgow city centre and additional free public parking.

2.2.7.4 Challenges will be faced with staff travelling to the site from the South side of the Clyde by public transport. There is an hourly bus service which takes just under an hour.

2.2.7.5 The site is within 20 minutes drive of the city centre and airport and 15 minutes of the Erskine Bridge. ca Preliminary Business Case 30

2.3 Detailed Options Appraisal

2.3.1 The following costs have been taken into account as part of the detailed options appraisal: • Staff Related Costs: The proposed locations are all within 30 miles of the current location. There are no anticipated training costs required for these options and no staff costs have been built in for VERNES. General guidance from HR indicates that relocation/excess fares are not normally applicable for moves within 30 miles. A sensitivity analysis has been undertaken to identify the risk on each option, should the MCAcommit to pay excess fares. • ICT Costs: The ICT infrastructure required for each option will be the same. This includes a telephone switch and network ICT infrastructure connectivity. • Estates Costs: Estimated costs have been provided by Estates for lease, refurbishment and fit out. It is anticipated that removal costs for each option willbe the same and have been based upon Orpington costs. • Benefits Valuation: Budgetary savings made against our current cost assumptions.

2.3.2 In line with HMTreasury Green Book guidance, the investment appraisal of all options has been undertaken using the discounting technique of Net Present Value (NPV). This has been calculated over the whole life of the project, with a discount rate of 3.5%.

2.4 Benefits Appraisal

2.4.1 Each Business Objective and Critical Success Factor has been considered independently and provided a score of between 1 and 5. The definition of the scoring is provided in the table below.

Criteria Description 1 2 3 4 5

Provides Provides sufficient Provides sufficient Provides sufficient Provides sufficient sufficient space space for MCA space for MCA space for MCA space and parking for MCA activity. 50/0 on operational activity Operational operational activity in excess of MCA 80 1 operational site parking to meet activity. On site Response and parking meets operational activity. No on the operational parking for 75% of 100% of requirement. site parking. requirement. the operational rerluirement requirement. Provides Provides sufficient Provides sufficient

minimum space . . . Provides sufficient space for MCA space for MCA Provides sufficient . . . MCA activity, customer Administrative to support space for activity, customer admin functions activity including counter, good counter, good BC 2 y but insufficient customer counter public transport public transport cus omer coun er. space for and good public links and 1 for 1 links, admin and customer transport links. admin staff parking customer staff counter. spaces. parking. Preliminary Business Case I 31

STCWFroritIine Exam room space Exam room Functions Shared access space to exam room sufficient to meet sufficient to meet Exam room space Exam room space space, to meet current operational current operational Assumes sufficient to meet sufficient to meet operational usage. Good usage. Good candidates travel current operational current operational BO usage. No public transport public transport from Glasgow usage. Limited usage. Good public transport links. 20 per cent links. 40 per cent city centre public transport to public transport to site. reduction to reduction to against baseline site. links, Increased costs delegate day rate delegate day rate of existing travel to visit, travel costs. travel costs. toNBG. Minimal space to Minimal space su space su space meet SU needs. to meet SU requirement met in requirement met in Shared desks for needs. Shared full, discrete desks full, discrete desks SU space Surveyor training desks for for surveyor and for surveyor and requirement met in and internship, Stability Unit Surveyor and internship. Minimal internship, full. SU physically B04 Minimal space Functions: internship. No segregation Optimised space segregated from segregation space segregation between SU and segregation other business between between other business between SU and units. 5U/MOLB and SU/MO/TLB and units. other business. admin functions. admin functions Space planning Space planning Space planning Space planning considers minimum Space planning considers minimum considers Cabinet considers Cabinet Cabinet Office ignores Cabinet Cabinet Office office standards office standards requirements, Meet Cabinet Office drivers space planning and additional and additional supplemented by Office and Net Internal standards and no CSFI operational operational additional standards for Area is in parking. Site Net requirements. Site requirements. Site operational space planning excess of Internal Area is 45° Net Internal Area, Net Internal Area, requirements. Site above cabinet within 20% of is within 45% of is within 30% of Net Internal Area is office drivers, Cabinet Office requirement. requirement. within 15 % of space plan. requirement. Meet Energy Energy Government Performance Energy Energy Energy Performance CSF2 Propey Certificate Performance Performance Performance Standards on Certificate Grade D Grade F or Certificate Grade C Certificate Grade B Certificate Grade A Carbon or lower emissions lower .—.———. .—— NPC greater NPC within 50 per NPC within 20 per NPC within 10 per than 50 per cent Best NPC over the Provide Value cent of the optimum cent of the optimum cent of the optimum CSF3 variance from proposed 10 year Money solution over the 10 solution over the 10 solution over the 10 the optimum term. !2Lt0 year term. year term. year term. A location centred A location Optimised upon the Erskine greater than 25 A location within 25 A location within 20 A location within 15 support to the bridge, minimising CSF4 minutes from minutes of the minutes of the minutes of the MCA customer transit, to the North, the Erskine Erskine Bridge. Erskine Bridge. Erskine Bridge. base South East and Bridge. West. Preliminary Business Case I 32

2.4.2 The initialraw scoring considers all the benefits to have equal weighting and is outlined in the followingtable.

NBG Option NBG Option SPT Option DWP Option Westpoint criteria Weight 6 1 2 3 4 Option5

801 1.00 5 5 1 2 4 2

802 1.00 5 5 4 3 3 3

803 1.00 3 3 5 4 5 5

BO4 1.00 5 5 3 4 4 4

CSFI 1.00 1 1 4 2 4 3

CSF2 1.00 1 1 1 2 4 3

CSF3 1.00 1 1 4 3 5 4

C5F4 1.00 2 2 3 4 4 4

Total Score 40 23 23 25 24 33 28

2.4.2 Recognising that the Business Objectives and Critical Success Factors are not equally weighted, the table below has been adapted to weight items accordingly.

0ptt0u1 SPT Option WPopbon Iestpornt Criteria Wght NBG Option 2 0pbon6

BO 1 10% 4 4 0.8 1.6 3.2 1.6

BO 2 10% 4 4 3.2 2.4 2.4 2.4

80 3 10% 2.4 2.4 4 3.2 4 4

804 10% 4 4 2.4 3.2 3.2 3.2

CSF 1 20% 1.6 1.6 6.4 3.2 6.4 4.8

CSF 2 5% 0.4 0.4 0.4 0.8 1.6 1.2

CSF 3 30% 2.4 2.4 9.6 7.2 12 9.6

CSF 4 5% 0.8 0.8 1.2 1.6 1.6 1.6

Total Score 100% 19.6 19.6 28 23.2 34.4 28.4

mca Preliminary Business Case I 33

2.5 Strategic Risks

2.5.1 The followingtable considers each option in terms of strategic risk.

NBG NBG SPT DWP Westpoi nt Aurora Risk Option Option Option Option Option 5 Option

•1 2 3 4 6

Insufficient funding for future financial pressures

Demand for emergency response:

We cannot deliver our day-to-day business:

Suitably qualified and experienced people

Process failure in the delivery of statutory services:

We do not anticipate customer demand

Failure to deliver non-statutory services

Health and wellbeing of our people

External demands, threats and opportunities on the horizon

MCA’s image

• Insufficient funding for future financial pressures: The Agency is required to deliver in excess of £20M resource savings over the course of the CSR. Options I and 2 increase the funding stream required by the Agency. Options 3-6 support FCG in reducing overall Agency running costs. • Demand for emergency response: The Marine Office business continuity plan allows for emergency survey work to be covered from another Marine Office. The Team Leader Base requires good immediate access to East and West coasts in the event of an incident. • We cannot deliver our day-to-day business: All options would enable the MCAto deliver against business objectives. Preliminary Business Case I 34

• Suitably qualified and experienced people: Staff could reject the proposed changed location. • Process failure in the delivery of statutory services: Surveyor activity is not solely reliant upon an operating base to conduct statutory obligations. Work flow could in the short term be allocated through an alternative Marine Office, during any period of disruption. • We do not anticipate customer demand: The Marine Office has seasonal activity, local planning around the relocation activity willmitigate any risk of this occurring. It is anticipated that Westpoint Business Park and Aurora House would have less fit out issues than DWP/SPT, reducing fit out migration time scales and minimising disruption. • Failure to deliver non-statutory services: Disruption arising from the transition phase could impact upon the Agency ability to deliver non-statutory services. It is anticipated that Westpoint Business Park and Aurora House would have less fit out issues than DWP/SPT, reducing fit out migration time scales and minimising disruption. Requires management during the transition phase. • Health and wellbeing of our people: This will need careful management during the transition phase. • External demands, threats and opportunities on the horizon: The Agency is about to commence a review of S&I activity. Surveyors working from home could take early advantage of this as an opportunity, but is dependent upon an agreed National policy being in place. • MCA’s image: The facility should support the promotion of the organisation as the leading Maritime Safety organisation. Options 1 to 4 carry varying levels of risk associated with the age and condition of the buildings. Option 5 is considered least risk due to new construction and is collocated on a site with shipping companies. Option 6 is also considered low risk as it is a new build.

2.6 Preferred Option

2.6.1 This overall options analysis identified that Option 5, Westpoint Business Park is the preferred option.

2.6.2 It is however noted that the financial weighting provides further details of sensitivity, which the SEG/EB may wish to note. Sensitivity analysis of rent reductions ifapplied to a single site could have a negligible impact upon raw scoring, but artificiallyskew the weighted score towards that site. It has been assumed that all landlords would be prepared to negotiate initialincentives, therefore sensitivity analysis of this nature would have to be comparable for each option and have no overall impact upon baseline or weighted scores. On this basis sensitivity analysis of this nature has been ignored.

2.6.3 On the basis of this evaluation it is our recommendation that the Agency commences detailed discussion with the Westpoint Business Park land agent. This willobtain the maximum benefits in terms of rent free period, minimum rent rate and optimum car parking spaces in accordance with MCAneeds, on the basis of 4700 sq ft. Preliminary Business Case 35 Preliminary Business Case 36

3 Commercial Aspects

3.1 Output Based Specification

3.1.1 Sufficient work has been undertaken to detail the MCA minimum operational space requirements for the new facility. This has enabled the MCAto progress to an Outline Business Case with detailed information on each business units needs. This information will be worked into detailed specifications for the future layout and space planning activity within the area of demise to provide actual costs for the refurbishment activity.

3.2 Payment Mechanisms

3.2.1 The MCA would utilise a traditional lease agreement to progress payment options in arrears. There is scope to include a significant rent free period within the agreement and potential that additional benefits could be accrued through further discussion with the landlord.

3.3 Risk Allocation and Transfer

3.3.1 Section 1.11 provides details of the generic Agency risk appetite against each option. On approval of the business case, a risk register will be generated to identify ownership and management of the risks associated with the migration project, in particular detailing local management responsibilities.

3.4 Contract Length

3.4.1 The preferred option is to negotiate on a 10 year term with periodic lease breaks, to obtain optimum flexibilityto meet the operational requirement. The 10 year term will provide sufficient incentive to prospective landlords to provide a rent free period and negotiate over published market rates. It is anticipated that a 10 year term, with a 5 year lease break could achieve a 12-18 month rent free period.

3.5 Personnel Issues

3.5.1 Staff have been engaged in reviewing potential sites for the future. There is a local concern over movement away from the Greenock area and the daily commute options, which will require local management engagement. Once an approved location has been agreed, finer details of the space planning and fit out can commence, which will require sign off and acceptance at a local level.

3.6 Implementation Timescales

3.6.1 Allworks are to be completed by December 2012. Detailed timings willbe worked up through the project plan, once the business case has been agreed.

ca Preliminary Business Case I 37

4 Affordability

4.1 Whole Life Costs

4.1.1 The table below provides the detail of the expected Net Present Value (Cost) for each option considered over a 10 year term and impact upon budget over a similar term.

All options based on Savingl(Cost) Budget a ten year lease with against the shortfall! a five year break or extrapolated surplus to two five year leases Total Net baseline in Net determine (financially the Total project Present Value Present Value affordability same) cash cost £M £M terms £M Do Nothing - remain at existing site and -22.34 -19.39 -18.18 -31.79 Option I take over the fulllease

Procure the current -20.74 -18.22 -17.01 -31.24 Option 2 site Lease space at Strathclyde 1 60 1 37 0 17 0 22 Partnership for . Option 3 Transport

Lease Space at DWP -1.78 -1.51 -0.31 -0.40 Option 4 Port Glasgow Lease space at Glasgow Airport -1.57 -1.33 -0.13 -0.17 Option 5 business park Lease space at Aurora House -1.72 -1.46 -0.26 -0.33 Option 6 Clydebank

4.1.2 This table excludes any consideration of relocation/excess fares to support staff travelling to the new site based upon current HR guidance that these staff benefits would not be applicable to an office relocation within 30 miles of the site.

4.1.3 The staff handbook Chapter 9, states that where an individual does not qualify for relocation excess fares may be paid for up to 3 years. The table below identifies the impact of paying excess fares, where this may be applicable (staff whose journey would be in excess of their current home to office journey). The information has assumed a 220 day working year, 2 journeys per day and the difference between current home to NBG location and home to identified option sites. The model has assumed public transport rates at £0.25 per mile, to calculate the potential impact upon each option.

4.1.4 Offering existing staff a relocation package of excess fares could mitigate the risk regarding provision of Suitably Qualified and Experienced People transferring to the new location.

4.1.5 The table below is provided to identify the impact of excess fares on the model. It is anticipated that the model provides a worst case scenario and has not factored for Preliminary Business Case I 38

surveyors or other staff working out of the office, to support operational activity, since excess fares should not be claimed for out of office activity.

All options based on Saving!(Cost) Budget a ten year lease with against the shortfall! a five year break or extrapolated surplus to two five year leases Total Net baseline in Net determine (financially the Total project Present Value Present Value affordability same) cash cost £M £M terms £M Do Nothing - remain at existing site and -22.34 -19.39 -18.18 -31.79 Option I take over the fulllease

Procure the current -20.74 -18.22 -17.01 -31.24 Option2 site Lease space at Strathclyde -1 73 -1 49 -0 28 -0 35 Partnership for . Option 3 Transport

Lease Space at DWP -1.80 -1.54 -0.33 -0.42 Option4 Port Glasgow Lease space at Glasgow Airport -1.65 -1.41 -0.21 -0.25 Option 5 business park Lease space at Aurora House -1.81 -1.55 -0.35 -0.42 Option6 Clydebank

4.1.6 The financial analysis identifies that there is little to choose between Westpoint Business Park, SPT and Aurora House, when baseline rents are considered. Taking into account excess fares, there is a widening of the gap between these options, but this is not considered material over the 10 year term.

4.1 .7 It is anticipated that all landlords will offer incentives during negotiations, including rent free periods and a contribution towards ingoing works. These potential benefits have not been factored into this business case, as the benefits would not be established until detailed discussions and commitments made. 4.1.8 Considering a 10% reduction in the market rate rents for each option, reduces the variance between each option over the 10 year term, but retains Westpoint Business Park as the preferred option. The recommendation of the financial analysis is to enter into early detailed discussions with the landlord to optimise benefits in terms of rent reduction and rent free periods.

5 Achievability

5.1 Evidence of Similar Projects

5.1.1 The MCA Estate team delivered the operational requirement for move of the Orpington Marine Office and the migration of Stockport Marine Office into MCA South Tyneside. Preliminary Business Case I 39

The team is in the process of delivering against the Cardiff Business Case requirement to rationalise floor space within the current facility.

5.2 Project Roles

5.2.1 The Project Sponsor/Senior Responsible Owner (SRO) will be BillMcFadyen who will be the individual responsible for ensuring that the project meets its objectives and delivers the projected benefits. The Senior Supplier will be AD Asset Management, responsible for delivery of a solution to meet the agreed and signed off operational need.

There will be a requirement for a Project Manager (PM) to take responsibility for delivering the project, with an identified Senior User established to sign off the operational requirement, design phase and achievement against targets. The Project Manager will oversee technical issues regarding on site works and support of staff moves, monitoring progress on a day-to-day basis, managing issues and escalating when necessary to the SRO or Senior Supplier. The Project Manager will be appointed once the business case is approved.

5.2.2 Project Plan

Once the business case has been approved by SEG and EB the project plan will be developed in detail with Estates.

5.2.3 Contract Management

The overarching contract management of third party suppliers in relation to any solution willbe managed through Estates Services supported by the Business Support Unit.

5.2.4 Risk Management Strategy

Risks identified as sitting within the scope of the project will be managed within the structure of the Project Risk Log. However, risks identified as a consequence of project activity (but which are not specific to the individual project) will need to be raised for inclusion in other higher-level risk logs / registers. Risks can be identified and raised by anyone, but the Project Manager will own and maintain the risk log and identify and record the appropriate risk owner.

5.2.5 Benefits Realisation Plan

This will be developed in detail as soon as the Business Case has been approved by the SEG and EB.

5.2.6 PlRs and PER

Post Implementation Reviews will be carried out periodically over the life of the contract to confirm that business benefits are being achieved; and a one-off Project Evaluation Review will occur within 6 months of the migration to the new site, to identify what went right, what went wrong, as lessons learnt for similar projects in the future. Preliminary Business Case I 40

5.2.7 Contingency Plans

The current MOTO agreement in Clyde expires in December 2012. Should the MCA fail to agree the way forward and take appropriate action in advance of the expiry date, this could expose the Agency to risk of an eviction notice being served, loss of the site and operational capability. nica Maritime and Coastguard Agency

PROTECTING OUR SEAS AND SHORES IN THE 21ST CENTURY

REPORT ON THE 21d1 CONSULTATION RESPONSES October 2011

“The backbone of the Coastguard willalways be the men and women who know the shores, love the sea and willdo their utmost to save lives at sea and around our coast”

Presentation of Her Majesty’sColourto HMCoastguard 20 July 2005

R.E. Banham FCMA, Non Executive Director P.R. Dymond OBE, HQ Coastguard Rescue Service Team Manager Independent Review Team Members

1 L’J Contents Page Numbers Title page 1

List of Contents 3

Executive Summary 5-8

Introduction 9

Section 1 Aim of an Independent Review 10

Section 2 Composition of the Review Team 11

Section 3 The Review Process 12/13

Section 4 Themes and Findings 14/16

Section 5 Location Retention Factors 17/18

Section 6 Risks and Concerns 19

Section 7 Ideas 20/21

Section 8 Metrics 22/25

Annex A Review Process Schematic 26 Annex B Review Team and Terms of Reference (TOR) 27/30 Annex C Corporate Governance & Risk (CG&R) TOR 31/32 Annex D CG&R Review Process Audit Statement 33 Annex E Characterisation Descriptors 34/35 Annex F Glossary of Terms 36

3 4 EXECUTIVE SUMMARY Background

A revised set of modernisation proposals for HM Coastguard was issued for public consultation on 14 July 2011. Consultation ended on 6 October 2011 and this report is the result of the independent in-house review of the responses received.

The same team that carried out the independent review of the responses to the first consultation concerning Coastguard modernisation was re-assembled on 10 October 2011 to carry out a review of the responses to this second consultation. The same process and methodology used successfully in the first independent review was used again.

Fewer responses were received to this second consultation ie 800 compared with 1859 for the original consultation. A number of location specific campaigns and petitions were also received primarily concerned with keeping specific stations open (see Section 8). The team was also made aware of a national web based campaign which did not submit its results to the consultation and which remains ongoing.

In producing this independent review report it was not the team’s mission to provide an alternative or final solution or to apply judgement as to whether a response was in favour of or against the proposals. The questions contained in the second consultation document invited evidence based comment and the exercise was intended to gather information rather than conduct a referendum.

The team’s work was monitored throughout by a member of staff from the Maritime & Coastguard Agency (MCA) Corporate Governance and Risk Division and representatives from the Public and Commercial Services (PCS) Union. Major Themes and Messages

A number of generic themes emerged in the responses:

Concept of Operations

Although additional material concerning the likely Concept of Operations (how the new proposals will work in practice) has been put out by the MCA since July 2011, this remains a significant area of concern with calls for robust testing and evaluation of the concept in a live environment.

Local Knowledge

Local knowledge was still a significant issue, but there was a different emphasis this time. A clear distinction emerged where the issue was about place names and pronunciation/dialect rather than language per se. A number of respondents specifically stated that language was not an issue in Search and Rescue (SAR) operations.

5 The means by which local knowledge and information is safely transferred to the remaining Maritime Rescue Co-ordination Centres (MRCC) during reorganisation was still a worry to many.

Standby Maritime Operations Centre (MOC)

MRCC Aberdeen was seen as a better alternative for the standby MOC as respondents felt the risk assessed strategic reasons for choosing MRCC Aberdeen as outlined in the original proposals remained extant.

Maritime Rescue Sub Centres (MRSC)

The use of the term Sub Centre was seen by staff as having the potential to create a two tier Coastguard Service with associated negative career development connotations.

The other main themes made in direct response to the consultation questions were: Consultation questions

The consultation document posed 4 specific questions pertaining to the revised proposals and a summary of the responses to those questions is as follows:

Question Ia: Do you agree that retaining 24/7 MRCCs at both Shetland and Stornoway adequately addresses the concerns expressed?

Question Ib: Do you that think there is a more cost effective way of addressing these concerns?

There was support for the retention of MRCCs Shetland and Stornoway for the reasons stated in the revised proposals. However some respondents thought that the proposed staff levels for Shetland, Stornoway and Aberdeen should be re-considered to reflect the likely workload and geographical areas of responsibility post modernisation, not forgetting MRCC Aberdeen’s offshore industry responsibilities. Concerns regarding the technical resilience of the telecoms service to the islands were repeated but recognising responsibility lay outside the Agency’s remit.

Question 2: Do you agree that retaining the 24/7 MRCC at Holyhead rather than Liverpool with which Holyhead is currently paired best addresses the concerns expressed in consultation?

Typically for a station under threat of closure, there were a number of responses, petitions and campaigns in support of retaining MRCC Liverpool. These took the form of outlining the advantages of the location and the importance of the activities undertaken. A petition with 50,000 signatures in support of retaining MRCC Liverpool was amongst the responses received.

The volume of support for the retention of MRCC Holyhead was muted but is a station earmarked for retention as described in the revised proposals.

6 Question 3: Does the new structure as described provide appropriate resilience to cover the UK Coastguard operational needs.

A particular area of concern was the proposed choice of Dover as the site for the stand-by MOO. Respondents expressed concern over the possible difficulties in rapid redeployment of extra staff to Dover due to potential traffic problems (eg M251M20;Operation Stack) or the heightened risk from a severe weather system on the South Coast impacting both Southern sites at the same time. Various other suggestions for the location of a stand-by MOO were received, generally as part of a “keep our local station open” submission or the offer of alternative premises.

Concern was again expressed over how the proposed concept of operations would work and how the balancing of workload between the MOC and MRCCs would function. Strong views were expressed on the need for detailed planning of the implementation to ensure SAR response is not compromised and for robust trials and evaluation of the processes and procedures to be carried out over an extended period in a live environment. To that end, the point was made that the MOO should be commissioned and live at the earliest opportunity, otherwise if station closures were to go ahead before the MOC was ready, then other stations (possibly with reduced staffing levels) would have to absorb the workload from the closed stations.

Question 4: In proposing the retention of Milford Haven rather than Swansea are there any other factors that need to be addressed.

This change to the original plans generated the most correspondence — including a 100,000 signature petition in support of Swansea. Similar to the response to question 2 above (Liverpool versus Holyhead) the strengths and value of Swansea, often compared to Milford Haven were outlined by many respondents. There was no obvious single factor that was new relating to the Agency’s criteria for site assessment.

7 Quantitative Summary: Themes and Concerns

A quantitative summary of key themes and concerns identified from all the responses received during the second consultation period are shown in the charts below, together with comparisons from the first consultation. The second consultation has shown that Concept of Operations and Local Knowledge continue to be the public’s main concerns. Definitions of the characterisations used in the chart can be found in Annex E.

AllCharacteristics(FirstandSecondConsultations)ActiualNumbers

‘ — o — _ r? qs , ,

AllCharactedstlca)Flrstand SecondConsultations)as PercentapsofTotalChracteristics

‘/ / / / / I u ‘ / / / q_ 5, ‘— , , ‘, , 51

8 Introduction

In December 2010, the Government announced a formal consultation on its plans to modernise HM Coastguard.st21 The consultation document1 ‘Protecting our Seas and Shores in the Century’ was issued immediately following that announcement with a closing date for responses of 24 March 2011 which was subsequently extended to 5 May 2011.

Following publication of the Report of that consultation and the Report of the House of Commons Transport Committee Sixth Report of Session 2010-2012, the Secretary of State for Transport announced a number of significant changes to the proposals in the original consultation document and that a further period of consultation would take place from 14 July to 6 October 2011.

A new consultation document was published containing these revised proposals, the more significant of which were the introduction of a single MOC, supported by 9 MRSCs operating on a 24/7 basis; the retention of MRSCs at Belfast, Shetland and Stornoway; and seeking views on keeping MRSC MilfordHaven as opposed to MRSC Swansea and MRSC Holyhead as opposed to MRSC Liverpool.

The consultation was again owned by the Department for Transport (DtT) but managed by the MCA. The same independent in-house team of experienced Coastguard Officers led by a well respected senior Coastguard Officer and chaired by a MCA Non-Executive Director was re-formed to carry out the second review. This took the form of a quantitative and qualitative consideration of all responses to the consultation received up to the closing date of 6 October 2011. Response channels consisted of e-forms (as per consultation document), emails, letters and larger responses in the form of location specific campaigns and petitions.

No member of the Review Team has been directly involved in the development of the original or revised modern isation proposals, and the team acted in an impartial and discreet manner to capture the themes, ideas, risks and factors contained in the responses.

The PCS Union again participated fully in the review process which was open, independent and impartial.

The output from the review team’s work is contained in this report which details the key findings from the consultation.

The Chair was not required to resolve any disagreements within the in-house independent review team.

1 In accordance with HM Government Code of Practice on Consultation 9 Section 1

Aim of an Independent Review

1.1 The purpose of an independent review, undertaken by MCA staff outside of the team developing the proposals, is to ensure impartiality and transparency throughout the review process including the production of the final review Report.

1.2 The purpose of this Report is to:

• provide information on the methodology used to review the responses to the consultation; • report on the key themes, concerns, ideas, risks and factors gathered from the responses to the consultation proposals; • provide findings arising after careful consideration of all responses on the basis of all evidence received; and • continue DfT/MCA’s commitment to an impartial and transparent approach to the consultation process.

1.3 The process to capture the response data was as follows:

• all e-forms, e-mails, letters, campaigns, petitions (including web- based petitions) and other written responses were recorded, referenced and catalogued under the appropriate question on receipt, where no specific question was addressed this was categorised as ‘any other comments’; • all requests for information under the Freedom of Information Act (FOIA) were logged and responded to within the time frames set down by the Act. Replies to FOIA responses were published on the MCAwebsite.

1.4 The response data capture was carried out by a team drawn from executive and administrative staff within MCA HQ.

1.5 A full audit trail has been compiled and comments used in reports and feedback can be traced back to source. A schematic of the review process is at Annex A and response numbers at Section 8.

10 Section 2 Composition of the Review Team

2.1 The Government decided that because of the technical and specialist nature of the proposals that the independent review team would consist of Coastguard Officers who had no involvement with, nor made any direct contribution to the concepts that underpinned the modernisation proposals described in the consultation document. This included the Chair, a Non- Executive Director to the MCA, and the Team Leader, a senior Coastguard Officer. Most importantly, the team would act fairly and without bias and operate separately from those responsible for the authorship of the consultation document.

2.2 The Team Leader was tasked with assembling a team of 12 Coastguard Officers with a range of grades, experience, location and gender. This team was augmented by 4 additional Coastguard Officers acting in their capacity as representatives of the PCS Union.

2.3 The Review Team was first brought together on 4 May 2011 after the close of the first consultation when the members were briefed as to their responsibilities; their terms of reference; the timeline and the methodology to be used to review the responses. The team met over two separate weeks to carry out their review of the responses to the first consultation.

2.4 The same Review Team was re-assembled on 10 October 2011 to carry out the review of responses to the second consultation and used the same process and methodology which had proven to be successful in the first independent review. The Review Team and their Terms of Reference are shown at Annex B.

2.5 An auditor from the MCA’s Corporate Governance and Risk Division (CG&R) was present throughout the review process to provide assurance that the collection and review of the responses was carried out in accordance with HM Government’s Code of Practice on Consultation. CG&R has remained involved to ensure that this Report and its findings are an accurate reflection of the responses and their evaluation. Terms of reference for CG&R are at Annex C.

2.6 A statement from CG&R on their internal audit of the review of the responses to the consultation is shown at Annex D.

11 Section 3 The Review Process

3.1 Consultation responses were received as e-form, e-mail, letter or other written format amounting to a total of 800 items. These contained replies to all or some of the four separate questions posed in the consultation document (See Executive Summary). Observations or comments not immediately related to the questions were also recorded and reviewed in the same manner as responses to the consultation questions. In addition there were a number of organised campaigns and petitions.

3.2 Not all of the e-form on-line responses addressed all of the questions, but collectively they made up the majority - 615 in total. Each answer or commentary in the response was recorded against its relevant consultation question thereby producing a catalogue of responses for each of the four questions. Where a response did not address any specific question, it was recorded as ‘any other comments’. These e-form responses, together with email, letter and other written responses totalled 800 individual answers or comments which the Independent Review Team scrutinised and characterised.

3.3 In the first part of its review, the team devoted its time to the characterisation of these e-form answers and comments using the same 18 possible descriptors used in characterisation of responses to the first consultation (see Annex E), plus the extraction and recording of risks/issues and ideas. If any significant new characteristics had been identified, these would have been included in the analysis. However, this was not the case. The same 18 characteristics were still entirely fit for purpose and their use enabled a direct overall comparison of key themes and common concerns to be made between the first and the second consultation. The category of “no comment” was again used where a consultation question was not addressed. Each answer or comment received was characterised under one or more of these descriptors, giving a total of 2320 comments and 1680 instances of ‘no comment’. The table at Section 8 shows the results of this characterisation and the common themes of concern raised, and the various groups of respondents who raised them.

E-form process

3.3.1 The review team was divided into four teams of 4 with a mix of grades, work location, experience and a PCS representative within each team. This also ensured that a process of dynamic peer review occurred simultaneously with the evaluation of each response. This mirrored the process used to analyse responses received during the first consultation exercise.

3.3.2 Each team was given the catalogue of responses to one of the four questions, plus the “any other comments”. Each team divided into 2 pairs to read each answer or comment and then attributed the appropriate characterisations and recorded any risks/issues and ideas.

12 Hard copy process

3.3.3 The characterisation of hard copy e-mails, letters and other written responses was carried out in the same way, using the same teams and their pairs working through the documents, attributing characteristics and logging risks/issues and ideas.

Submissions with alternative proposals

3.3.4 This consultation was closely focussed on the four specific questions asked and no invitation was made for alternative proposals. If a response was received which proposed a change unrelated to the four questions, these were treated in the same manner as the “any other comments” made in the other written responses.

Treatment of Petitions and Campaigns

3.3.5 This second consultation gave rise to a number of public petitions and orchestrated campaigns and arose in a variety of formats - hand written, electronic (on-line), and by completion of tear out coupons or flyers provided by local press or other organisers. Typically, they invite participants to sign-up to a simple slogan or statement of protest and rarely give a reason for their support.

3.3.7 Government guidance on consultation refers to the analysis of responses being primarily a qualitative rather than quantitative exercise. In a sense petitions represent an expression of protest which can exist in parallel to a consultation. One on-line petition we became aware of was still receiving support over a week after the consultation had closed. Petitions which the review team became aware of were noted and a summary is shown at Section 8. One example of the standard letter associated with each campaigns/petitions was characterised by the review team. It is possible that others existed of which the consultation team were unaware. Campaign/petition letters and e-mails

3.3.8 These consisted of various pre-printed stock letters or stock e mail text, received from named individuals. These were addressed to Ministers, local MPs or sent in batches directly to the consultation team. As with the petitions, this correspondence was associated with specific local campaigns.

3.3.9 Unlike the straightforward petitions, these stock letters generally raised a number of points related to the case for retaining a specific centre, and asked questions without necessarily addressing the specifics of the consultation.

3.3.10 In each case the correspondent either received an acknowledgement, and was referred to a general reply to their questions published on the MCA web site; or received a full individual reply. In all instances these correspondents were referred back to the formal consultation process. 13 Section 4 Themes and Findings

4.1 The themes and findings described here are those that have emerged from the consultation on the revised proposals.

Concept of Operations

Finding I

That the MOO should be commissioned and declared fully operational at the earliest opportunity, otherwise if station closures go ahead before the MOO is ready, then other stations (possibly with reduced staffing levels) would have to absorb the workload from the closed stations. This would increase the risks to successful SAR operations.

Finding 2

As in the first consultation, respondents were still concerned by the lack of detail as to how the balancing of workload between the MOO and remaining MROOs will operate and how areas of responsibility and their associated radio communications will be switched during foreseen and, more importantly, unforeseen periods of high activity.

Finding 3

The mechanics of the new operational concept should be robustly tested and evaluated over an extended period in a live environment involving Ooastguard staff.

Finding 4

Respondents were concerned by the choice of MROO Dover as the site for the stand-by MOO as they viewed this as negating the risk assessed strategic reasons for choosing Aberdeen in the original proposals. MROO Dover has a full time VTS function and potential physical space limitations. Ooncerns were also expressed over the potential for reduced resilience with the MOO and stand-by MOO both being located on the south coast. These included concerns over vulnerability to the impact of a severe south coast centric weather system; a southern area pandemic; and potential rapid re-deployment difficulties due to traffic problems. Various other suggestions for the location of a stand-by MOO were received, generally as part of a “keep our local station open” submission or offers of alternative premises.

Finding 5

Respondents viewed MROO Aberdeen as a better alternative for the standby MOO based on the original strategic risk assessment. Some respondents suggested that the staffing levels proposed for Shetland, Stornoway and Aberdeen should be re-adjusted to enable Aberdeen to act as a standby MOO

14 and maintain effective Oil and Gas incident co-ordination capability. It was also suggested that creating a standby MOC at MRCC Aberdeen with enhanced staffing could provide further career opportunities particularly in the North.

Local Knowledge

Finding 6

That a safe and secure means is used to transfer local knowledge and local information to the MOC and remaining MRCCs during re-organisation.

Finding 7

Loss of local knowledge, local intelligence and difficulties with local language and dialect continued to be a concern. What emerged this time was the issue about place names and pronunciation/dialect rather than language per Se. A number of respondents specifically stated that language was not an issue in SAR operations. Local Resilience and Relationships

Finding 8

Devolved administrations, emergency services, industry, SAR and civil resilience partners remained concerned that the proposals would weaken local operational relationships and that the effectiveness of a multi-agency response would be compromised.

Finding 9

The small boat and recreational community continued to express concern that the proposals assumed an unrealistic level of technology in terms of communications and navigational aids within their sector.

Finding 10

As the re-organisation progresses, there will be a need to re-assure both the public and staff that ‘itis business as usual’.

The Coastguard Rescue Service

Finding 11

Some respondents continued to question the need to introduce another layer of management into the Coastal Operations structure and would prefer to see this investment redirected into additional paid training and technology for the CRS.

15 Resourcing and People

Finding 12

That the proposed staffing levels at remaining MRCCs should be based on operational workload data for the likely regular geographical areas of responsibility and types of incident rather than a standard complement for all. This would help simplify the MOC’s role in balancing workload within the national concept of operations.

Finding 13

The inability of staff to relocate and the potential loss of those staff and their experience and expertise remained a major concern among respondents.

Finding 14

That staff leaving the service ahead of planned station closures could lead to staffing difficulties and jeopardise MCA’s ability to effectively manage and co ordinate SAR operations.

Finding 15

Concerns were expressed that the MDC would be unable to function as planned because the MCA would be unable to recruit or redeploy sufficient staff or staff with the required competencies.

Finding 16

Concerns expressed by staff that re-introducing the title ‘Maritime Rescue Sub-Centre’ would inadvertently lead to a two-tier service.

Finding 17

That insufficient trained staff will be available to design, develop and deliver the new training required by the modernisation proposals whilst continuing to meet current training levels and competence during the inevitable overlap between maintaining ‘business as usual’ and preparing staff for their future roles.

Finding 18

That little heed had been paid to how staff could work more flexibly within the MDC and MRCCs by considering different watch systems which may suit some MRCCs more than others.

Finding 19

That the proposal to close MRCC Swansea instead of MRCC MilfordHaven is politically driven rather than for operational reasons.

16 Section 5 Location Retention Factors

5.1 The consultation document on the revised proposals sought comments and factors on the retention of MRCC Holyhead as opposed to MRCC Liverpool, and MRCC MilfordHaven as opposed to MRCC Swansea.

5.2 The following factors were put forward by respondents in support of each location:

. Riseinuse ofmarine environmentoff North Wales coast e.g. offshore renewables . Familiarity with Welsh language, local pronunciation and complex place names . North Wales is a key tourist area . Liaison with civil contingency partners in particular North Wales Police . Proximity to RAF Valley and SAR helicopter flight . Ferry port . Located at busy shipping pinch point around Anglesey

• Responsibilities for inland waters in Lake District • Expansion of maritime activity offshore • Increasing use of the Port of Liverpool by shipping including Cruise ships • Co-located MCA site with long lease and cheapest of the two MRCCs to run • Welsh language is not perceived as a problem • Campaigns and petitions waged to keep MRCC Liverpool open including petition with 50,000 names. • Costly to dispose of MRCC Liverpool ifclosed • Primary liaison station for operational working with Isle of Man • An increasingly important tourist area

17 • MRCC MilfordHaven close to LNG and LPG plants which puts the centre at risk of sustaining damage or long term outage should incident occur at those plants • Good road, rail and air links to Swansea but not at MilfordHaven • Quicker access to MRCC Swansea for engineers responding to equipment outages • Better recruitment potential at Swansea than at MilfordHaven • MRCC Swansea is the better of the two premises and willbe less costly going forward • A petition with 100,000 names wishing to keep MRCC Swansea open delivered to HM Government • Rise in use of marine environment in upper Bristol Channel

• Equally good location to deal with maritime incidents in south and west Wales, north Devon and Cornwall and whole Bristol Channel and Celtic Sea areas • Oil, Gas, LNG terminals, Cruise Liners and third busiest UK port • Shipping density and hazardous cargoes • Familiarity with Welsh language, local pronunciation and complex place names • Updated National Security Strategy where security of Welsh ports is specifically mentioned — port of Milford Haven is potentially high risk to terrorist or other illegal activity but presence of Coastguard (MRCC) seen as a deterrent • Time expired pyrotechnics concerns in west Wales if MRCC MilfordHaven closes • West Wales is a key tourist area

18 Section 6 Risks and Concerns

6 A qualitative part of the review of the responses was the identification of operational risks and concerns raised by the respondents:

Concept of Operations

Deterioration in SAR performance due to insufficient training in the new concept of operations including familiarisation with new geographic areas, local place names, dialects/pronunciation Renaming MRCCs as Sub-Centres perceived by staff as giving rise to a two tier service Working arrangements with other Cat 1 partners particularly during major incidents may deteriorate as a result of structural/organisational changes and the lack of local authority and emergency service engagement at the appropriate managerial/tactical/strategic level The ability ofthe national structure to operate as defined because the new concept of operations, the supporting technological solution and the processes and procedures involved are as yet unproven and will remain so unless or until comprehensive trials/testing are successfully demonstrated in a live environment Misdirection of 999 calls within the new national network Risk of losing information or mishandling information during incident handover Not enough skilled/experienced trainers available to meet the training workload necessary to ensure the necessary competence levels are achieved in the current and additional workstreams expected of the modernised service Phasing and implementation needs careful planning to avoid SAR deterioration and to meet the needs of the work force In the event of IT system failures, inexperienced operators may be unable to function effectively unless exhaustive testing and training occurs before rollout Offshore industry response and liaison posts should remain at Aberdeen which should be staffed to function as the standby MOC otherwise there is a risk that in any staff reduction knowledge and experience (recognised by the industry) willbe lost During the early stages of operating the national network there is a risk that assets (e.g. Helicopters) will be tasked more often as a risk averse response If MOC not operational before closure of existing stations this may put an additional burden on the remaining MRCCs as they take on additional unfamiliar areas of coverage and possibly with reduced staff

Staffing

Proposed staffing at Dover may not be sufficient to energise the back-up MOC until staff from MOC arrive who could be delayed by traffic hold ups etc Having a standard staffing complement at the remaining MRCCs could be inadequate for normal day to day operations given change in size of areas Risk of losing experienced staff during re-organisation as personal circumstances may mean staff are unable to re-locate to another station Lack of career progression around the coast except at the MOC

General

Increased dumping of pyrotechnics unless public made aware of revised procedures Public confidence in the service lost during any closures or changes

19 Section 7 Ideas

7 Another qualitative part of the review was to capture ideas from within the responses. These were categorised under specific headings and are shown below:

Concept of Operations

The concept of operations/method of working in a national (as opposed to a territorial) network environment should be robustly tested and evaluated over an extended period in a series of practical exercises and live scenarios using CG officers Reconsider MOC/MRSC Proposal. Instead of investing in MOC invest in a national network of 10 MRCCs or variations thereof Nominated MRCCs should have specialist duties or expertise which is available to the MOC and other MRCCs to ensure resilience and continuity of service in the event of failure in any part of the national network Retain London until 2012 Olympic finished and then close With reduction in number of MRCCs follow London model and embed a CG within selected port authorities

Coastguard Rescue Service

Reduce numbers of managers in proposed coastal operations structure, and re-invest money in CRS training and technology Mobile phones should be fitted to all CRVs to provide a choice of communications including a more secure mode of communication Ifclosed, MRCC Swansea to be converted into a Welsh HQ for the CRS in Wales New technology required to link CRT/CRVs to MOC/MRCC for exchanging and accessing data

MOClStandby MOC

lnverclyde Council offering site and facilities for new MRCC or standby MOC. Other responses proposed a 24/7 station in Scotland’s central belt as a replacement for MRCCs Clyde and Forth Increase staff complement at MRCC Aberdeen to ensure that it is sufficiently well resourced to deal with offshore incidents (major and minor); to maintain its close working relationship with the offshore industry; and to ensure the appropriate level of expertise and competence is maintained for well informed engagement with the offshore industry. MRCC Aberdeen should also become the standby MOC to mitigate against the impact on MRCC Dover of major southern area disruption due to weather, southern area pandemics, ferry operator/harbour strikes (Operation Stack), etc.. Staff would also have choice of career progression in north or south if MRCC Aberdeen has increased complement and responsibilities. MRCC Aberdeen must be able to maintain its crucial links and liaison with all stakeholders involved in the offshore industry and offshore emergencies.

20 Staffing

Maintain RCCM equivalents at MRCCs Decrease proposed staff levels at the MOC and increase staff levels at MRCCs to provide additional resilience in the event of flu pandemics, bad weather and loss of any part of the national network Reduce level of staff at both Shetland and Stornoway to reflect the level of activity or close MRCC Shetland. In either case redeploy staff to MRCC Aberdeen or elsewhere Keep current shift pattern but offer more staff the opportunity to work part time to enable additional staff to be available during daylight hours Fixed terms appointments for 6 months to be introduced to cover the busy summer period i.e. from February for two months intensive training and then become part of the Ops Room team May-Aug i.e seasonal workers with essential yet limited skills Restrict leave to no more than 2 weeks during the peak season to allow maximum staffing flexibilitywithin the national network Courses not to be held at Training Centre during peak season to allow maximum staffing flexibilitywithin the national network Introduce 2 watch system

Revenue Stream/Cost Saving

Raise revenue through commercial and recreational vessel insurance policies or tax to partly fund maritime SAR and maintain a fuller infrastructure Consider sharing premises and resources to reduce costs. e.g. relocate Dyfed/Powys Police Marine Unit and Border Agency from Pembroke Dock to MRCC Milford Haven Rather than cutting costs MCAshould be looking to generate revenue streams

A number of ideas were put forward concerning MOC alternatives (some of which appear already in this log) and these ranged from no MOC to several MOCs either in existing locations or new locations. These were as follows:

Instead of one large MOC establish a series of smaller MOCs at the expense of some MRCCs Make MRCC Portland the MOC or establish MOC in Weymouth/Portland area Establish MOC at Daedalus where room exists to expand and is adjacent to SAR flight and other facilities Create MOC at MRCC Liverpool; space exists to expand; one of the cheapest MCA sites; significant MCA presence at site already; good road, rail and air links; central to UK Retain 2 MOCs in key strategic areas Make MRCC Dover the MOC instead of spending time and money searching for a suitable site in the Portsmouth/Southampton area

21 Section 8

Metrics

The MCA received 800 consultation responses, all of which were logged on receipt, allocated a unique reference number and, where possible, acknowledged by e-mail or letter. These consisted of 615 e-forms direct from the MCA web site link; 65 items of correspondence, 120 e-mails, many with response pro-formas attached. Not all responses followed the suggested response format or directly addressed the four questions asked in the consultation document, but where it was clear that the intention was to comment on the consultation proposals, these were included as “any other comments”. Additionally, there were a number of petitions received from local pressure groups and a series of stock campaign letters and e-mails, which were acknowledged and referred to the consultation process.

The consultation exercise also generated a number Parliamentary Questions and correspondence from MPs and other interested parties and several requests for information under the terms of the Freedom of Information Act. These were all dealt with or replied to by Ministers, the MCA Chief Executive or other officials. This flow of correspondence pie-dates the consultation and continues beyond its closure and all correspondents were referred to the consultation process.

The 800 consultation responses addressed all, or some, of the four questions asked in the consultation document, plus any other comments they might wish to make. These responses were characterised in relation to 18 possible themes, giving rise to a total of 4746 individual items of data, including “no comment” and instances where the only comment was a simple yes or no.

22 Common themes of concern by group of respondent

ct

.‘ a: — 0 . C) = 0 ._ — —

S.. . . I Small to Medium Enterprtse(upto5Oernployees) 29 15 2 2 19 3 1 2 4 1 6 10 1 2 4 10 1 112 2% Large Company 16 3 2 1 3 9 2 1 1 1 1 5 3 1 1 50 1% Representative Organisation 53 18 4 10 13 36 1 5 7 4 1 7 3 4 15 6 7 12 9 1 216 5% Trade Union 9 12 5 3 4 10 1 2 9 6 3 7 2 3 2 4 2 3 1 88 1.9% Interest Group 29 28 8 10 5 38 1 2 10 7 2 9 1 5 13 10 8 4 6 3 199 4% LocalGovemment 128 31 11 9 12 35 7 6 4 1 4 2 10 15 14 5 12 7 313 7% Central Government 86 24 10 6 11 21 10 12 6 2 4 3 5 4 2 6 12 4 2 230 5% 14 2 8 5 2 113 2% Other Emergency Service (Police/Fire/Ambulance) 24 10 3 3 4 25 — 1 2 2 1 3 1 3 MemberofMCAStaff 119 67 22 54 38 109 12 23 75 74 29 50 9 9 16 20 16 31 8 4 785 17% Member of a Coastguard Rescue Service 56 43 16 23 10 53 3 12 12 12 35 18 6 14 23 11 7 21 17 6 398 8% MemberofthePublic 937 327 107 117 51 548 24 80 104 64 50 84 18 112 249 47 108 186 89 122 3424 72% Other 26 9 2 2 2 17 3 1 2 3 1 2 4 1 4 1 2 82 2% None Shown 168 34 8 26 12 41 7 10 16 11 7 18 2 9 2 5 11 23 5 1 416 9%

Totals 1680 621 200 264 167 961 49 157 257 193 133 210 52 182 370 113 184 314 168 151 4746 100% Percentottotalcomments 35% 13% 4% 6% 4% 20% 1% 3% 5% 4% 3% 4% 1% 4% 8% 2% 4% 7% 4% 3% 100% Where interest in single subject is greater than 5% of total comments/no comments on all themes.

Note: The numbers shown in the columns headed YES and NO are returns that contained no other comment.

23 Characterisation by Questions

I 000

000

400

200

I I II

(P C?’,

(P

24 Campaigns and 2Petitions

Nature Campaign Name Numbers E-mail Save our Coastguard 365 Campaign letter Liverpool version (a) 72 Liverpool version (b) 94 Liverpool version (C) 4 Liverpool version (d) 96 Campaign Liverpool should stay open because.. 185 Question sheet “Under one roof” cover document.

Signatures on Liverpool Petition 50,000 hard copy Campaign letter Save Clyde version (a) 1,127 Save Clyde version (b) 22

Newspaper tear MilfordCoastguard Saves Lives 10 out Signatures on Save Swansea 157 hard copy Signatures on Save Swansea delivered to No.10 100,000 hard copy Downing Street

Dorset Echo Locate super centre in Weymouth 22,152 Signatures on delivered to No.10 Downing Street hardcopy Web based Not directly linked to consultation and 5,000+ petition numbers still rising.

2 Petitions received were noted as above but it is possible that other web-based petitions existed of which the Review Team were unaware. 25 ANNEXA

Response Review Process

Response Review Process V3.2 Consultation Reference to hard copy Database Letters and other MSUs/PQs/e Petition/Campaign hard copy. mails sent to Letters and Petitions Electronic Responses Minister etc. 4 (e-forms and e-mails)

>0ci) Cu I NB:All responders are referred back COO to the formal consultation process. 0)0) CuD D D Anonymise responses, but indicate nature of Prepare statistics and metrics on all O responder (e.g. organisation or member of staff). other correspondence received, including summary of examples of Compile responses into batches by Question No. —0 petitions/campaign type and any other comment; print-out ready for correspondence. — characterisation. Zcu00

• Characterise responses to each question by themes (include petition letters, but only characterising one of each type — refer to the metrics on each type received).

• Identify any ideas and specific risks/areas of specific serious concern/significant quotes; summarise and characterise.

Compiled all Ideas/Risks and Issues Record identified. in Key characterisation database to create Board summarising all metrics/graphs. Chairperson’s report to the The ConsultationTeam responses to the consultation exercise — agree draft with Review Team The ReviewTeam I Results Database

26 ANNEX B

REVIEW TEAM AND TERMS OF REFERENCE

The ReviewTeam

The Team Leader arranged for the same group used in the first independent review to re-assemble for the second review. This included officers from MRCCs earmarked for closure as well as MRCCs earmarked to remain open as per the second consultation proposals. There were two officers representing Coastguard Sector Managers, one officer from MCA Headquarters and an officer from Senior Coastal Management - a team total of 12 Coastguard Officers.

The PCS provided a further 4 Coastguard Officers who acted in their capacity as PCS Representatives and played a full and active part in the review process.

The team comprised the following Officers —

Bob Banham, Non-Executive Director, Chair Kevin Brown, WM Aberdeen Peter Bullard, WM Falmouth Hilary Durkan, SM Southampton Peter Dymond, Independent Review Team Leader Ian Graham, WO Belfast, PCS Rep Steve Huxley, SAR Communications Manager Val Jenkinson, SEC Vice President, PCS Rep Steve Jones, WM Swansea Dave Macbeth, WO Stornoway, PCS Rep Carey Mackinnon, WO Solent Steve Quinn, WM Aberdeen, PCS Rep Mark Rodaway, RCCM Portland Katherine Self, CWA Clyde Robert Teatheredge, WM Thames Sue Todd, CSM East SCOTNI, Deputy Team Leader Tony Tuton, RCCM Humber Wendy Wood, HQ CRS Team Anne Young, SM Dornoch

27 Terms of Reference

The need for Assurance

The publication on 14 July 2011 of the document “Protecting our Seas and Shores in the 21st Century Consultation on revised proposals for modernising the Coastguard” was the start of the formal consultation period concerning the proposals contained within the document. The consultation ends on 6 October 2011 and an independent in-house review team will be established to consider all the responses put forward against the proposals in the consultation document to form a measured and rationally argued way forward. This team will act fairly and without bias and will operate separately from the team responsible for the authorship of the consultation document.

The membership of this review team is based on the following criteria:

• That members have had no direct contribution to the concepts that underpin the modernisation proposals described in the consultation document; • That members have a knowledge of the consultation document, the circumstances of its creation and the questions it asks (an initial presentation of the proposals willbe provided to the review team by the consultation team who will also be available to provide detailed clarification on any specific points as required); • That Coastguard technical members have a sound practical experience of having worked in the Coastguard organisation for at least 2 years; • That non-Coastguard members have worked or been associated with the MCA for at least 4 years; • That members are drawn from a range of levels and geographical locations across the service. Governance

The team is to be appointed as a separate working team within the Consultation Programme Management structure reporting through a chairperson. The nomination for chair will be approved by the MCA Executive Board. The work of the team will be guided by a senior and experienced Coastguard Officer.

The team will also include representation, as necessary, from Finance and Governance, and HR.

Attitude and Behaviours

Participation on the Review team is a position of trust that carries obligations and degrees of personal accountability.

There is a requirement for team members to act with considered impartiality and objectivity in assessing the arguments and weighing the evidence presented in the consultation responses, even accounting for the possibility that they may be personally affected by any findings.

28 Team members must be discreet before, during and after their involvement. It is unacceptable for members to represent any section or lobby during this undertaking or report back to colleagues and line managers or publish in any way any aspect of their participation.

Information used, processed and produced by the working team will be protectively marked as per HM Government guidelines. Members of the review team will be subject to the MCA’s Information Security Policy and will be subject to compliance with the Data Protection Act.

If candidates believe at any time, either before or during the Review, that they cannot conform to these professional standards of behaviour they should declare and excuse themselves from involvement without prejudice. Team members must abide by all current MCA rules including dignity at work and the CivilService Code. Required Outputs

The Review Team is to produce a Report for the Programme Senior Responsible Officer (SRO) which contains the following:

• An overview of the responses received and their general characteristics; • A summary of the views expressed in respect of each of the questions asked in the consultation document; and any other significant comments; • Report the Review findings to SRO of the Consultation Programme and MCA Chief Executive. If there is disagreement within the Review team which cannot be resolved this should be documented and the recommendation made based on the judgement of the team’s chairperson.

The documentation of any unresolved disagreement should be annexed to the recommendation; there willbe no publication of ‘MinorityReports’.

Timing

The Independent Review Team will be established prior to the end of the consultation period (6 October 2011). The existing consultation team will maintain a formal supplier/customer relationship with the Review team. It will provide the Review team with the following:

• a full contextual briefing on the proposals; • access to any background material and information used in preparation of the proposals; • access to all responses; • a full statistical analysis of all responses and respondents; and • access to specialist individuals who have contributed to the proposals, to provide further detail or explanation.

Separation of function will be maintained throughout the review process, the principal link being a neutral executive member of both teams who has had no direct input into the consultation document.

29 Team Members

Members of the review team will represent a spread of grades and geographical location and currently work in locations which are potentially affected in different ways by the proposals. It is anticipated that the PCS will be represented at all meetings of the Review Team.

Rationale for this approach

Quality assurance is generally outside the scope of PRINCE2 (Project Management Methodology) because it is the responsibility of the corporate or programme organisation in which a project sits. However, the PRINCE bible does say that it is good practice to arrange for quality assurance independent of the project management team. Also one of the senses in which the term ‘Quality Assurance’ is used is “the activity of reviewing a project’s organisation, processes and/or products to assess independently whether quality requirements are met” Office of Government Commerce guidance on Managing Successful Programmes (MSP) defines ‘Quality Assurance’ as “An independent check that products will be fit for purpose or meet requirements”

The Department for Business Innovation and Skills Code of Practice on Consultation

All responses (both written responses and those fed in through other channels such as discussion forums and public meetings) should be analysed carefully, using the expertise, experiences and views of respondents to develop a more effective and efficient policy. The focus should be on the evidence given by consultees to back up their arguments. Analysing consultation responses is primarily a qualitative rather than a quantitative exercise.

In order to ensure that responses are analysed correctly, it is important to understand who different bodies represent, and how the response has been pulled together, e.g. whether the views of members of a representative body were sought prior to drafting the response.

Consultation documents should, where possible, give an indication as to the likely timetable for further policy development. Should any significant changes in the timing arise, steps should be taken to communicate these to potential consultees.

Following a consultation exercise, the Government should provide a summary of who responded to the consultation exercise and a summary of the views expressed to each question. A summary of any other significant comments should also be provided. This feedback should normally set out what decisions have been taken in light of what was learnt from the consultation exercise. This information should normally be published before or alongside any further action, e.g. laying legislation before Parliament.

Those who have participated in a consultation exercise should normally be alerted to the publication of this information. Consideration should be given to publishing the individual responses received to consultation exercises.

30 ANNEX C

TERMS OF REFERENCE

INTERNAL QUALITY AUDIT OF THE INDEPENDENT REVIEW OF RESPONSES TO THE JULY 2011 FUTURE COASTGUARD CONSULTATION

Directorate(s): FINANCE & GOVERNANCE Director: SUE KETTERIDGE

Audit objective

To provide assurance that the collection and review of the responses to the 2011 revised consultation document “Protecting Our Seas and Shores in the st21 Century” has been carried out in accordance with HM Government’s Code of Practice on Consultation, that all responses have been taken into account and analysed, and that the resulting report is an accurate reflection of those responses.

Audit criteria

2. The criteria against which the process will be audited are:

• HM Government’s Code of Practice on Consultation • Independent Review Team Terms of Reference • ISO 9001:2008 Standard — Quality Management System Requirements.

Audit scope

3. The audit willexamine the MCA’sprocess for reviewing the responses received to the July 2011 Coastguard modernisation consultation following the completion of the formal consultation period on 6 October 2011. This includes:

• The methodology used to examine and categorise responses • The composition and operation of the team undertaking the review of responses • The delivery of the required outputs from the review team’s terms of reference Audit approach

4. The audit will be carried out in an objective and impartial manner, through discussion with key contacts, examination of relevant documents and files, and by sampling the responses received to ensure they have been accurately recorded.

31 5. Any emerging findings will be discussed with key contacts during the audit. At the end of fieldwork, a closing meeting will be held to present findings, confirm factual accuracy and agree any corrective actions. Following this meeting, a draft report will be issued for comment prior to issuing the final report.

6. The proposed timetable of events is:

Opening Meeting w/c 3rd October 2011 Start of fieldwork: 10th October 2011 Completion of fieldwork: Dependant on review timescale Closing meeting held: tbc Draft report issued: [10 working days after closing meeting] Auditee response: [10 working days after draft report issue] Final report issued: [5 working days after auditee response]

9. The audit team consists of:

Lead Auditor: Steve Horn, Lead Auditor, CG&R

10. Key Contacts:

Bob Banham Non-Executive Director and Chair of Review Panel Peter Dymond Review Team Manager Andrew Austin- Head of Research & Planning Hancock

NB: The planning, scope, approach and timetable set out in these terms of reference may change in the light of preliminary findings. Any significant changes will be discussed with the Director of Finance & Governance and key contacts as appropriate.

Steve Horn Technical Risk Assurance Lead Auditor Corporate Governance & Risk

3 C’.-...... -. ....,.... 4..-.I. 4k- ‘.JI.JII I I lltIVVI.Jl I’. II iciy Lclfl Jlat, 1fri LII LLI LI lii I L V lLVV LCiI II II IL.LILll I ‘.11 I I Li ..iLIL’.JIJL.#I LLI L4ll I assurance on the collection and recording of data, and the preparations for the review of responses. 32 ANNEX D

CG&R Review Pocess Audit Statement.

INTERNAL QUALITY AUDIT OF THE INDEPENDENT REVIEW OF RESPONSES TO THE FUTURE COASTGUARD CONSULTATION

The analysis and reporting of the responses to the consultation document “Protecting Our Seas and Shores in the st21 Century” on revised proposals for modernising the Coastguard 2011 was independently audited by an ISO 9001:2008 lead auditor from the MCA’s Corporate Governance and Risk Division. The purpose of the audit was to ensure that the review and analysis of responses was carried out in accordance with HM Government’s Code of Practice on Consultation that all responses were taken into account and analysed, and that the resulting report was an accurate reflection of those responses. 4 Terms of reference, for the audit were agreed with the Chair of the Review Team (an MCA Non-Executive Director), and the MCA Finance and Governance Director, ahead of the review of the consultation responses (See Annex C

The audit included observation of the team undertaking the analysis of the responses, discussion with key contacts, and 10% sampling of the responses received through the data capture and analysis tool.

The auditor is able to give the following assurance:

1. The composition and operation of the Review Team met the requirements for independence and impartiality, and the analysis and discussion of responses was undertaken objectively.

2. The methodology used to capture, examine and categorise responses, was robust and ensured that all responses were considered.

3. The resultant Report is a fair and accurate representation of the views expressed through the consultation process, and meets the required outputs from the Review Team’s terms of reference.

Steve Horn Lead Auditor, Technical Risk Assurance Corporate Governance & Risk Maritime & Coastguard Agency

HM Government Code of Practice on Consultation, published 2008. See www.bis.gov.uk 33 ANNEX E Characterisation Descriptors

LK: Knowledge of the local area (geographical), knowledge of local place names and terrain, knowledge of local anomalies and environment. Situational awareness.

LI: Local Intelligence: Knowledge of resources and useful contacts; their capabilities and limitations; dynamic information which is known about locally but not further a field. e.g. local events; key holders; location access; land owners.

LN: Language - Local dialects, language and pronunciation.

LE: Local resilience planning. Maintaining SAR partner, other emergency services and stakeholder relationships.

ConOps: Anticipated concept of operations, (e.g. working practices between MOC and MRCC5), roles and operational procedures. Selection of centres and hours of operation.

Corn: Complexity — Periods of high incident workload versus fewer but equally resource intensive, complex individual incidents

Eco: Economy - Impact on jobs, tourism and the local economy

Res: Resourcing - Comments about resourcing; retention of sufficient experienced staff and impact on training and leave.

Peps: People - Watch patterns, terms and conditions, overtime, relocation and redundancy policy.

CRS: Comments regarding the reliance on, or additional tasks expected of, the volunteer Coastguard Rescue Service. Comments on proposed new Sector Organisation; on scene co-ordination of ‘dry’incidents.

Tech: Technology - Comments about future technical resilience and reliability, networking arrangements or existing systems.

Info: Information - Comments about the lack of information or detail in the consultation document.

Mis: Misunderstanding - Comments which indicate a lack of understanding of the role, organisation, capability and communications of the Coastguard or how the proposals relate to the operations room staff.

Amb: Ambiguous - The response does not address the question.

NoCo: No comment — no response to a question.

34 CC: Operational communications between MOC and MRCCs. How will the communication work, how will telephone calls be handled and transferred, how will radio traffic received at one site be passed to the other. How will MOCs and MRCCs communicate with CRS and other assets/resources?

Rec: Comments regarding the effect of the proposals on non—SOLAS recreational craft and other leisure activities as opposed to larger commercial vessels.

Cost Cutting: Comments suggesting that this a cost cutting exercise.

35 ANNEX F

Glossary of Terms

Cat I Category I responder for Civil Emergencies CG Coastguard CG&R Corporate Governance & Risk CRC Coastguard Rescue Officer CRS Coastguard Rescue Service CRT Coastguard Rescue Team CRV Coastguard Rescue Vehicle CSM Coastal Safety Manager CWA Coastguard Watch Assistant DfT Department for Transport FOIA Freedom of Information Act HMCG Her Majesty’s Coastguard LNG Liquid Natural Gas LPG Liquid Petroleum Gas MCA Maritime & Coastguard Agency MOC Maritime Operations Centre MRCC Maritime Rescue Co-ordination Centre MRSC Maritime Rescue Sub Centre PCS Public and Commercial Services Union RAE Royal Air Force RCCM Rescue Co-ordination Centre Manager SAR Search and Rescue SM Sector Manager SOLAS Safety of Life at Sea Convention SRO Senior Responsible Officer TEP Time Expired Pyrotechnics VTS Vessel Traffic Services WM Watch Manager WO Watch Officer

36 mca Mar,time and Coastguard Agency

PROTECTING OUR SEAS AND SHORES IN THE 21ST CENTURY

REPORT ON THE CONSULTATION RESPONSES June 2011

“The backbone of the Coastguard willalways be the men and women who know the shores, love the sea and willdo their utmost to save lives at sea and around our coast”

Presentation of Her Majesty’s Colour to HM Coastguard 20 July 2005

R.E. Banham FCMA, Non Executive Director P.R Dymond OBE, HQ Coastguard Rescue Service Team Manager Independent Review Team Members

I t’J Contents Page Numbers Title page 1

Listof Contents 2

Executive Summary 3-6

Introduction 7

Section 1 Aim of an Independent Review 8

Section 2 Composition of the Review Team 9

Section 3 The Review Process 10-11

Section 4 Themes and Findings 12-15

Section 5 Alternative Proposals 16-18

Section 6 Locations 19

Section 7 Risks and Concerns 20

Section 8 Ideas 21

Section 9 Observations 22

Annex A Review Process Schematic 23 Annex B Metrics 24 Annex C Review Team 25 Annex D Terms of Reference for Review Team 26-29 Annex E Terms of Reference for Corporate Governance & Risk Team 30-31 Annex F Statement of Internal Audit of the Review Process 32 Annex G Consultation Questions 33 Annex H Characterisation Descriptors 34-35

Annex I Summary of Alternative Proposals 36-46 Annex J Common Themes of Concern by Group of Respondent 47 Annex K Risks and Concerns Log 48-49 Annex L Ideas Log 50-60 Annex M Glossary of Terms 61

3 17 EXECUTIVE SUMMARY Background

In December 2010, the Government announced a formal consultation on its plans to modernise HM Coastguard and a consultation document ‘Protecting our Seas and Shores in the 21st Century’ was issued immediately following that announcement. The consultation document provided information about the modernisation proposals under consideration. These included improved technology to deliver a nationally networked and more resilient service, at lower cost and staff would be better rewarded for taking on increased responsibilities with enhanced career opportunities.

A team comprising 17 serving Coastguard Officers including four Public and Commercial Services Union (PCS) representatives was assembled to independently review the responses to the consultation. The team was led by a senior Coastguard Officer with a Maritime & Coastguard Agency (MCA) Non- Executive Director as Chair.

The review team carried out a quantitative review of the responses to the consultation document to identify key themes and concerns. At the same time a qualitative examination was completed to identify risks and ideas. In the case of alternative proposals received the rationale and underlying drivers have also been noted.

In producThg this independent review report it was not the team’s mission to provide an alternative or final solution or to apply judgement as to whether a response was in favour o or against, the proposals. The questions contained in the consultation document invited evidence based comment and the exercise was intended to gather information rather than conduct a referendum.

The team’s work was monitored throughout by members of staff from the MCA Corporate Governance and Risk Division and the PCS representatives. Major Themes and Messages

Local Knowledge

This was by far the biggest area of concern (32%), with comments primarily from the small boat (<300gt), leisure and recreational sectors. The modernisation proposals were not seen to provide a reasonable level of assurance. There were three recurring themes under local knowledge:

• loss of local knowledge or slow access to local knowledge leading to delayed or incorrect response and potential loss of life; • over reliance on the volunteer Coastguard Rescue Service (CRS) or other partners such as the Royal National Lifeboat Institution (RNLI) to fill the

5 local knowledge gap arising from the closure of a local Rescue Co ordination Centre (RCC); and • difficulties likely to be encountered in relocating current serving Coastguard Officers, who have the local knowledge, to the remaining RCCs owing to personal circumstances at their present location or constraints on financial support packages.

Concept of Operations (how the new proposals will work in practice)

This was the second significant area of concern (16%). The most common comment was that the remaining RCCs should be run on a 24/7 basis. The main drivers being:

• that a handover between a daytime Rescue Sub Centre (RSC) and a Maritime Operations Centre (MOC), in particular for ongoing incidents, is high risk; • lack of local knowledge willbe heightened at night; and • there is the potential to create a two tier Coastguard Service with the staff at the RSCs being viewed as ‘second class’ and with limited career development opportunities in the daytime set up.

Additionally the modernisation proposals did not give enough detail on the likely work practices, procedures and protocols envisaged within the new MOC/RSC structure making respondents apprehensive about the quality of service delivery and commenting on the need for exhaustive trials and testing.

The need for the current regional operations structure was challenged against the background of a downsized national service. Resources and People

The primary issues here concerned basic levels of pay, the relocation package or the severance package if compulsory redundancies became necessary. The modernisation proposals indicated that introduction of new technology and working practices would require enhanced skills and would be appropriately rewarded. Naturally without any detailed information, staff concerns were heightened. Technology

Costly Public Sector failures to successfully deliver major system/technology improvements prompted many concerns over the MCA’s ability to introduce the key technological improvements that underpin the proposed modernisation. Generally, this part of the modernisation plan was well supported, with the caveat of the need for detailed planning and testing before roll out and RCC closure.

6 Regulation

Several of the MCA’s stakeholders felt that existing regulations covering the small boat and leisure sectors were in need of modernisation. Suggestions included the testing and licensing of yacht and small boat users and life jacket regulations (parallels with the motor industry). Respondents felt funds raised could be used to offset MCAcosts.

Alternative Proposals

27 submissions with alternative proposals were received mainly from RCCs or serving officers, one from the PCS and another from a local authority. Their main messages were —

• a reduced number of RCCs (retaining between 6 and 15 centres); • a geographic spread of stations to cover each devolved administration, minimise staff relocation, and maintain local knowledge; • 24/7 operations throughout, therefore retaining more staff; • support for investment in an upgraded communications network to improve national and territorial resilience; • low support for the two MOC concept — lack of operating process details in the proposals may have been a contributory factor; and • low support for the proposed changes to the CRS and its revised management; also uncertainty around its operational interface with MOCs/RSCs.

Sum mary

The Findings in this Report reflect the content of the responses to the consultation on the modernisation of HM Coastguard and express varying concerns about different aspects of the proposals. Whilst there is general acceptance of the need for HM Coastguard to modernise, the respondents have questioned the modernisation as proposed and argued that its radical nature will reduce the UK’s capability to continue to respond successfully to maritime and coastal emergencies.

The lack of operational detail in the consultation proposals and the likely loss of experience, local knowledge and an untested concept of operations and supporting technology have raised doubts about the proposals’ validity and credibility.

From the responses received it is clear that the final decision on a modern Coastguard infrastructure and concept of operations needs to be carefully explained to staff and members of the public and that thorough testing is required before implementation to ensure the planned improvements and efficiencies can be safely realised.

7 Quantitative Summary: Themes and Concerns

A quantitative summary of key themes and concerns identified from all the responses received during the consultation period, including the alternative proposals, are shown in the chart below. Definitions of the characteristics used in the chart can be found in Annex H.

Distribution of key themes

Recreational Users Cost Cutting Local Knowledge Operational 16% Communications 2% Ambiguous 7%\ Intelligence \ A Misunderstanding N 7% 4%

InsufficientInformation Language/Dialect 3% 3%

Technology 7% Local Partner Liaison 6%

—Concept of Operations 16%

4%

6% \Complexity Local Economy 2% 3%

8 Introduction

In December 2010, the Government announced a formal consultation on its plans to modernise HM Coastguard.st21 The consultation document1 Protecting our Seas and Shores in the Century’ was issued immediately following that announcement with a closing date for responses of 24 March 2011 which was subsequently extended to 5 May 2011.

The consultation document provided information about the modernisation proposals under consideration and in particular the use of technology to move away from territorial centres and deliver a nationally networked and more resilient service, at lower cost, with better rewarded staff taking on increased responsibilities and with enhanced career opportunities. The document also highlighted that the scope of the consultation focused around 7 key questions (as listed at Annex G) with an option to add any other comments not covered by the key questions.

The consultation was owned by the Department for Transport (DfT) but managed by the MCA. An independent in-house team of experienced Coastguard Officers led by a well respected senior Coastguard Officer and chaired by an MCA Non- Executive Director was formed to carry out the review. This took the form of a quantitative and qualitative consideration of all responses to the consultation received up to the closing date of 5 May 2011. Response channels consisted of e-forms (as per consultation document), emails, letters and larger responses in the form of some alternative suggestions to those described in the consultation document.

Neither the Chair, team leader nor team members had been involved in the development of the modernisation proposals within the consultation document and the team acted in an impartial, independent and discreet manner to capture the themes, ideas, risks and alternative proposals from the responses.

The PCS Union played an integral part in developing the process and, through their involvement in the review of the responses, has ensured the process has been open, independent and impartial.

The output from the review team’s work is contained in this report which details the key findings from the consultation.

The Chair was not required to resolve any disagreements within the independent review team.

1 In accordance with HM Government Code of Practice on Consultation 9 Section 1 Aim of an Independent Review

1.1 The purpose of an independent review is to ensure impartiality and transparency throughout the review process including the production of the final review Report.

1.2 The purpose of this Report is to:

• provide information on the methodology used to review the responses to the consultation; • report on the key themes, concerns, ideas and risks gathered from the responses to the consultation proposals; • provide findings and observations arising after careful consideration of all responses on the basis of all evidence received; and • to continue DfT/MCA’s commitment to an impartial and transparent approach to the consultation process.

1.3 The process to capture the response data was as follows:

• all e-forms, e-mails, letters, alternative proposals and other written responses were recorded, referenced and catalogued under the appropriate question on receipt, where no specific question was addressed this was categorised as any other comments’; • all requests for information under the Freedom of Information Act were logged and responded to within the time frames set down by the Act. Replies to FOIA responses were published on the MCAwebsite.

1.4 The response data capture was carried out by a team drawn from executive and administrative staff within MCA HQ.

1.5 A full audit trail has been compiled and comments used in reports and feedback can be traced back to source. A schematic of the review process is at Annex A and response numbers at Annex B.

10 Section 2 Composition of the Review Team

2.1 The Government decided that because of the technical and specialist nature of the proposals that the independent review team would consist of Coastguard Officers who had no involvement with, nor made any direct contribution to the concepts that underpinned the modernisation proposals described in the consultation document. This included the Chair, a Non-Executive Director to the MCA, and the Team Leader, a senior Coastguard Officer. Most importantly, the team would act fairly and without bias and operate separately from those responsible for the authorship of the consultation document.

2.2 The Team Leader was tasked with assembling a team of 12 Coastguard Officers with a range of grades, experience, location and gender. This team was augmented by 4 additional Coastguard Officers acting in their capacity as representatives of the PCS Union and an additional Coastguard Officer representing senior coastal managers and to act as deputy team leader. The Review Team is listed at Annex C.

2.3 The Review Team was first brought together on 4 May 2011 where the members were briefed as to their responsibilities; their terms of reference; the timeline and the methodology to be used to review the responses. The team met over two separate weeks to carry out their review of the responses to the consultation. The full terms of reference for the team are at Annex D.

2.4 An auditor from the MCA’s Corporate Governance and Risk Division (CG&R) was present throughout the review process to provide assurance that the collection and review of the responses was carried out in accordance with HM Government’s Code of Practice on Consultation. CG&R has remained involved to ensure that this Report and its findings are an accurate reflection of the responses and their evaluation. Terms of reference for CG&R are at Annex E.

2.5 A statement from CG&R on their internal audit of the review of the responses to the consultation is shown at Annex F.

11 Section 3 The Review Process

3.1 Responses were received as e-form, e-mail, letter or other written format amounting to a total of over 1,800 items of correspondence which contained replies to all or some of the 7 separate questions posed in the consultation document (See Annex G). This included an invitation to add any other observations or comments not covered by the questions and for the purposes of the review, this was treated as question 8.

3.2 e-form responses with answers to some or all of the questions provided the bulk of these submissions and each answer was catalogued under the appropriate question thereby producing a catalogue of responses for each question. Where a response did not address any specific question, it was catalogued under the ‘any other comments’ question. The responses to each question plus email, letter and other written responses gave rise to over 14,000 individual answers or comments that needed to be scrutinised and characterised.

3.3 In the first part of its review, the team devoted its time to the characterisation of these answers and comments in relation to 18 possible descriptors (see Annex H) plus the extraction of risks and ideas. This included “no comment” where a question was not addressed. Each answer or comment was characterised under one or more of these descriptors and gave rise to over 25,000 individual items of data, including over 8,100 ‘no comments’ being recorded. These were used to identify key themes and common concerns in relation to each question. The results of this characterisation are at Annex J where the table shows the common themes of concern against the various groups of respondents.

e-form process

3.3.1 The review team was divided into 8 pairs, with a mix of grades, location and experience within each pair. This also ensured that a process of dynamic peer review occurred simultaneously with the evaluation of each response. For the first two days, one PCS representative was given a roving assignment to sit in with each pair to ensure the agreed methodology and process was being adhered to.

3.3.2 Each pair was given the catalogue of responses to one of the eight questions in order to read each answer or comment and to attribute the appropriate characterisations and record risks, concerns and ideas accordingly.

Hard copy process

3.3.3 The characterisation of hard copy e-mails, letters and other written responses was carried out in the same way, using the same pairs working through the documents and attributing characteristics accordingly. 12 Submissions with alternative proposals - process

3.3.4 27 of the responses described alternative proposals, incorporating different organisational, structural and technical network laydowns to that contained in the consultation document. For this part of the review, the team was divided into groups of 4 or 5 to concentrate on the characterisation and summarising of these alternative proposals. These groups were predetermined and allocated submissions to review which did not relate to the home or neighbouring RCCs of the group members, and avoided submissions they had personally submitted or those of colleagues from their own or neighbouring RCCs. More detail of these alternative proposals is shown in Section 5 and the summaries are shown at Annex I.

13 Section 4 Themes and Findings

4.1 The themes and findings that emerged across the responses are as follows:

LOCAL KNOWLEDGE

Finding I

That the overriding concern in the responses to the consultation was that the proposed reduction in RCCs will lead to loss of local knowledge, local intelligence, give rise to potential difficulties with local language and dialect and lead to delayed response and potential loss of life.

Finding 2

That the proposals placed an over-reliance on SAR volunteers for local knowledge when in fact, because they are volunteers, they may not be available or their local knowledge may be inconsistent and at no set standard.

Finding 3

The importance and context of local knowledge and its associated factors in SAR co-ordination were thought to be under-valued in the proposal.

Finding 4

Many of the concerns relating to local knowledge emanated from, or were related to, the small craft user and recreational community who felt they had not been adequately considered in the proposal.

LOCAL RESILIENCE AND RELATIONSHIPS

Finding 5

That the reduction in the number of RCCs will weaken the local operational relationships with devolved administrations, emergency services, SAR and civil resilience partners and that this will impact on command, control, communications and co-ordination within single or multi-agency incidents including major incident working.

Finding 6

The reduction in the number of RCCs could lead to isolation of Coastguard Rescue Teams (CRT5) and other SAR partners who view RCCs as the focal

14 point for Coastguard activity and a source of local knowledge and maritime information.

Finding 7

Respondents felt that the proposed centralisation’ of HM Coastguard willweaken its local ‘presence’ when the current Government drive is for regional advancement and an increased localism agenda.

Finding 8

That there was no real evidence in the proposals that new or developing external pressures eg major expansion in off-shore renewable energy developments, importation of Liquid Petroleum Gas and other marine related activities and industries have been considered.

CONCEPT OF OPERATIONS

Finding 9

The consultation proposals lacked detail of the MDC role, concept of operation and its relationship with the daytime RSCs. The lack of information concerning the protocols, processes and procedures to be used in support of such a concept were also noted by respondents.

Finding 10

The respondents saw no evidence of robust testing or field trials to prove the MDC and daytime RSC concept of operations nor of the technological solution that willfacilitate this concept and the wider modernisation.

Finding 11

The handover of incidents from daytime RSC to MDC and vice versa was perceived to be high risk for delivering emergency response which could be mitigated by providing 24 hour cover at the retained centres.

Finding 12

That whilst there was support for a modernisation of HM Coastguard it was based on 24 hour cover at any retained centres. There was little support for daytime RSCs.

Finding 13

Respondents felt that the complexity of co-ordinating SAR response operations by a volunteer Coastguard Rescue Team in the ‘dry’ coastal littoral area when involving land, sea or air assets and its relationship with the MDC or RSC was not addressed in the consultation proposals. 15 Finding 14

Respondents indicated that the proposals assume an unrealistic level of technology in terms of communications and navigational aids within the small boat and recreational community.

Finding 15

Respondents indicated that the MCA Regional operations structure worked against the concept of a national maritime emergency response system by putting an unnecessary ‘dog-leg’ in the command and control chain.

THE COASTGUARD RESCUE SERVICE

Finding 16

That the demands already placed on the volunteer CRS are such that there is little or no capacity to take on the proposed additional roles, particularly the complex process of on scene co-ordination, and the additional training it will entail.

Finding 17

That whilst there was support for strengthening the management of the CRS as per the proposals, some respondents questioned the need to introduce another layer of management and preferred the introduction of a layer working in support of current Sector Managers which would also introduce a degree of succession planning and career development.

Finding 18

That a considerable investment in technology will be required to achieve the proposed improvements in the management of, and support to, the CRS, and for the data transfer requirements needed to ensure effective on-scene co ordination.

RESOURCING AND PEOPLE

Finding 19

That the reduction in the number of RCCs and the lack of mobility amongst staff could potentially lead to a substantial loss of expertise and experience which in extremis could affect MCA’s ability to fulfilits statutory SAR co-ordination role and maintain its Vessel Traffic Monitoring (VTM)capability.

16 Finding 20

That the staffing of MOOs and daytime RSCs could lead to an unacceptable two- tier Coastguard service in terms of grade, pay and operational exposure.

Finding 21

That the modelling of RCC activity to identify peak and non-peak periods did not appear to have included all non-SAR tasks and may not represent the true picture of RCC activity patterns.

Finding 22

That the proposals minimised the opportunities for career advancement as there would be fewer sites and fewer posts.

Finding 23

That many respondents raised questions concerning the ‘unknowns’ i.e. new terms and conditions of service; annualised hours and watch patterns; relocation package; redundancy terms.

TECHNOLOGY

Finding 24

That the updates and improvements to HM Coastguard’s existing information technology, which would underpin the modernisation proposals, were untested and unproven in a live environment.

Finding 25

That other Government and Local Authority failures to deliver successful implementations of major system/technology improvements prompted questions concerning the MCA’s ability to deliver the key improvements which were the corner stone of the proposed modernisation.

THE PROJECT

Finding 26

Concern was expressed that the extended period of consultation and the potential for more to come would impact on the delivery period. A number of respondents felt the time line was unrealistic in the base case.

17 Section 5 Alternative Proposals

5.1 A total of 27 submissions were received each offering a set of different proposals to those in the consultation document. Of these 27 submissions, 25 were either from a group of RCCs, single RCCs or individual Coastguard Officers with two from external organisations.

5.2 Whilst there was acceptance of the need to modernise HM Coastguard, there was less consistency in terms of organisational structure with, for instance, the number of retained RCCs varying between 6 and 15 with one submission advocating no reduction but with improved network technology.

5.3 Sixteen of these alternative proposals listed those RCCs which the authors thought should be retained.

5.4 In terms of the proposed concept of operations, there was little support for the two MOCs solution with either one or none being the most popular suggestion. This was confirmed by a lack of support for a totally national concept of operations. There was some support for a hybrid between national and territorial, but the majority preferred a territorial concept of operations. Interestingly, although there was a lack of support for a national concept of operations, there was stronger support for operational resilience on a national basis though the preference remained for resilience within different groupings which tended to support the territorial concept of operations.

5.5 Another key theme in the more substantial submissions was that the network should allow for the ready assimilation by one RCC of another’s duties to allow for increased opportunities for local training events to ensure the necessary improvements in the operational standards that will underpin the modernisation programme.

5.6 Of the 22 submissions that commented on the coastal rescue proposals, the majority (14) suggested some variations to the proposed structure. The most common variation being that instead of inserting another level of management, that the resources should be used to provide direct support to current Sector Managers at a subordinate level. Six submissions supported the proposed new management structure whilst the remaining two preferred the status quo.

Alternative Proposals — Drivers for Change

5.7 There was acceptance in these alternative proposals for the need to modernise and on the assumption that the technology will allow for RCCs to be fully networked on a territorial and national basis, the biggest drivers for these alternative proposals appeared to be staff and resilience issues.

18 Staff Issues

5.8 Respondents expressed concern that as an organisation whose duty is to save lives or to help those in trouble at sea or on the coast, HM Coastguard can ill-affordto lose substantial numbers of experienced staff with the necessary skills and knowledge during the modernisation process. To do so may mean it would be incapable of meeting its primary duty. They also suggested that the less radical nature of the modernisation proposals contained in the alternative submissions mitigated that risk and also provided increased opportunities for career progression; increased opportunities for local training and better standards; minimum change with minimum disruption; and less need for staff to move. Resilience

5.9 The unpopularity of the daytime RSCs was evident in most of the alternative proposals where 24 hour centres were preferred regardless of status i.e. MOC/RCC/RSC. The small increase in the number of RCCs suggested by these proposals would help to ensure that local liaison and relationships with SAR and resilience partners were maintained; that there was a RCC in each of the devolved administrations and would allow for a reasonable geographical spread of centres. Most of these proposals required the RCCs to be fully networked allowing national resilience but grouped territorially for normal operational purposes.

Alternative Proposals — Themes and Findings

Finding 27

That there is support for the modernisation of HM Coastguard.

Finding 28

Respondents felt that there was little or no supporting evidence in terms of the concept of operations to suggest that the proposals, as described in the consultation document, would deliver the stated improvements in maritime and coastal emergency response.

Finding 29

Respondents felt that there was more likelihood of success if there was an increased Coastguard presence on a 24/7 basis in geographically dispersed stations, including the devolved administrations, where there would be less disruption to staff, better retention of experience and local knowledge and better operational and technical resilience.

19 Finding 30

That increased specialist training opportunities would need to be made available to ensure the necessary uplift in the standards, training and overall performance that willunderpin the modernised Coastguard Service.

A summary of the main attributes of the 27 alternative proposals and the Agency’s modernisation plan are shown in Annex.

20 Section 6 Locations

6.1 Chapter 4 of the consultation document requested particular comments or information about factors that should influence the choice for Sub-Centres in either Belfast or Liverpool, and either Stornoway or Shetland. The review established that the following factors were put forward in respect of each location.

• Rise in use of marine environment • Oilexploration off the Antrim coast • Liaison with devolved administration • Liaison with civilcontingency partners • Local Knowledge and pronunciation • Grid OS not the same as the rest of UK • Closure would mean no centre in Northern Ireland • Density of shipping • The ORS could become isolated • Relationship with Eire and cross border SAR

• Responsibilities for inland waters in Lake District • Expansion of maritime activity • Density of Shipping • Co-located site with long lease • Relationship with John Moore University • Coastal destination for residents of large cities/towns

• Fragilityof BT communication links • A strategic position for the UK • Expansion in oil exploration •Acomplex area • Cheaper to run than a MOO • Density of shipping • Highlevels of maritime activity

• Maintain quality of SAR on West Ooast of Scotland • Remote geography and topography • Shipping density and hazardous cargoes • A complex area • Cheaper to run than a MOO • Impact on local economy • MCAowns building • Retention of experienced staff • Local knowledge and language

21 Section 7 Risks and Concerns

7.1 A qualitative part of the review of the responses was the identification of risks and concerns raised by the respondents. The main operational risks and concerns identified included:

Deterioration in SAR performance resulting from:

• loss of SAR experience, expertise and local awareness; • lack of any clear, tried and tested concept of operations between MOC and RSCs and similarly between MOCs, RSCs and CRTs; • lack of any clear and considered path for transition from territorial to national concept of operation; • over reliance on SAR Volunteers e.g. CRS and RNLIfor local knowledge, local intelligence and on scene co-ordination; • lack of appropriate technology in CRS to facilitate revised concept of operations; and • weakened relationships with SAR stakeholders, Devolved Administrations, Local Government and civil resilience partners.

Resource concerns included:

• insufficient staff resource to cope with base level of SAR and non SAR work streams and the increasing levels of maritime activity predicted in the consultation document; • lack of resources to staff MOC/RSCs and to enable revised training requirement to be met; • lack of available hours for volunteer Coastguards to undertake revised training requirements; • inability to retain/recruit staff unless revised pay, conditions of service and adequate relocation package implemented; and • workforce morale.

Other risks and concerns included:

• lack of confidence that network technology upgrades willfacilitate the modernisation plans and be sufficiently resilient; • loss of reputation if the proposals fail; • operational targets not met; and • increased burden put on industry and SAR partners.

The complete list of risks is shown at Annex K.

22 Section 8 Ideas

8.1 Another qualitative part of the review was to capture ideas from within the responses. These were categorised under the headings shown below with the full list of ideas shown at Annex L.

• Maritime Operations Centre (MOC) Configuration • Other Configurations • Coast Rescue • Organisational Amalgamation • Additional Workstreams and Revenue Generation • Partnership Working • Trials and Training • Staffing • Selection Criteria • Other

23 Section 9 Observations

9.1 The Independent Review Team drew some observations from the responses:

• Whilst not included in the consultation document or its proposals, a number of respondents expressed concerns about the wider SAR picture and the reduction or withdrawal of VHF/DF, the Emergency Towing Vessels (ETVs), Nimrod Long Range SAR Aircraft, Maritime Incident Response Group (MIRG) and the Harmonised SAR Helicopter Force (SAR-H). Also, that any future proposals should make reference to these withdrawals and their mitigation.

• That the MCA should do more to educate the public on the role of HM Coastguard, its organisation, communications network, capability and the wider UKSAR framework.

• There was much comment concerning the centralisation’ concept as described in the consultation document with reference to other failed Government centralisation initiatives eg Fire Service.

• That the costs of salaries, security, heating, lighting and general maintenance of daytime-only centres had not been measured against a sub-centre’s operational value within the new concept of operations.

• It is evident from the responses that staff relocation willbe required to maintain the highest level of experience and knowledge and the MCA may need Ministerial support to provide a satisfactory package.

• Many respondents found that the consultation document lacked sufficient detail on the proposed modernisation, in particular the concept of operations, and that the wording of the 7 set questions may have contributed to the ambiguity in many of the responses.

24 ______The The Key — Z Z.c th .

o a-0 Consultation Review — - (e-forms Electronic a. Q . o Team or Compile responder Redact member and Team Responses responses, e-mails) responses where of public/staff Characterise Compile Identify database, characterised aspect every validate characterisation Record The indicated but into MSUs/PQs ideas Review potential show comparison Letters is batches data etc). ensure (e.g. responses and nature Reference and and Organisation risks/concerns, by Process in etc _____ summary Question. of 25 by correspondence. characterisation Filter of Redact .1 to theme. correspondence. hard Schematic for out and copy summarise alternative non-response compile and responses. Compiled Provide metrics by Jrn proposals. and validate for of Review before summarising characterise. information, outputs all tables, documents. Prepare Alternative data ideas Proposals reviewing progress

ANNEXA from I extracted create graphs comparison all characterisation alternatives. and copy take and stock ANNEX B

Metrics

The MCA received 1,859 consultation responses, all of which were logged on receipt, allocated a unique reference number and, where possible, acknowledged by e-mail or letter. These consisted of 856 e-forms direct from the link on the MCA web site; 684 items of correspondence, 310 e-mails, many with response pro-formas as attachments, and 9 by hand. Not all responses followed the suggested response format or directly addressed the seven questions asked in the consultation document, but where it was clear that the intention was to comment on the consultation proposals, these were included. Additionally, there were 63 requests for disclosure of information which were responded to under the Freedom of Information Act as well as a number of petitions received from local pressure groups and in response to local press campaigns.

The consultation exercise also generated a surge of Parliamentary Questions and correspondence from MPs and other interested parties. These were replied to either by Ministers, the MCA Chief Executive or other officials. This flow of correspondence pre-dates the consultation and continues beyond its closure.

The 1,859 consultation responses addressed all, or some, of the seven questions asked in the consultation document, plus any other comments they might wish to make. These responses were characterised in relation to 18 possible themes giving rise to a total of 17,273 individual items of data. These themes included “no comment” because not everyone addressed all questions.

26 ANNEX C

The Review Team

The Team Leader invited one officer from each of 4 RCCs earmarked for closure as per the consultation proposals and 4 from RCCs earmarked to remain open. Two officers representing Coastguard Sector Managers were also invited to join the team together with one officer from MCA Headquarters and one from MCA Training Centre. A further officer representing senior coastal management to act as Deputy Team Leader was also invited to join giving a team total of 13 Coastguard Officers.

The PCS provided a further 4 Coastguard Officers who acted in their capacity as PCS Representatives and played a full and active part in the review process.

One officer from a RCC earmarked for closure was unable to attend at short notice but, on a line manager recommendation, a replacement was recommended, albeit from a RCC earmarked for remaining open but this officer, in addition to his RCC experience, brought 39 years experience as a volunteer Coastguard Rescue Officer (CR0) to the team which gave added value to the team’s all round expertise.

The team comprised the following Officers —

Bob Banham, Non-Executive Director, Chair Kevin Brown, WM Aberdeen Peter Bullard, WM Falmouth Paul Cardell, Training Centre Hilary Durkan, SM Southampton Peter Dymond, Independent Review Team Leader Ian Graham, WO Belfast, PCS Equalities Officer Steve Huxley, SAR Communications Manager Val Jenkinson, SEC Vice President, PCS Rep Steve Jones, WM Swansea Dave Macbeth, WO Stornoway, PCS Rep Carey Mackinnon, WO Solent Steve Quinn, WM Aberdeen, PCS Rep Mark Rodaway, RCCM Portland Katherine Self, CWA Clyde Robert Teatheredge, WM Thames Sue Todd, CSM East SCOTNI, Deputy Team Leader Tony Tuton, RCCM Humber Wendy Wood, HQ CRS Team Anne Young, SM Dornoch

27 ANNEX 0

MODERNISATION OF HM COASTGUARD

REVIEWING THE RESPONSES TO THE CONSULTATION DOCUMENT “PROTECTING OUR SEAS AND SHORES IN THE 21ST CENTURY”

TERMS OF REFERENCE

The need for Assurance

The publication of the Coastguard modernisation document ‘Protecting our seas and shores in the st21 Century” on 16 December 2010 was the start of the formal consultation period concerning the proposals contained within the document. The consultation ends on 5 May 2011 and an independent in-house review team will be established to consider all responses and to examine any alternative proposals put forward weighed against the proposals in the consultation document to form a measured and rationally argued way forward.

This team will act fairly and without bias and will operate separately from the team responsible for the authorship of the consultation document.

The membership of this review team is based on the following criteria:

• That members have had no direct contribution to the concepts that underpin the modernisation proposals described in the consultation document;

• That members have a knowledge of the consultation document, the circumstances of its creation and the questions it asks (an initial presentation of the proposals will be provided to the review team by the consultation team who will also be available to provide detailed clarification on any specific points as required);

• That Coastguard technical members have a sound practical experience of having worked in the Coastguard organisation for at least 2 years;

• That non-Coastguard members have worked or been associated with the MCAfor at least 4 years;

• That members are drawn from a range of levels and geographical locations across the service. Governance

The team is to be appointed as a separate working team within the Consultation Programme Management structure reporting through a chairperson.

The nomination for chair will be approved by the MCA Executive Board. 28 The work of the team will be guided by a senior and experienced Coastguard Officer.

The team will also include representation, as necessary, from Finance and Governance, and HR. Attitude and Behaviours

Participation on the Review team is a position of trust that carries obligations and degrees of personal accountability.

There is a requirement for team members to act with considered impartiality and objectivity in assessing the arguments and weighing the evidence presented in the consultation responses, even accounting for the possibility that they may be personally affected by any findings.

Team members must be discreet before, during and after their involvement. It is unacceptable for members to represent any section or lobby during this undertaking or report back to colleagues and line managers or publish in any way any aspect of their participation.

Information used, processed and produced by the working team will be protectively marked as per HM Government guidelines. Members of the review team will be subject to the MCA’s Information Security Policy and will be subject to compliance with the Data Protection Act.

If candidates believe at any time, either before or during the Review, that they cannot conform to these professional standards of behaviour they should declare and excuse themselves from involvement without prejudice. Team members must abide by all current MCA rules including dignity at work and the Civil Service Code. Required Outputs

The Review Team is to produce a Report for the Programme Senior Responsible Officer (SRO) which contains the following:

• An overview of the responses received and their general characteristics;

• A summary of the views expressed in respect of each of the questions asked in the consultation document; and any other significant comments made or alternative approaches suggested, either in the form of individual responses or alternative plans suggested by various groups;

• Report the Review findings to SRO of the Consultation Programme and MCA Chief Executive. If there is disagreement within the Review team which cannot be resolved this should be documented and the recommendation made based on the judgement of the team’s chairperson. 29 The documentation of any unresolved disagreement should be annexed to the recommendation; there willbe no publication of ‘MinorityReports’.

Timing

The team will be established prior to the end of the consultation period (5 May 2011).

The existing consultation team will maintain a formal supplier/customer relationship with the Review team. It will provide the Review team with the following:

• a full contextual briefing on the proposals; • access to any background material and information used in preparation of the proposals; • access to all responses; • a full statistical analysis of all responses and respondees; and • access to specialist individuals who have contributed to the proposals, to provide further detail or explanation.

Separation of function will be maintained throughout the review process, the principal link being a neutral executive member of both teams who has had no direct input into the consultation document.

Team Members

Members of the review team will represent a spread of grades and geographical location and currently work in locations which are potentially affected in different ways by the proposals. It is anticipated that the PCS will be represented at all meetings of the Review Team.

30 Appendix to Annex D

Rationale for this approach

Quality assurance is generally outside the scope of PRINCE2 (Project Management Methodology) because it is the responsibility of the corporate or programme organisation in which a project sits. However, the PRINCE bible does say that it is good practice to arrange for quality assurance independent of the project management team. Also one of the senses in which the term ‘Quality Assurance’ is used is “the activity of reviewing a project’s organisation, processes and/or products to assess independently whether quality requirements are met”

Office of Government Commerce guidance on Managing SuccessfUl Programmes (MSP) defines ‘Quality Assurance’ as “An independent check that products willbe fit for purpose or meet requirements”

The Department for Business Innovation and Skills Code of Practice on Consultation

All responses (both written responses and those fed in through other channels such as discussion forums and public meetings) should be analysed carefully, using the expertise, experiences and views of respondents to develop a more effective and efficient policy. The focus should be on the evidence given by consultees to back up their arguments. Analysing consultation responses is primarily a qualitative rather than a quantitative exercise.

In order to ensure that responses are analysed correctly, it is important to understand who different bodies represent, and how the response has been pulled together, e.g. whether the views of members of a representative body were sought prior to drafting the response.

Consultation documents should, where possible, give an indication as to the likely timetable for further policy development. Should any significant changes in the timing arise, steps should be taken to communicate these to potential consultees.

Following a consultation exercise, the Government should provide a summary of who responded to the consultation exercise and a summary of the views expressed to each question. A summary of any other significant comments should also be provided. This feedback should normally set out what decisions have been taken in light of what was learnt from the consultation exercise. This information should normally be published before or alongside any further action, e.g. laying legislation before Parliament.

Those who have participated in a consultation exercise should normally be alerted to the publication of this information.

Consideration should be given to publishing the individual responses received to consultation exercises.

31 ANNEX E

TERMS OF REFERENCE

INTERNAL QUALITYAUDIT OF THE INDEPENDENT REVIEW OF RESPONSES TO THE FUTURE COASTGUARD CONSULTATION

Directorate(s): FINANCE & GOVERNANCE Director: SUE KETTERIDGE Audit objective

To provide assurance that the collection and review of the responses to the consultation document “Protecting Our Seas and Shores in the st21 Century” has been carried out in accordance with HM Government’s Code of Practice on Consultation, that all responses (both written responses and those fed in through other channels such as discussion forums and public meetings) have been taken into account and analysed, and that the resulting report and recommendations to the MCA Executive Board are an accurate reflection of those responses. Audit criteria

2. The criteria against which the process will be audited are:

• HM Government’s Code of Practice on Consultation • Response Review Team Terms of Reference • ISO 9001 :2008 Standard — Quality Management System Requirements. Audit scope

3. The audit will examine the MCA’s process for reviewing the responses received to the Coastguard modernisation document following the completion of the formal consultation period on 5 May 2011. This includes:

• The methodology used to examine and categorise responses • The composition and operation of the team undertaking the review of responses • The delivery of the required outputs from the review team’s terms of reference

32 Audit approach

4. The audit will be carried out in an objective and impartial manner, through discussion with key contacts, examination of relevant documents and files, and by sampling the responses received to ensure they have been accurately recorded.

5. Any emerging findings will be discussed with management during the audit. At the end of fieldwork, a closing meeting will be held to present findings, confirm factual accuracy and agree corrective actions. Following this meeting, a draft report will be issued for final comments prior to issuing the final report.

6. The proposed timetable of events is:

Opening Meeting Start of fieldwork: th16 May 2011 Completion of fieldwork: Depend ant on review timescale Closing meeting held: tbc Draft report issued: [10 working days after closing meeting] Auditee response: [10 working days after draft report issue] Final report issued: [5 working days after auditee response]

9. The audit team consists of:

Lead Auditor: Steve Horn, Lead Auditor, CG&R Auditor(s): Yvonne Whitworth, Lead Auditor, CG&R

10. Key Contacts:

Bob Banham Non-Executive Director and Chair of Review Panel Peter Dymond Review Team Manager Andrew Austin- Head of Research & Planning Hancock

NB: The planning, scope, approach and timetable set out in these terms of reference may change in the light of preliminary findings. Any significant changes will be discussed with the Director of Finance & Governance and key contacts as appropriate.

Steve Horn Technical Risk Assurance Lead Auditor Corporate Governance & Risk

33 ANNEX F

INTERNAL QUALITY AUDIT OF THE INDEPENDENT REVIEW OF RESPONSES TO THE FUTURE COASTGUARD CONSULTATION

The reporting and analysis of the responses to the consultation document “Protecting Our Seas and Shores in the 2jst Century” was audited by an independent team, comprising ISO 9001:2008 lead auditors from the MCA’s Corporate Governance and Risk Division. The purpose of the audit was to ensure that the review and analysis of responses was carried out in accordance with HM Government’s Code of Practice on Consultation, that all responses (both written responses and those fed in through other channels such as discussion forums and public meetings) were taken into account and analysed, and that the resulting report to the MCA Chief Executive was an accurate reflection of those responses.

Terms of reference for the audit were agreed with the independent chair ahead of the review process.

The audit included observation of the team undertaking the analysis of the responses, discussion with key contacts, and 10% sampling of the responses received through the data capture and analysis tool.

The audit team are able to give the following assurance:

1. The composition and operation of the Review Team met the requirements for independence and impartiality, and the analysis and discussion of responses was undertaken objectively.

2. The methodology used to capture, examine and categorise responses, was robust and ensured that all responses were considered.

3. The resultant Report is a fair and accurate representation of the views expressed through the consultation process, and meets the required outputs from the terms of reference,

Steve Horn Technical Risk Assurance Lead Auditor Corporate Governance & Risk Maritime & Coastguard Agency

34 ANNEX G Consultation Questions

QI. Chapter 1. We have set out the changes that would affect the way the Coastguard needs to operate. Are there any other changes and pressures that should be taken into account in our plans for a modernised Coastguard service? Please provide supporting evidence for your comments.

Q2. Chapter 2. We have explained the current Coastguard structure and the potential weakness in that structure in the face of increasing demand. Are there other strengths or weaknesses in the current arrangements that we should be taking into account? Please provide supporting reasons for your comments.

Q3. Chapter 3. Under our proposals we would establish two Maritime Operations Centres handling emergency messages 24 hours a day, supported by a number of sub-centres operating at times of peak demand linked by a national network of radio connections and information sources. In your view, does this provide an appropriate and effective approach to Search and Rescue coordination response? Please provide supporting reasons for your comments.

Q4. Chapter 4. Our proposals for Maritime Operations Centres and sub-centres locates these around the UK coastline and makes use of the MCA current estate. Do you agree with the proposals for the location of these Centres and sub- centres? Please provide supporting reasons for your comments.

Q5. Chapter 4. In your view, are the new roles and responsibilities for Coastguard officers at different levels in the proposed structure appropriate to the tasks that need to be delivered? Please provide supporting reasons for your comments.

Q6. Chapter 5. Under these proposals the regular Coastguard working in Maritime Operations Centres and sub-centres will draw more heavily on the local knowledge of geography, community and coastal risk provided by the network of local volunteer HM Coastguard Rescue Teams and increased liaison with partner SAR organisations. Do you agree that this is the best way to ensure the availability of such knowledge? Please provide supporting reasons for your statement.

Q7. Chapter 5. In your opinion, will the proposed strengthening of management for the Coastguard Rescue Service organisation, including the introduction of 24/7 on-call Coastal Safety Officers, provide a more resilient response service to those in need in UK coastal areas? Please provide supporting reasons for your comments.

The consultation Document also invited respondees to provide comments on the proposed modernisation which were not covered by the above questions.

35 ANNEX H Characterisation Descriptors

LK: Knowledge of the local area, knowledge of local place names, knowledge of local anomalies and environment. Situational awareness.

LI: Local Intelligence: Knowledge of resources and useful contacts; their capabilities and limitations. Dynamic information which is known about locally but not further afield.

LN: Language - Local dialects, language and pronunciation.

LE: Local resilience planning. Maintaining SAR Partner and stakeholder relationships.

ConOps: Anticipated concept of operations, (e.g. working practices between MOC and sub-centres), roles and operational procedures. Selection of centres and hours of operation.

Corn: Complexity — Periods of high incident workload versus fewer but equally resource intensive, complex individual incidents

Eco: Economy - Impact on jobs, tourism and the local economy

Res: Resourcing - Comments about resourcing; retention of sufficient experienced staff and impact on training and leave.

Peps: People - Watch patterns, terms and conditions, overtime, relocation and redundancy policy.

CRS: Comments regarding the reliance on, or additional tasks expected of, the volunteer Coastguard Rescue Service. Comments on proposed new Sector Organisation; on scene co-ordination of dry’ incidents.

Tech: Technology - Comments about future technical resilience and reliability, networking arrangements or existing systems.

Info: Information - Comments about the lack of information or detail in the consultation document.

Mis: Misunderstanding - Comments which indicate a lack of understanding of the role, organisation, capability and communications of the Coastguard or how the proposals relate to the operations room staff.

Amb: Ambiguous - The response does not address the question.

NoCo: No comment — no response to a question. 36 OC: Operational communications between MOC and sub centres. How will the communication work, how will telephone calls be handled and transferred, how will radio traffic received at one site be passed to the other. How will MOCs and sub Centres communicate with CRS and other resources.

Rec: Comments regarding the effect of the proposals on non—SOLAS recreational craft and other leisure activities as opposed to larger commercial vessels.

Cost: Comments on costs; where costs can be saved.

37

ANNEX I Summary of alternative proposals

Clyde MDC South Establishing a single Forth (Soton/Portsmouth) national network Shetland or MDC North strategically Stomoway (Aberdeen) controlled by Belfast or Liverpool Dover Maritime Operations Holyhead Falmouth (Day only) Centres. Milford Haven Swansea (Day only) Brixham Humber (Day only) Deployment of a Consultation Thames Shetland or workforce matching - Protecting Yarmouth Stornoway (Day only) Consultation seasonal and 248 105 17 9 Y Y National Yes National our Seas and 370 Portland Belfast or Liverpool Proposals diurnal workloads. Shores in the Solent (Day only) 21st Century London Higher skilled and therefore higher paid Coastguards.

Enhanced operational leadership in the Coastguard Rescue Service.

Brixham plus one Stornoway Geographic spread centre from each of Shetland of centres. the existing pairs of London (24 hour) centres except that Falmouth A more realistic Stornoway and alternative based on Shetland remain The remaining half to staff retention and expertise. A Safer open. remain open. Would Consultation also be 24 hour. Y N Territorial Yes National Future - 460 338 102 17 11 Proposals Falmouth 24 Hour centres resulting in more resilience.

Falmouth reason being their unique international expertise.

39 Clyde NMOC Southampton Devolved Forth Aberdeen (MRCC) administrations will Yarmouth Swansea (MRCC) be well served. Thames Humber (MRCC) Solent (see NMOC) Belfast (MRCC) This proposal could Portland Dover (MRCC) be implemented Brixham earlier than MCA Milford Haven London (MRSC) approval. Holyhead Shetland (MRSC) Stornoway (MRSC) Better retention of Liverpool (MRSC) existing Falmouth (MRSC) staff/expertise. Belfast, Not Not Not Not Consultation Improved career Humber and 318 11 Y Y Hybrid National stated stated stated Stated Proposals progression. Swansea Increased training and higher standards.

Two additional centres selected to increase MCA presence/local liaison.

Desire for all remaining centres to be 24/7.

4 centres but not A new Highcliffe Minimum change named. Coastguard. possible with Solent and Portland minimum disruption. combined. Not New Not Not Not Stornoway, Shetland, Y N Territorial Yes Alternative RAP Plan 15 Grouping stated stated stated stated London, Dover, Falmouth plus 9 others which were not mentioned but 24hr centres.

40 Yarmouth MOC North at As the 3rd busiest Brixham Aberdeen centre in the UK the Holyhead MOC South author believes Milford Haven Humber Thames should be Forthh/Clyde/Shetla Dover retained as a day nd/Stornoway London centre. This is Not Not Not Not Solent Thames Not supported by Why Thames 10 N Y Hybrid Yes Not Stated stated stated stated stated Portland Falmouth Stated information on the Brixham Swansea Sunk VTS, Ship to Liverpool or Belfast Liverpool or Belfast Ship Stornoway or Transfers, Shetland Anchorage, density of shipping and large numbers of recreational craft

Shetland Stomoway Keeping Stomoway Forth Aberdeen (or new NE open. Clyde Scotland build) Belfast or Liverpool Belfast or Liverpool Reducing travel viz Holyhead Humber a viz Swansea Southampton/Portsm training/meetings Milford Haven outh new build therefore ACasefor6 Not Not Falmouth Dover Not New cost saving. 24hr Stations 243 6 NN Territorial Not Stated stated stated stated Brixham Stated Grouping in the UK Portland MOC Concept Solent flawed. Yarmouth Thames

Not specified. But Not specified. But one Need for retention one centre to be centre to be retained of centre in the NW Protecting retained in the NW in the NW & NW area & NW Area. our Maritime & NW area. New 417 278 120 19 10 N N Hybrid Yes Alternative and Coastal Grouping Lack of resilience in Environment current proposal. Dissolution of MCA Regions.

41 Shetland Aberdeen An evolutionary Forth Southern MOC approach to the Yarmouth Stornoway MCA proposal in Thames Belfast order to mitigate key Solent Humber risks and increase Portland Falmouth staff support. Brixham Dover Swansea Wales Controlled transition Aberdeen Not Not Not 370 Holyhead London Y N Hybrid Yes National Alternative period over 5 years. Coastguard Stated Stated Stated Liverpool Clyde All 24/7 Maintenance of national 24/7 Highcliffe approach to reduce the majority of risks within the current MCA proposal for MOC operational infrastwcture.

Not stated Not stated Retain regional resilience and Alternative concept of Organisation operations. al Structure Not Approx Not Not New Consultation 270 10 N N Territorial of HM stated 90 stated Stated Grouping Proposals Improves career

Coastguard - opportunities. Plan B Strengthen regional resilience and training.

42 Not stated Not stated Retain area concept with one MRCC Close one of each Retain one of each from each existing existing pair of pair including pair. centres except Stornoway and Stornoway/Shetland Shetland and pass of Networked MRCCs which should London CG to the allowing full national remain open. PLA. resilience le no MDC.

Resilience is Retention of more Not experienced staff - Not Not Futile An Not Not 10 N N Temtonal National No tStated Alternative stated stated stated stated Stated providing greater Proposal resilience and retaining local knowledge.

Senior officers would not be required to work shifts.

No options provided in the MCA orooosal.

Not stated Not stated Retain local knowledge Future of the expertise and Fifteen not named Not Coastguard - Not Not Not Not N N Territorial National Alternative increased 15 except London Stated Alternative stated stated stated stated resilience. Proposal Removal of SM5 and CWA grade.

Not stated Not stated but 24/7 for Cost savings Consultation Response to Not Not Not Not 9 or those remaining open N Y Territorial Yes National through less people, Consultation stated stated stated stated 1 1 Proposals less centres, better rewards.

43 Clyde Belfast Resilience. Aberdeen Stornoway Yarmouth Shetland Cost cutting by Thames Forth retention and use of Holyhead Humber MCA Estate and not Brixham Swansea build new. Portland Liverpool An individual Not Not Not Milford Haven London New Consultation Retention of 24/7 member of 250 NN Territorial Stated Stated Stated Dover Stated Grouping Proposals centres. MCA staff Solent Falmouth Preservation of job satisfaction of CG All 24/7 Officers.

Keeping it local.

Swansea One national business As little change as All Regional unit ie no Regions possible to the Business Units existing system. Holyhead Highcl life Clyde Liverpool Solent Brixham Portland Falmouth A Possible Milford Not Not Not Not New Future of HM 13 Belfast Y N Territorial Alternative Stated Stated Stated Stated Stated Grouping Coastguard Stornoway Shetland Aberdeen Humber Thames London Dover

Not stated - but London 24/7 centres. An geographical Dover Not Not New Alternative 314 78 11 spread Plus 7 Others all 2417 N N Hybrid Yes Alternative Resilience. stated stated Grouping Proposal Plus 2 “MO Cs” Increased pay levels.

44 Portland Solent Less risk, low cost Brixham Falmouth proposal to maintain Milford Haven Swansea 24/7 cover at a Liverpool Holyhead National Network of Clyde Belfast MRCCs with An individual Not Not Not Forth Aberdeen enhanced duties, member of 376 9 N N Territorial Yes National Alternative Stated Stated Stated Thames Dover but no MOCs within MCA staff Humber Shetland UKSRR. London Stornoway Training Centre All 24/7

Not stated 3 in Scotland ie Minimum change Shetland, Stornoway but some and Aberdeen modernisation.

MRCC 2 on East Coast of The national Not Not England Not network would be in Shetland and Not Not 13 Y N Territorial National Altemative MRCC Stated Stated Stated Stated Stated support of the Stornoway Belfast and London MRCCs not a replacement. 3 Wales and West

3 in South which . includes Dover

Nil 19 Status quo taking advantage of current technology Not Not Not Current upgrades. MRCC Not 19 N N Territorial Yes Current Holyhead Stated Stated Stated Stated Pairing Additional cost savings identified by employing staff more efficiently.

45 Not stated Not stated Expand MCA responsibilities to Up to 5 Minimum of 14 to cover air/land and include Stomoway, Maritime SAR and Shetland. London, to include additional Dover and Falmouth surveillance, security and Combine Portland, enforcement

Solent and MCA HQ - functions. All remaining centres 24/7 Disband Regions.

Give ownership and responsibility to people at the front end.

Those involved in development of the consultation proposal should not have any involvement in the determination of the

London Dover Optimum team size Liverpool Solent to deliver efficient Brixham Falmouth service. Portland Swansea Milford Haven Belfast A more staged Holyhead Stornoway approach to change Clyde Aberdeen to ensure resilience. Shetland Humber Forth Thames All 24/7 Yarmouth

46 Not stated Dover (24/7) Enhance what Southern (24/7) structure already Falmouth (24/7) exists with minimum Swansea (24/7) change. NW Irish Sea ie Liverpool, Clyde or Belfast) (2417) Aberdeen (24/7) The Middle Not Not Not Not New 252 11 Humber (24/7) N N Territorial Current Way Stated Stated Stated Stated Grouping Brixham or Portland (day centre) 2 Scottish Day stations Thames or Yarmouth (day centre)

Not stated Not stated 2417. An individual Not Not New member of 360 78 13 London plus 10 others N N Hybrid Yes Alternative Resilience. Stated Stated Grouping MCA staff plus 2 MOCS Increased pay levels.

47 Forth Stornoway Retain MRCC Yarmouth Shetland Clyde. Portland Aberdeen Solent Humber UKto have Bnxham Liverpool recognised MOC. Milford Haven Thames Holyhead Belfast Each devolved Dover administration to Clyde have MRCC. MOC Southampton Falmouth Even distribution of London workload. Not Not Not Swansea New Consultation MRCC Clyde 292 13 NN Territorial Yes Stated Stated Stated Grouping Proposals Vulnerability of telecom systems to Scottish Island centres. International work to be carried out at MOC.

London CC linked to MOC.

Wrong criteria chosen for MOC location selection.

Not stated Not stated but 24/7 Retain frontline staff.

Reduce non- operational roles. 350- Not Not New Liverpool Not N N Territorial Yes Alternative 15 Grouping Coastguard Stated 490 Stated Stated Greater resilience.

Efficiency Savings and opportunities for income generation.

48 49 ANNEXJ Common themes of concern by group of respondent

•0 8 a, S 0 9

-9 -

C -E , :,

.a,, a, C ö o - 4 o o — .5 >, C - >. — .-.a, a, —

-a- Small to Medium Enterprise (up to 50 employees) 117 60 33 24 116 13 17 39 28 36 42 12 30 67 10 30 39 713 4% Large Company 55 22 6 49 67 14 16 27 14 24 29 20 13 33 6 7 17 419 2% Representative Organisation 164 75 34 58 194 21 20 69 32 73 106 47 41 75 19 65 52 1145 7% Trade Union 20 3 5 8 2 3 3 5 4 17 0 3 5 82 05% Interest Group 106 39 23 21 78 8 10 34 23 33 33 17 31 55 11 22 24 568 3% Local Government 224 114 34 91 215 27 65 61 35 62 125 45 40 44 19 56 69 1326 8% Central Government 76 42 18 53 71 7 25 35 29 31 31 14 16 8 10 23 23 512 3%

Other Emergency Service (Police/FirelAmbulance) 59 34 15 76 83 9 9 31 9 26 26 13 8 28 7 2 10 445 3%

Member of MCA Staff 255 146 45 144 365 52 42 236 222 163 222 92 27 58 60 80 105 2314 13% Member of a Coastguard Rescue Service 70 45 20 28 77 9 6 57 31 77 51 10 17 33 15 14 17 577 3% Member of the Public 1463 632 332 371 1304 144 263 455 272 415 530 151 362 766 108 372 451 8391 49% Other 106 57 14 50 89 6 14 51 20 36 38 14 31 50 15 22 26 639 4% None Shown 24 5 9 7 27 4 4 12 11 5 19 6 2 2 3 142 1%

Totals 2739 1274 584 977 2694 315 492 1109 729 984 1257 445 634 1219 282 698 841 17273 100% 16% 7% 3% 6% 16% 2% 3% 6% 4% 6% 7% 3% 4% 7% 2% 4% 5% 100%

Where interest in single subject is greater than 5% of total interest in all subjects

The matrix shows the majority interest for members of the public was Local Knowledge/Local Intelligence and Concept of Operations, with a significant instance of Ambiguous comments. For members of staff the Concept of Operations was a common theme, as was Local Knowledge, Resourcing, People Issues and Technology.

50 ANNEX K RISKS AND CONCERNS LOG

Risks and Concerns - Operations . .. - Cost cutting exercise that is neither value for money nor values a life;

Deterioration in Search & Rescue (SAR) response - loss of local knowledge leading to delays in, or inappropriate, tasking; complexity of on-scene co-ordination and CRT/RCC/MOC relationship leading to breakdown in process; fragmented command, control and co-ordination; distance to travel for Coastal Safety Officer ifrequired to attend coastal incident could lead to delay in on scene supervision. Transition from proven territorial concept of operations to unproven national version. Proposals are commercial shipping centric and do not address challenges of non Solas vessels <300gt/coastal and recreational users who may not have the on board technologies referred to in the consultation document. Potential deterioration in SAR performance generally due to combined effects of modernisation proposals together with loss or reductions in MIRG, ETV, Nimrod, SARH. Potential inferior operational interlace between MOC/RSC and CRS/SAR Partners. Not enough Maritime Operations Centres. Over reliance on Coastguard Rescue Service - volunteers only; high demands already made on them; new roles requiring additional training; effects on employers and families; inconsistent local knowledge. Reduced number of RCCs leading to loss of local knowledge. The reduction in number of RCCs operational at night with some daytime only centres - inabilityto deal with the 30% of incidents that happen after 1900; - the creation of a two tier structure ie MOCs and daytime sub centres - worsening of skills fade; - handover between MDC and daytime sub centres. Before transition from current to new proposed structure, the concept of operations, associated processes and the technology need to be proven. Weakened relationships with Devolved Administrations, Local Govt. & CivilResilience partners. -, 4,J That non-SAR tasks, support to wider emergency response and the forecast increase in maritime activity and incidents (as predicted by the consultation document) not taken into account when establishing staff numbers. Any deterioration in SAR response could increase the potential for prosecutions under Corporate and Personal liabilitylegislation. Current training for Coastguards and Coastguard Rescue Service Volunteers not adequate for new proposals. Development of proposal/consultation process has not engaged staff/stakeholders appropriately. Experienced staff unwilling/unable to relocate because of family commitments in current location or high cost of living in MOC/RSC areas. Health and Safety of coastal fulltime and volunteer Coastguards - lone working; lack of team support; lack of appropriate technology. Inabilityto effectively recruit and/or retain fulltime and volunteer Coastguards for reasons already stated within this risk log. Insufficient admin support. Lack of staffing resilience/flexible hours - inability tofield senior staff in major incidents. Reduction in workforce morale. Adding a bureaucratic layer of management to CRS management when support at the base layer is more important.

51 Risks and Concerns - Other increased burden on Industry and AF< i-’artners. Loss of reputation if proposals fail. MOCs/SCs remote from communities, stakeholders and incidents. Modernisation effects result in operational targets not met. Fewer collection points available for Time Expired Pyrotechnics. This is a cost cutting exercise providing neither value for Money nor valuing human life. Inabilityto deal with the challenge posed by the Offshore Oil, Gas & Renewable Energy industries.

52 ______

ANNEX L IDEAS LOG

- Maritime Operations Centre (MOC) Configuration Ideas

1 MOC only 2 MOCs appear sufficient, why so many sub centres 2 MOOS is “alleggs in one basket” 4 MOOs Aberdeen, Humber Solent and Liverpool - 5 Sub centres Falmouth, Swansea, Belfast, Stornoway and Shetland - 24hr at Dover, London and Thames. 4 MOOs linked plus sub centres parented by a MOO

3 MOOs - 1 in Scotland, England and Wales - with evenly spread sub-centres 3 MOOs Aberdeen, Falmouth and Dover 3 MOOs for greater resilience 3 MOOs including Falmouth 4 MOOs including Falmouth 2 MOOs but linked together and into a national network of 24/7 centres. 2 MOOs plus 24/7 sub-centres A MOO should be based near Felixstowe due to: Largest container port in Europe, Levels of commercial leisure activity Agree to MOO concept - subject to technological support (suggest purchase of “offthe shelf” not state of the art) and backed up with a clear redundancy programme that allows for a retention of experience. Alternative proposal to place Southern MOO at Falmouth. Central belt MOOto allow fulltraining facilities, therefore allowing cost saving as trainers can attend one big station negating the need for training centre Consider use of RNAS Ouldrose as a future MOOifexpansion of Falmouth not possible Oonsult locally forMOC/Sub-Oentre location Dover as 3rd MOOto increase resilience Dover or Brixham as 3rd MOO - already meet building criteria Establish 3 MOOs to cater for East and South Coast (No mention of west coast). Other stations to run as day stations thus installing confidence and support within local communities Establish a MOO at Dover with sub centres at Swansea, Falmouth, Lee on Solent and Humber. MOOat Aberdeen with Northern centres as proposed Establish two MOOs and a number local sub centres using modern info technology intelligently Introduce a 3rd MOOfor greater resilience - Clyde due to location. Irish Administration proposal for 2 MOO concept currently in place in Dublin to be investigated Locate a MOO in Wales Locate a MOO in Wales (plus one other sub-centre) Locate MOO in area of Portsdown Hill(Crown Estates property) to provide greater resilience against natural disasters Locate MOO South at Swansea due to: Travel Links (Airport, M4 and Rail), existing building can be modified, substantial Maritime Risks in Wales and 24/7 MOOwould compliment Welsh Government functions Locate MOO South further North and more central eg Leeds Locate MOOs in less expensive areas Locate the MOOat Weymouth MOO should be established at Daedalus MOO South - New Build Southampton - Remaining stations carrying on in existing locations MOO South at Dover Move from pairing stations to triples (9 plus 3 MOOs) Northern MOOto be moved to the central belt to allow better access to government departments (national and devolved) and with better transport links Proposal for 2 MOOs only in NW UKSAR area. Clyde and Crosby and two additional sub centres in Northern Ireland and North Wales 53 Maritime Operations Centre (MOC)Configuration Ideas Proposal for Swansea to become a MOC rather than Solent Propose 2 MOOs for Scotland (No comment on other areas) Propose 2 MOOs plus more sub centres Propose 3 x24/7 sites (Aberdeen, Dover and Falmouth) Propose 4 main centres - Falmouth, Liverpool or Holyhead, Stornoway, Humber (Hull). Users would be less than 400 miles from a centre - Redundancy for failure Propose 4 MOCs - Scotland (1) England East, West and South. Each MOC supported by two sub centres working 12 hour days Propose 4 MOCS - North, South, East and West Propose 4 MOOS - North, South, East and West. Supported by geographically strategic sub centres (Falmouth, So’ton, Aberdeen, Belfast or Liverpool) Propose an alternative MOOsite at Weymouth Propose Liverpool as MOO, based on freehold property and co-located property ropose the establishment of 7 MOOs geographically distributed and interconnected - Suggested ites - Shetland, Stornoway, Belfast, Falmouth, Dover, Humber, Aberdeen Reduce the tactically and strategically unnatural division of SAR from Oounter Pollution by including the latter expertise in the MOOs Respondent questions the need to incur the additional costs in building a new MOO in the south. Suggests utilizingan established station and to introduce the technology to that station Retain Aberdeen as a MOO Retain Clyde as Northern MOO Set up Area specific desks in MOOs to help with local knowledge and to alternate staff as required. MOO (Open 24/7) in each MOAregion MOOto act as back up to ROOs. Site MOOs inland to save money SOSREP, Deputy SOSREP and the Oounter Pollution team to be based at a MOO. Staff in MOOs should rotate between working in MOOs and on the coast to increase their own local knowledge. Minilocal stations should be set up withinthe MOOs Support for proposal but more sub-centres required Three MOOs - Southampton, Falmouth and Stornoway/Orkney subject to transitional risks Triangular MOOarrangement - Aberdeen, Dover, Brixham Two MOOsmay be sufficient but include Falmouth because of expertise covering responses deep into the Atlantic. Two MOOsone located at MROOFalmouth Two MOOs Southern one located at Falmouth. Aberdeen and Dover should also be retained Weymouth and Portland council suggest a number of sites in their area for a future Southern MOO.Also arguing that it is a major centre of Maritime activity Oombine Solent/Portland or a MOO at Spring Place HQ Suggest I MOOgiving support to 9 24/7 stations and London. (Including one in each devolved admin) Ensure MROO/MOOis retained in NW England to ensure cover in Eastern Irish Sea I MOO in Southampton: MROOClyde - has MOAenquired about future of Navy buildings with DIO (Defence Infrastructure Organisation) locate Scottish MOOin central belt alongside Police and Fire minimum requirements for MOOshould be 3 MOOwould operate as an MROO

54 Other Configuration Ideas

24/7 centres give staff fairer recruitment and progression opportunities. They retain and develop local knowledge and expertise. They should sustain/develop links with civilcontingency groups, creates strong links between MRCCs and Local CRS 4 South coast stations - Dover, Solent, Brixham, Falmouth due to volume of maritime activity. Better connections would enable a reduction in staff numbers 7 x 24/7 Centres 9 Networked 24/7 centres (to reduce risk of daytime/night time non face to face handovers) 9 or 10 Stations - Linked to either side flank station A more evenly distributed spread of 24/7 RCCs and personnel across a wider network to provide a more resilient structure. A multi linked station approach by upgrading the networks of existing centres would have increased resilience A network with more connected nodes would be more resilient to failure A suggestion for a proposed single command and control platform encompassing all areas of the proposal After RER project, stations willbe linked sufficiently providing greater interoperability Agreed to centralised 999 call centre but localised geographical co-ordination All 18 current station should be linked Alternative sites for Portland - Southwell Business Park (Defence Research Agency former site) Close one RCC in each current pair leaving 9 networked centres plus London. Amalgamate Clyde, Forth and Aberdeen into one super station in the central belt Beneficial to have the higher grade roles available on an on-call 24/7 to assist multi-agency partners with their specialist knowledge outside sub-centre hours. Preference for all sub-centres to be 24/7 Bottom up approach. Ifroles are changing locations could be out of physical proximityto the sea. Call centre in India Choices should be Falmouth vs. Swansea and Falmouth vs. Dover rather than choosing between stations which are so far apart Combine some centres to cover the south coast Establish 18 (or thereabouts) networked centres without the need to build, equip and staff the new MOCs. Such a system would be highly resilient and flexible Existing sub-centres to be maintained Fewer but all 24hr Centres more robustly linked to each other. Begin with current 18 MRCCs and integrate less busy into more busy gradually to reduce risk of losing experience Fewer stations but each being 24 hour stations to provide the local knowledge Given better networking of existing sites, staff could be (and should be ) distributed among existing sites Group Stations in threes Have on-call response staff to man up MRCCs 24/7 Ifrisk and demand are increasing then number of stations should be increased not reduced Improve Connections between existing stations Interlock current stations to provide better resilience Keep all sub centres to retain coordination of local incidents Keep Belfast 24 hr cover due to increased activity regarding oil exploratrion offAntrim coast Link Existing stations Linking of existing MRCCs using more modern technology to improve communication eg. Given as www Local incidents should be dealt with bylocal centres and passed to national centres for major incidents London can be closed and subsumed by Thames and Dover London CG to close and duties transferred to MOC London should be a tide based service (?). Humber should be a 24/7. Dover functions (CNIS) moved to Southampton Maintain and enhance existing service

55 ______

Other Configuration Ideas Maintain current infrastructure, but flexible manning at night Maintain MRCC Status Quo Make use of existing estate and explore more opportunities to share/use other government premises Minimum 3 24/7 stations, prefer one at Falmouth More 24 hour centres More sites required in the south of England More stations required than mentioned in Consultation Document Networking and backing up whilst maintaining local touch No Need for sub-centres Oil and gas industry submission proposes that all oil and gas incidents handled out of Aberdeen Plymouth or Cornwall for Southern MOC as seafaring communities. Ideas are sound but locations not justified Alternative to MOC/Sub Centres. Continue to reduce the number of stations without MOCs however upgrade technology at remaining stations. Cost savings - No MOC South to build, less relocation costs, less redundancy payouts, do away with the need to introduce CSO’s to manage CRS. Proposing sites at Glasgow, Liverpool, MilfordHaven, Falmouth, Folkestone, London, Hull,Newcastle, Leith and Shetland plus sub centres Reduce manning at current centres to two during night hours, supported by your two proposed Maritime Operations Centres Reduce no of stations from 2 MOCs plus 5 to 5 x24/7 stations The Team Leader profile indicates that they would be responsible for a geographic area. Why not forgo the cost of establishing a MOC and leave team leaders with existing stations i.e. within the area for which their geographical expertise exists Centralisation of HMCG is the wrong way to go and further suggests that the Coastguard should be regionalised Retain all 18 RCCs but linked together: MOCs no longer required as there willbe genuine national cover (resilience) by local knowledge trained staff with suitable backup Retain one station in Northern Ireland, in Scotland, Two in Wales, five in England (Including Dover and Falmouth) all on 24hr basis Retain Stornoway, Shetland, Belfast, Liverpool. Locate MOC in Northern Ireland. Aberdeen as a sub- Centre Scotland coastline needs four coastguard stations Scrap the MOC concept and replace with many local stations with a hub capability to coordinate on a UK wide basis Skeleton cover at sub-centres during night periods to provide localised support Rescue Sub Centres should be 24/7. Suggestion of at least one daytime centre in each of the government regions so that it could be activated to work autonomously in the case of a national disaster or on a 24hr basis as and when required in the event of a local emergency The only way to meet increased demand from the maritime sector is to increase our capabilities by increasing manpower to cope with the increased demand utilizingthe current system Upgrade technology to linkall establishments and keep more open 24/7 - better for resilience Vast majority of current stations remain open as day stations 08:00-20:00 with 3 or 4 open as 24hr stations - all stations linked Co-locate Solent and Portland at Highcliffe Use of dual kilostreams to linkto pair and one other station for resilience 12 MRCCs 24/7 and structure politicallyacceptable structure Second communications hub at Belfast i.e. geographically dispersed and not on mainland UK Locate main IT hub within a militarysite to minimise security concerns Retain CNIS/Offshore specialists, put at HQ Reduce number of MRCCs but link remaining MRCCS better

56 Wind-down of closure stations to be phased down to daylight only hours then closure That MRCCs consider whether they could become day only stations Retain at least 9 24/7 MRCCs fullyintegrated (excluding London) Retain International SAR at Falmouth Aberdeen to front interface with oil and gas

Coast Rescue Ideas

Better education of what we do - joint local training arranged via CSO. Enforced and regular safety patrols Coastguard vehicles need equipping the same as the ambulance service etc. Including sat nay, pda. In order to automate communications between CRS and MOC Consideration should be given to employing additional Sector Manager assistants in some Sectors at lower cost and avoiding need to re-align sectors CRS to be equipped with Airwave and operate/adopt local standard operating procedures for interoperability and co-ordinating Agencies on scene Each CRT to maintain a database recording incidents, trends, agencies involved, contacts etc. Building up to an effective local knowledge source Improved coastal resilience could be achieved by careful analysis of incident patterns with targeted resources and a reduction of CRS teams mitigated by air mobile response Technology to be supplied to CRS to facilitate data transfer with MOC/RSC, tasking and on scene coordination, improved communications and access to intranet. Instead of creating another level of coastal “management” it is suggested that assistant sector managers be created to strengthen the CRS organisation Introducing new role below CSOs to take on more routine duties More coordination could be provided by Coastal Officers - Providing technology sufficient More mobile units to create more mobile structure More use of IRTs to provide local intelligence Regular fulltime staff and Auxiliaries because a more complete service. Current disparity could be a future risk Introduce 3 tier CRS Management structure. Assistant Sector Manager (ACSO), Sector Manager (SCO) and Senior Sector Manager (SCSO). Responsibilities and roles given in consultation document need more detail A ‘bottom up” review of the entire CRS to determine size, shape, roles and organisation. Devolve more responsibility to the station officer and CRT members. Examples - Training, Admin etc. This would harness the talents and initiatives of the teams and empower the local communities in line with the government concept of the ‘Big Society” Use the RNLIas a model to base CRS organisation with regard to equipment, training and numbers of personnel Retain Status Quo for the Coastguard Rescue Service. Support for strengthened Coastal Organisation The Coastguard Rescue Service should be passed to the RNLIand cost savings made invested in the existing MRCC network The CRS should be charity funded along the lines of the RNLI To make the proposed concept work, volunteers would require comprehensive training in basic SAR theory and co-ordination. Transfer/Handover of CRS Volunteers to RNLI. SAT phones for remote area teams Centralise management of CRS CRTs should be paid a retained wage Retain all 9 CSM Posts to ensure effective management of CRS (3x RD post to fund 9 CSMS managing 2x Team leaders) Increase CRS training budget 57 PmaIgamate with F, .Ll and fund it centrally Amalgamate HMCG with the US Navy as they are the best - Closer integration at all levels of training, operations and technology with Fire Service Co-locate MRCC at RAE Valley to incorporate SAR Force HQ and consider creating a JRCC following closure of ARCC in 2013 Cost savings in sharing buildings and technologies International cooperation, interoperability and load sharing in the future Joint Channel Agency - Joint control with the French Link up with National Coastwatch Institution (NCI) MCAshould devolve authority to local organisations like the National Coastwatch Institution (NCI) Standalone organisation for the Coastguard Combine or work more integrally with other public bodies such as Borders Agency, HMR&C,Police, Fisheries to form a fully integrated UKmaritime organisation. Consider CG sub offices in the Admiralty/RN bases

Additional Workstreams and Revenue Generation Ideas HMCGto provide Joint Rescue Co-ordination Centre (JRCC) for UK Encourage young people to have a career at sea and make more money from exam fees HMCGto take on role of UKMCC Greater involvement of CG in dealing inland flood and other natural disasters. Combined with British Waterways and HMRC Invest Money in MCAestate rather than leasing and extending leases on other property (Cost saving in the long term). Legislate/Regulate small craft and leisure users Public to pay for SAR HMCGto add incidentlaccident reduction to its core business. Introduce solar panels and wind turbines on all coastguard buildings as a way of cutting costs or indeed generating income with an objective of becoming self sufficient Run Shetland Ops centre funded by Shetland Charitable Trust To search for funding via increasing activities from renewable sea based turbine projects - Funding Streams MCAto develop our own flood response to capitalise on specialised co-ordination capabilities With CG Communications we are better placed than other organisations to assist future security requirements HMCG should take responsibility for Land SAR Selling property could help fund modernisation, for example Highcliffe Seek cheaper estates when leases expire Make use of owned estate for longer term cost savings/business continuity Introduction of more duties ie VTMetc

MOC to take on CivilSAR (aviation , licensing leisure sector including inland waterways inland mountain SAR and medical transfers Charge for TEP intakes charge for expertise and training and investigate other avenues of potential revenue Sell Daedalus Income and savings made by lease or rent of surplus buildings/vacated office space. Sell Training Centre Site Economic sense to take a long term lease in Inverclyde area and lease out spare space at Aberdeen PLA to fund London MRCC Expand service to cover Inland Rescue HMCG given more responsibilities in regards to the e-boarders scheme

58 Panehip Working Ideas - Acceptance of proposal but need to ensure MOUarrangements are reviewed and robust Better liaison with stakeholders/SAR Partners to build and enhance local knowledge of watchkeepers Better use of National Coastwatch Institution (NCI)in future proposal Clear MOUs required with local organisations and responders Closer links to the Met Office forlonger range forecasts Co-location of Police Marine Unit at MilfordHaven Develop a technical solution to ensure lifeboats are fullymonitored from any data centre around the coast Greater links are required between the Scottish CivilResilience Manager and Northern Ireland Strategic Planning Begin dialogue with IrishCoastguard on international synergies and potential joint cost saving initiatives. Linkwith Scottish Fishermans federation for training watchkeepers in fishing industry matters MCAshould make more use of other indigenous emergency services for local knowledge purposes On-scene command function shared with other emergency services Replace some southern stations with Lifeguards on beaches Retain the offshore energy liaison team to ensure services to the oil industry are maintained Single 24 hour Point of Contact (POC) for renewable energies with specific responsibilities and knowledge There should be more recognition in the proposals for Port Authorities and their responsibilities under Port marine Safety code and improved liaison and an MOUto ensure holes are covered Use local knowledge of the inshore fishing fleet Joint working and sharing of facilities with other emergency services, especially Fire and Rescue Service (FRS). Each MRCC has responsibility for local liaison that was not covered by CRS

A,ternative watch system involving b s per and C...... iern I rou. a year as part of regular duty and training Any new technologies need to be fullytested in the future environment before the transformation begins to ensure it provide the solution required and fullysupports the new shape of CG Changes to other sites should only occur once MOC concept is operational Full networking of the organisation willprovide more resilience to cover peak loads and equipment outage. However the local fire services went down this route and the whole project has now been abandoned. So it is essential that the IT infrastructure is in place and validated before any other organisational change. Get one MOC operational with a number of day stations to prove that this willwork IfBelfast were to close or become daytime only mitigation strategy required to include example inter- service familiarisation, testing, harrnonised standards Implement Communications upgrade first. Radio fix must not have Watch Manager position as the control location. Alternative closure phasing plan Increase training during winter months so trainers can be released to the coast to assess training requirements in summer months MCAshould examine closely the fire control projects to avoid making the same errors Money could be saved by doing training on station rather than costs of T&E to Training Centre Future SAR training should include courses for those at the tactical and strategic levels of operational management. Replicate an incident or simultaneous incidents in real conditions on south coast without cover from RCCs Falmouth, Portland or Brixham to test the MOC/RSC concept. Adequately train on-scene commanders and ensure they were competent in handling emergency situations

59 ______

Trials and Training Ideas

oastguaro officers undergo blue light driver training to obtain K i A exemptions to mitigate Sound idea - but cautious approach to technology to allow to bed in Support for proposal but a fullfeasibility pilot is required System to be run as a pilot scheme and run in parallel with the existing structure The change must be managed over a longer period to reduce risk, given the experiences of South East Coast Ambulance Service mergers. Use existing stations to train CRTs and RNLI Train ops room staff to the grade above providing a bank of officers able to step in when the need arises Training staff (from MCATC) to visit stations to monitor and assess skills and standards. Develop e learning training packages for the coast MRCC to be established as a centre of excellence for TSS and VI 03 Qualifications. Incentivise CG for amount of qualifications held Training courses restricted to autumn and winter months Maintain a pool of Trainers (staff) to fillvacancies at each station Staff joining CG would start training at MOC before being assigned to home MRCC to complete training Training: regional training capability, SMC “Command Team” Training Embrace and involve operations room staff to design and help implementation of future Coastguard Establish 8 centres of excellence for each CG Technical Competency Staff should be trained for a position before they can apply for a position No officer to be allowed to apply for a Training Officervacancy without being a substantive WM or having at least 6 years operational service CG to be training as VTS operators Training facilities at North and South MOCs MOC should have orime trainina role. This is where trainers would start

StafflStaffing Ideas Decrease CEO pay to enhance staffing and increase basic pay Manage staff hours differently to allow all stations to remain open with 24hr coverage New posts must be graded against other emergency services and not against civilservice administrators. A move from MRCCs manned continuously by shift workers. Introduce more day workers and less shift workers. This would increase resilience, balance numbers on watch in line with incident statistics (days busier)and incur a cost saving due to less staff claiming shift allowance Reduce Falmouth shift pattern to 4 watches of 5 (saves 7 staff) but maintain 24/7) No need for an additional layer of Coastal Management and clearly indicates the opinion that the MCA should pay its existing staff a professional wage Retain current shift pattern. It allows good recovery period. Annualised Hours Retain Status Quo but Use Volunteers to man stations Retain watch shift system Review workload on a site by site basis and adjust staff levels accordingly SM, do not require more managers. They need a reduction in teams. This could be achieved by introducing SM assistants at less cost than proposed SMC experience should be part of shift heads roles and responsibilities Strategic personnel should not be watch keepers To review existing watch patterns and resourcing Flexible staff working levels, consider adjustment to forecast poor weather or increased traffic situations Within each team in MDC there should be a member to provide extensive knowledge of local place names 60 ______

StafflStaffing Ideas [ Must have flexibility during changeover Reduce manning at night with “on call’ officers in event of major incident

Introduce new posts - 1 per area, coastal support officers - to support SMs, senior watch manager to support RCCMs and WMs and provide resilient support for operational front line officers Review the MCA Management structure particularly in relation to HMCG to achieve a flattened out management structure Remove the CWA grade from MRCCs and associated personnel numbers Remove the SM role to be replaced with increased liaison and management of the CRS by MRCCS. Replace with a dedicated trainer at each MRCC Formation of an elite team of SMC qualified officers to lead a regional centralised resilience team for major incident working, covering staff shortages during periods of technical failure located in a hub in each region Annualised Hours 50% increase in base salaries A change of role title could lead to greater pay Senior Watch Manager at each MRCC Spread workload more and increase functionality to meet the Vessel Traffic Monitoring Directive More qualifications = more pay

All grades raised 1 pay band (RCCM to CWA) Additional staff available on call Keep current shift system. Would allow people to stay away when on shift and travel home after their 4 watches for 4 days 6 shift team system - six teams, 12 hour watches, for MOO, Shift Leader and 8 Staff in each team two teams to provide sick leave/cover, on call can be deployed flexibly Staffing level for RSO = 4 per watch staffing level for MOO = 9 per watch Abolish CSMs - SMs report to ROOMs Abolish OWA, WO and WM Grades. Have OGI and OG2 with pay indicators given Progression up pay scale is dependant on qualification “When staffing levels are unsustainable.., realistic retirement redundancy offers or relocation for staff to other stations or priority given for them to take on coastal safety officer roles in their chosen location

Allow surplus staff at remaining stations until natural wastage occurs Reduce Operational post from 596 to 489 Oonsider the introduction of additional qualifications to ensure staff retain qualifications and skills and remunerate accordingly eg in date SMO ticket etc Ourrent ROOM to be operations managers, their counterpart will be coastal rescue service manager (in charge of ORS but same grade as Operations Manager) SMs assisted by coastal support staff to provide career progression OSAR 0 - ORS (current OSM role) MSAR 0 - Ops Manager (current ROOM) MSAR S - Strategic Manager (Ohief OG on equivalent)

Oonduct an ice Style” risk /cost analysis which stations to close and which to retain. Decision on sub-centre locations should not be political but taken in consultation with Shipping Agencies and waterway users Locate additional stations to proposed lay down based on strategic location and particular area they guard

61 Selection Criteria Ideas

Locate centres in tour corners ot tne UK tornoway, Aberdeen, Dover and Falmouth, reason: concentration of shipping and marine industry as it passes close to the UK Locate stations in areas where there are significant marine developments Locate stations next to high level density commercial/leisure traffic Proposal a good idea -but the role of London CG could be undertaken by the Police as this work is replicated by the Police for majority of incidents. London being kept open is a politicaldecision? Reconsider location of Northern MOC. Better placed in Scotland’s Central belt. Reasons: Transport Infrastructure, co-location with other emergency authorities and more convenient access to other government departments Retain Centres based on incident numbers e.g. retain busy stations Retain stations with co-located facilities Select MOC/RSC sites based on co-location with other MCAresources. Select sites on correct size and least staff changes Selection should be based on sites with highest incident numbers Sub-Centres should be based on minimizing relocation costs so placed in areas with stable staffing Too many MRCCs - Thought should be given to location/risk and to flexible manning (including on call staff) for 24/7 cover Use existing estate in England and Wales rather than expensive new build Stations should reflect tonnage of ports, types of cargoes, locations: Aberdeen - oil industry/North Sea traffic; Southampton - English Channel traffic; MilfordHaven - oil, LNG industry & Irish sea traffic An accurate and detailed assessment of the level of activityat each MRCC is made - not just incidents Conduct a properly structured and managed review panel but with substantial staff input to identify change management issues and likelyturnover rates

Ac , ., t way to tackle the cost saving issue is to start by asking the people on the front line how they would make improvements and cost savings Appoint a single point of contact for independent lifeboat operators and other declared facilities As the UK ispart of Europe and an island surrounded by international shipping, (which benefits Europe as a whole) European Community should be making a substantial contribution to the upkeep of this essential service. Automated weather service available on line or on a VHF Channel Communications could be piggy backed onto Firelink airways scheme Concern that the proposal does not consider devolved government requirements - in addition the model of devolved Scottish Coastguard should be trialled before proposal complete Consider lessons learned following closure of Kirkwallcentre in 2000 Consult with devolved administrations before making final decision Create a well publicised national phone number for the Coastguard as in France (which is 1616). DF Needs to be reinstated Each area should have own VHF channel (like Eire) Each remote radio site should have a standalone VHF DSC with an aerial on the mast Efforts to improve search and rescue should be executed in parallel with an external review of the effectiveness and application of regulatory standards. ‘Prevention better than cure’. Ifwe don’t do what we say we do then should we exist in our current form at all ETVs need to be retained Every effort should be made to renegotiate the lease at Milford Mandatory basic maritime and boat training for leisure craft users. Have local press arrangements as opposed to having to go through Southampton Local Coastguard can police the local area. Coastguards need to be out on boats looking after the area Long term cost savings would be greater by using existing MCAowned buildings rather than leased properties 62 Other Ideas Modernise technology and value the opinions of front line co-ordination staff and customers when seeking to improve the service More key elements of local knowledge should be built into the system Use the simplicity of the ambulance E.R.C channel as a model for our radio network (relay stations - Simple but effective) Regions scrapped - Management re-structured Rescue Sub Centres should have direct communications with each other. The nomenclature of posts within the consultation document is confusing and should be reviewed viz a viz “Coastal Safety Prevention Work Maintain established relationships between partner agency commanders during incident response operations Transfer of SAR co-ordination from Liverpool to the 1DMfor incidents within 3 miles of the coast should be progressed and reviewed Turnover redundant stations to RNLIand NCI, Retain DF Webcams to assist coverage of coast. Respondent did not feel that remote on call safety officer would strengthen on land command and control and suggests that web cam technology may develop the concept of operations to an accountable level IT Support on each MRCC Locate servers at Data Centres or MRCC5 VTS Radar should be installed at MRCC Liverpool Maintenance (property) budgets should be delegated to the relevant RCCM for the MRCC and SM for the Sector base RCCMs to become district commanders with responsibility for MRCCS and fields Name MRCCS after geographical areas not its location would lead to a more nationalised service eg MRCC Scotland Modernise current legislation so that it is current and fitfor purpose look at current pyrotechnic legislation and update in the light of current technology reactivate day station in light of major incident Improve interface between waterborne/coast using public and the Coastguard Change the nomenclature of MRCCs to RCCs to reflect the widening inland remit Change title of HMCGto UKCGto better reflect its increasing role in the UK Streamline non operational management structure eg Chief Coastguard Reports direct to CEO Use Daedalus for Training Centre. Increase income

63 ANNEX M

Glossary of Terms

CG&R Corporate Governance & Risk CR0 Coastguard Rescue Officer CRS Coastguard Rescue Service CRT Coastguard Rescue Team CSM Coastal Safety Manager CWA Coastguard Watch Assistant DfT Department for Transport ETV Emergency Towing Vessel FOIA Freedom of Information Act HMCG Her Majesty’s Coastguard MCA Maritime & Coastguard Agency MIRG Maritime Incident Response Group MOC Maritime Operations Centre PCS Public and Commercial Services Union RCC Rescue Co-ordination Centre RCCM Rescue Co-ordination Centre Manager RNLI Royal National Lifeboat Institution RSC Rescue Sub Centre SAR Search and Rescue SAR-H Harmonised SAR Helicopter Force SM Sector Manager SOLAS Safety of Lifeat Sea Convention SRO Senior Responsible Officer TEP Time Expired Pyrotechnics VHF/DF Very High Frequency (Radio) Direction Finding VTM Vessel Traffic Monitoring WM Watch Manager WO Watch Officer

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