Public Consultation Response Template

Response form the Commissioners of Irish Lights

Introduction The Commissioners of Irish Lights is the General Lighthouse Authority throughout the island of Ireland, its adjacent seas and islands. It is the longest established maritime organisation in Ireland, delivering an essential safety service around these coasts, protecting the marine environment, and supporting the marine industry and coastal communities. Its mission, ‘Safe Navigation at Sea’, is to be a leading and innovative provider of reliable, efficient and cost effective navigation and maritime services for the safety of all. Irish Lights’ vision is to protect lives, property, trade and the environment by delivering next generation maritime services at the interface of navigation, technology, engineering and data management.

Irish Lights provide services across the five Focus Areas contained in our 2018-23 strategy “Safe Seas; Connected Coasts”:  Focus Area 1 - Provision of General Aids to Navigation around the island of Ireland  Focus Area 2 - Local Aids & Other Navigation Services  Focus Area 3 – Commercial Services  Focus Area 4 - Value Added Services to contribute to the Wider Maritime Economy  Focus Area 5 - Tourism, Heritage and Community Engagement

Implicit in Focus Area 1 – General aids to navigation is the recognition that maritime aids to navigation (including terrestrial physical, visual, electronic, and satellite aids) are critical national infrastructure to maintain the supply and export lines into and out of Ireland. Maritime transport is the most important means of connecting Ireland to international markets, accounting for more than 90% of Ireland’s international trade in volume terms. The end of the Brexit transition period and the imposition of customs arrangements for goods entering Ireland, has highlighted the real need to protect these lines of supply. Facilitating this commerce, along with fishing, leisure and coastal tourism activities, the 330 fixed and floating general aids to navigation provided by Irish Lights are a critical national safety infrastructure for the maritime sector.

Focus Area 2 includes the superintendence and management of over 60 Local Lighthouse Authorities (including Local Authorities, utility companies and operators of offshore structures including Oil & gas and offshore wind/wave) and inspection of over 3,300 local aids to navigation. The objective of this focus area is to ensure that these bodies meet the required standards set by the International Maritime Organisation (IMO) and the International Association of Marine Aids to Navigation and Lighthouse Authorities (IALA). Through this focus area, Irish Lights maintains an extensive network of local contacts with the shared goal of providing maritime safety. In addition, Irish Lights maintains a risk response capability to deal with wreck and new dangers to navigation within 24 hours in key areas including Cork, Rosslare, Dublin and Belfast/Larne.

Focus Area 4 encompasses value added services, both current and future, which Irish Lights can provide to the wider maritime community, including the State. This focus area includes the provision of support to the National Search & Rescue Plan 2019. Irish Lights contributes to regular National training exercises with the Naval Service, Irish , RNLI and other key responders.

Irish Lights also participates in international SAR preparation and training with the , MCA, HM Coastguard and Coastguard as part of the Irish Sea Working Group.

Focus Area 5 includes our tourism and heritage activities undertaken in conjunction with the Great Lighthouses of Ireland brand. Along with Focus Area 2, this also allows for extensive engagement with local communities and organisations around the coast.

Irish Lights – A niche capability Irish Lights fulfils the State’s obligation under SOLAS Chapter V Regulation 13 regarding the provision of maritime aids to navigation (AtoN) “as the volume of traffic justifies and the degree of risk requires”. In assessing these risks, Irish Lights draws on a myriad of internal/shared knowledge and best practice, gathered in collaboration with international bodies such as the IMO and IALA as required by SOLAS. These international recommendations and guidelines require Irish Lights to maintain the availability of AtoN at very high levels (between 99.8% and 97% depending on critically of the AtoN) which, in turn, necessitates an ability to respond to any outages, wrecks or new dangers with immediate effect.

These provisions and the specialist nature of AtoN maintenance provide the rationale for a dedicated buoy tender vessel, the ILV Granuaile, which allows Irish Lights to meet all of the State’s legal obligations under SOLAS while also providing a risk response capability for wreck and new dangers to navigation. In parallel with providing this critical national infrastructure, Irish Lights is permitted to raise commercial income from any reserve capacity held by the organisation in order to offset the costs of service provision. In practice, these funds are raised through a mixture of commercial rental agreements, fees for services provided and charter income from the ILV Granuaile.

In addition to the ILV Granuaile, the Irish Lights headquarters facility and buoy yard in Dun Laoghaire provides access to civil, mechanical and electrical support facilities, including design & build capability. Irish Lights is also further developing our data handling and management capability to allow for future use cases of our infrastructure for eNavigation, coastal flood forecasting and other services.

Irish Lights & the Defence Forces – A collaborative success story Irish Lights has a long history of collaboration and mutual support with the Defence Forces, most recently during the COVID pandemic. As part of Joint Task Force “FORTITUDE”, the Defence Forces provided contingency support to Irish Lights in the areas of remote monitoring AtoN and for helicopter access to our sites in the event that our dedicated contract air asset was unavailable. Thankfully, neither contingency was required but both were highly valued by Irish Lights.

Previously, Irish Lights has provided support to the Defence Forces in the UNCLOS Baselines mapping project conducted in 2015 by Ordnance Survey Ireland, where Irish Lights was able to provide logistic and helicopter refuelling support to the Air Corps in accessing key locations on the exposed West coast. This project underpins the Maritime Jurisdiction Bill 2019, which in turn is key to the Marine Planning & Development Bill 2020. Irish Lights will continue to play a key statutory role under this bill in managing the marine spatial planning requirements and planning consent arrangements of the State out to the 200nm Exclusive Economic Zone.

Irish Lights maintains two helicopter refuelling facilities on the West coast at Castletownbere, Co. Cork and Blacksod, Co. Mayo. Both are extensively used by Air Corps assets and SAR aviation assets, in addition to their primary use in support of Irish Lights aviation requirements for the maintenance of AtoN. Irish Lights expects that these key assets will retain their strategic significance for SAR and military aviation, in addition to our own maritime safety requirements for maintenance of Aids to Navigation. It is worth noting that the infrastructure at these sites is reaching end-of-life and

consideration of the future sizing and capacity of these sites is required. At present, they are sized to facilitate their national strategic role.

The Irish Lights vessel Granuaile is an 80 metre, 2,625T multi-purpose DP1 platform that has operated extensively with the Naval Service Diving section and more recently, with the Garda Síochána Water Unit. There are practical considerations that make Granuaile an ideal asset for this type of activity – a three point mooring capability, low freeboard, flat open deck for recompression chamber and accommodation for diving teams, plus the ability of the ship to berth at the Naval Base in Haulbowline in order to embark equipment using the ship’s crane. However, in addition to these practical considerations there is long history of civil-military operations between Irish Lights and the Naval Service Diving Section in particular. This is evidenced by exercises and operations such as the lifting of the F/V Pisces in 2003, recovery of the crew of the F/V Rising Sun in 2005, the F/V Pere Charles in 2007, the search for and recovery of the airframe and crew of Rescue 116 in 2017 and more recently recovery of the crew of the F/V Alize in 2020.

These examples and others cited below illustrate the shared purpose of both organisations to provide “For the Safety for All” and to “Strengthen the Nation”.

1. Capabilities – In this regard, you may wish to consider future integrated capability development and the planning and delivery requirements to support a joint force approach in terms of new equipment, professional military education and training, maintenance and development of infrastructure, developments in military doctrine, and transformative concepts, including specialist capabilities, that prepare and support the Defence Forces for future operations.

Future capability development and transformative concepts: Shared and specialist capabilities

 Strategy cohesion and transformative capabilities – Irish Lights & the Naval Service

“Ireland is highly dependent on external trade links and is reliant on the unimpeded movement of goods for our economic well-being…Ireland is highly reliant on sea transport routes, particularly via the United Kingdom, for the import and export of goods and for essential supplies. The high reliance on these transport links presents a potential vulnerability…”1.

“Globally, climate change will see increased competition for scarce resources and may have devastating consequences for many states on Europe’s periphery.”2

In the coming decades, the seas around Ireland are likely to change significantly in response to climate change. Available sea room on the East and South East coast will increasingly be occupied by fixed and floating wind infrastructure in order to fully develop and harness our offshore energy resource. Further West, wave energy could become economical as technology improves. These changes will be managed by the Marine Planning & Development Management (MPDM) Bill 2020, which is currently in the final stages of enactment. The spatial and policy context for the MPDM Bill is set by the National Marine Planning Framework which includes elements such as the Marine Planning Policy Statement, the Marine Spatial Plan, development management guidelines and a common spatial data platform which will provide up to date information and spatial representations of applications and granted consents. Irish Lights contributes to marine spatial planning and safety of navigation through involvement in the NMPF and MPDM, including approval and statutory consents for offshore structures and associated AtoN. Strong synergies and opportunities for collaboration therefore exist between Irish Lights and the Naval Service in the areas of navigation safety and protection of these maritime assets.

In parallel, over this period changes in international shipping patterns are also likely due to climate change, including alterations to the traditional shipping routes around Ireland by allowing an alternative route to/from the Asia-Pacific market via the Northeast Passage for the majority of the year. An ice-free Northeast passage could see an increase in maritime bulk traffic and LNG exports along this route, as Russia expands this capability in the coming decades, leading to increasing maritime traffic to the Northwest of Ireland through the Iceland – Faeroe Island gap, and also into the North Sea (Schach and Madlener, 2018)3. The interaction of this increasing traffic risk within Ireland’s Exclusive Economic Zone will require a collaborative planning and response capability from the seagoing agencies of the State.

1 White Paper on Defence update 2019, Security Environment Assessment, Globalisation, paragraph 2.2.10 2 White Paper on Defence update 2019, Security Environment Assessment, Climate Change, paragraph 2.2.8 3 Schach, M., Madlener, R., Impacts of an ice-free Northeast Passage on LNG markets and geopolitics, Energy Policy, Volume 122, 2018, Pages 438-448, ISSN 0301-4215,

Technology will also drive developments around automation and autonomy in shipping, resulting in ships with either less crew or no crew embarked. Irish Lights will continue to work closely with all relevant agencies and bodies to manage these changes, including the Defence Forces and in particular the Naval Service.

Climate change will place increasing emphasis on fuel use and pollution from the shipping sector. Both new ships and existing ships will be subject to IMO design and operation constraints on fuel use including a move away from marine gas oil to alternative greener power sources, economical steaming and reduction of fuel use to generate electricity for so-called hotel loads while in port. In the short to medium term, an opportunity exists to develop common standards for shared shore infrastructure, to facilitate shore power facilities or “cold ironing” to deliver alternative maritime power (AMP) for ships while in port in Ireland, reducing or eliminating the requirement to operate diesel engines while alongside. These initiatives could form part of any future National ports policy from a net- zero emissions perspective in order to plan future power capabilities of vessels and shared shore infrastructure (e.g. shore power, electrical charging, hydrogen etc.). As key components of the State’s seagoing capability, both Irish Lights and the Naval Service could lead by example and explore new capability in this regard.

 Energy security and security of offshore infrastructure

“Ireland’s energy security is therefore heavily reliant on a relatively small number of vital installations, both onshore and sub-sea. As Ireland continues to decarbonise its electricity system, offshore wind installations will be developed, initially in the shallower waters in the Irish Sea by mid-2020s with floating wind technologies deployed off the west coast later in the decade.”4 “The development of off-shore renewable energy technology will lead to an increased focus on maritime based energy systems in the coming years, and the future development of infrastructure will need to be monitored.”5

The September 2020 feasibility study on Establishment of a Research, Technology & Innovation Capability for the Irish Defence Organisation, coupled with continued access to EU funding for 3rd level research institutions could provide a mechanism for advancing shared R&D between Irish Lights and the Defence Forces. Currently, through our shared R&D section based in Harwich in the UK, Irish Lights is building experience of participation in applied research studies including involvement in the Offshore Wind Evidence and Change programme, administered by the Crown Estate in the UK. Projects under this programme will examine practical issues concerning offshore developments such as the cumulative effect of multiple developments on shipping patterns, the impact of offshore windfarms on navigation aids on board ships (radar, VHF, AIS) and the impact of different turbine alignment patterns on SAR capabilities.

 Maritime surveillance – use of maritime resources6 and shared common maritime operational picture

4 White Paper on Defence update 2019, Security Environment Assessment: Energy Security, paragraph 2.4.6 5 White Paper on Defence update 2019, Security Environment Assessment, Maritime Domain…and Security of Offshore Infrastructure, paragraph 2.4.7 6 White Paper on Defence: Project No. 9 (Appendix C) – Efficient use of all maritime state resources

“Recognising the ever changing maritime environment and technological developments…further areas of greater synergy will be explored with departments and agencies with responsibility in the maritime area during the implementation of the White Paper in order to ensure the best and most efficient use of all state resources.”7

“…a review, engaging all of the relevant national bodies, of current structures for monitoring, managing and analysing maritime data and information will be undertaken.”8

The prevalence of maritime surveillance data from compliant actors using systems such as Automatic Identification System (AIS), Vessel Monitoring Systems (VMS), Long Range Information & Tracking (LRIT) and others may give a false sense of security to policy makers regarding Ireland’s capability for maritime intelligence, surveillance, target acquisition, and reconnaissance (ISTAR). In reality, what these systems provide is a much-improved view of the compliant actors as part of the overall “haystack”, while the “needle” or non-compliant actor, requires active intervention to identify and intercept. These non-compliant actors can include smaller vessels, which are not required to transmit AIS, vessels that do not broadcast their position to avoid detection, vessels that have lost power etc. This leaves the Irish maritime domain exposed to risk of both bad actors and "black swan" events. The MV Alta, a derelict cargo ship that was abandoned off Bermuda in 2018, illustrates this vulnerability. The vessel went undetected for six weeks in the Irish EEZ before passing the Kinsale gas rigs and the entrance to Cork harbour and grounding on the coast of East Cork, close to Ballycotton in February 2020.

Ireland therefore has a requirement for a Common Operating Picture in line with the EU Maritime Security Strategy9. This requirement is considered in the Defence Forces context in the 2015 White Paper, but it extends beyond a military purpose to a multi-layered “Recognised Maritime Picture” including data from all of the relevant national bodies. This dynamic maritime data is different in scope and purpose, but also complimentary to the more static planning application and consent data contained in the common spatial data hub, envisaged under the NMPF.

One of the technology/data feeds into such a maritime picture could be the use of Irish Lights existing infrastructure as sites for long-range (HF) coastal radar solutions to fill these gaps in surface traffic analysis. The recent (03 Mar 2021) Marine Casualty Investigation Board (MCIB) report on the MV Alta incident noted in that case – ‘Ireland does not have such a network of shore-based radar installations scanning the open coastal seas. Therefore, the ship could not be detected by a shore based radar system operating from Ireland.’ The first recommendation of the report is that both the Ministers for Defence and Agriculture, Food and the Marine should form a working group to ‘make proposals for means to identify, monitor, track and interdict derelict ships before they endanger other ships and seafarers in the vicinity’. In our lighthouse infrastructure, Irish Lights operates a network of sixty-five effective high sites, which could be considered for this additional maritime safety use10. In addition to foreknowledge of derelict vessels through an enhanced maritime picture, such data could be used for monitoring/enforcement of forthcoming Marine Planning and Development Management Bill activity, Marine Protected Areas and overview of Strategic Maritime Activity Zones. It would also provide

7 White Paper on Defence: Maritime Co-operation and Co-ordination, section 3.5.6 8 White Paper on Defence: Intelligence, Surveillance and Reconnaissance, section 6.2.2 9 White Paper on Defence: EU Maritime Security Strategy and EUMSS Action Plan, section 3.4.4 10 White Paper on Defence: Project No. 29G – Use of Lighthouse Sites for Radar Surveillance

for more accurate navigation risk assessments (through the sharing of anonymised radar and VMS data with Irish Lights for traffic analysis) as well as maritime safety and pollution control surveillance.

Similarly, electro-optical/infra-red camera installations at selected key lighthouse sites, particularly near port approaches for example, would provide a much-enhanced picture of maritime activity in those areas.

 Collaboration – “contribute to Ireland’s economic wellbeing through engagement with industry, research and development and job initiatives, in support of government policy”11

The shared capabilities of the Naval Service and Irish Lights provide unique opportunities for transformative collaboration, particularly in relation to the integrated marine plan for Ireland “Harnessing Our Ocean Wealth”12. A strong and long-standing relationship has led to current collaboration on a number of topics, e.g. contributing to Ireland’s interest in the Global Navigation Satellite System (GNSS) including Galileo and the European Geostationary Navigation Overlay Service (EGNOS).

EGNOS is Europe's regional satellite-based augmentation system (SBAS) that is used to improve the performance of global navigation satellite systems such as GPS and Galileo. It has been deployed to provide safety of life navigation services to aviation, maritime and land-based users over most of Europe.

While the geographic coordinates of the Irish landmass have not moved since Brexit, Googling “EU without UK map” will display the increased physical separation that now exists between Ireland and our nearest European neighbours. In this peripheral position, Ireland must ensure continued access to shared EU services and protections, including ongoing improvement to our transportation infrastructure, through programmes such as Galileo and EGNOS.

Irish Lights is collaborating with the Naval Service in “ground truthing” of maritime-EGNOS coverage at the North western edge of our 200nm Exclusive Economic Zone. The output from this trial will inform future decisions on whether to extend the range of EGNOS to provide better coverage of this maritime area, possibly though additional ground segment infrastructure such as Ranging and Integrity Monitoring Stations (RIMS). The RIMS hosting sites are secured areas and tend to be established in airports and telecommunication space centres to satisfy security requirements. There are currently two RIMS sites in the UK located at Glasgow and Gatwick, but only one in Ireland located in Cork. The UK also houses a Central Processing Facility (CPF) and a Central Control Facility (CCF) as part of the EGNOS ground segment, neither of which are replicated in Ireland. However, since 31 Dec 2020, the UK no longer participates in the EU Galileo or EGNOS programmes. Although discussions with the European GNSS Agency (GSA) are ongoing, in parallel the UK is rapidly developing its own space programme, leaving a question mark over continued involvement with EGNOS. Irish Lights and the Defence Forces can contribute to Ireland’s future participation in and development of these shared European programmes, which are important to Ireland from a maritime safety and physical security perspective.

11 White Paper on Defence: Chapter 5, Roles of the PDF 12 White Paper on Defence: Protection of Marine Resources, section 3.5.5

In future, these enhancements to GNSS and EGNOS will take on an increasing importance due to the expected proliferation of Maritime Autonomous Surface Ships (MASS). Although larger, fully autonomous self-driving ships on international voyages are still in the offing, developments in autonomy in the <24m vessel range are already evident. Whether supporting an R&D ecosystem for MASS ashore, or dealing with the practical implications of MASS at sea with regard to Aids to Navigation and interaction with other users of the maritime space, these vessels will require careful consideration by the competent authorities including both the Naval Service and Irish Lights.

In a wider sense, Irish Lights would like to advance a greater understanding of the importance of GNSS to Ireland for critical national infrastructure and key economic sectors. The Defence Forces has a similar requirement for valid and uninterrupted GNSS in the context of military operations. Apart for providing position and navigation information, these signals are extensively used for precise timing across multiple sectors such as finance and IT. Research from the UK suggests that loss of GNSS would have a multi-billion Euro effect on a developed economy13. Signals from GNSS satellites are vulnerable to interference due to the very low power levels used. Historically, apart from some contested areas worldwide, cases of widespread GNSS jamming have been rare and often of short duration/range. Nonetheless, the future risk to general shipping and to future autonomous surface ships (MASS) in particular, while transiting key port approach areas is significant14. In order to counter this risk, examination of adequate backup and contingency arrangements for resilient position, navigation and timing services (Resilient PNT) in the event of a GNSS outage is required. Irish Lights is undertaking this work in conjunction with our shared R&D section, alongside our sister Lighthouse Authorities of Trinity House in the UK and the Northern Lighthouse Board in Scotland. The Defence Forces could greatly contribute to this effort by exploring the capability to detect this type of GNSS denial over a wide area, but particularly adjacent to Tier 1 and 2 ports. In other jurisdictions, the ability to jam these GNSS signals to deny their local use and to detect hostile cyber operations such as jamming and spoofing of GNSS and SBAS signals is a core military capability.

 Seagoing capability of the State

Irish Lights and the Naval Service provide collaborative but different contributions to the seagoing capability of the State. Irish Lights has statutory responsibility under the Merchant Shipping Acts (Ireland and the UK) for Marine Aids to Navigation (AtoN) and discharging Irish and UK government responsibilities under the Safety of Life at Sea Convention (SOLAS) 1974 in the waters around Ireland (north and south).

The ILV Granuaile, a dedicated buoy tender and AtoN support vessel fulfils the State requirements through an ability to respond immediately to AtoN outages, wreck response and new dangers to navigation. A 24/7/365 capability is maintained by utilising two crews and month on/month off duty periods. A further consideration is the displacement and hull form requirements to operate in relatively shallow coastal areas in order to maintain maritime AtoN.

Some or all of these characteristics may differ from a prospective military Multi Role Vessel (MRV), which may have a larger tonnage and hull form to support operations off the West

13 https://londoneconomics.co.uk/blog/publication/economic-impact-uk-disruption-gnss/ 14 https://www.gov.uk/government/publications/satellite-derived-time-and-position-blackett-review

coast in winter, may be crewed and run on a four weeks out/two weeks in patrol plan with a single crew and may have concurrent and overlapping tasks in the form of maritime security operations, fishery protection, drug interdiction, out of EEZ patrolling, and joint military operations both at home and overseas.

Nonetheless when not on deployment overseas, a Multi Role Vessel operated by the Naval Service, and operating in mutual support with an Irish Lights buoy tender, would greatly enhance the capability of the State in areas beyond traditional naval operations such as emergency towage response, pollution prevention/response, SAR and mass maritime casualty events. As an island nation, Ireland has particular requirements in each of these areas and an MRV operated by the Naval Service would have a transformative influence on the capability of the State to deal with each of these potential situations when not operating in a Joint role overseas.

 Naval Service – requirement for a National Maritime Information Centre

A further transformative capability would be meeting the requirement for a National Maritime Information Centre to co-ordinate the controlled sharing of sensitive data for the maritime domain, with person-to-person liaison with other organisations including Irish Lights. Historically a limiting factor of such collaborative arrangements has been a desire to connect actual IT systems across security domains. Through the establishment of a “virtual” Maritime Information Centre and by establishing the connection at peer-to-peer level, this difficulty can be avoided. The COVID pandemic has demonstrated the utility of such remote working arrangements. Irish Lights is a potential contributor to this maritime picture through our network of coastal infrastructure and our vessel. In addition, Irish Lights would benefit from access to maritime safety data to enhance risk assessments and improve knowledge of the marine space.

2. Structures – In this regard, you may wish to consider the most effective high-level Command and Control (C2) structures within the Defence Forces to ensure an agile and balanced approach that can function across all domains at home and overseas.

Additionally, you may wish to address appropriate future force structures for the Army (including its brigade structure), the Air Corps, and the Naval Service, individually as component services and collectively as part of an integrated joint force approach.

Furthermore, you may wish to address the changing nature of reservists, which presents an opportunity for the Reserve Defence Force to further integrate and support the Permanent Defence Force through the provision of enhanced collective and specialist capability across all domains.

 Support opportunities for siting of Inshore Patrol Vessel flotilla on the east coast15

In terms of Naval Service structure, the geographic position of Ireland’s only naval base in Cork Harbour, while ideally situated for access to the key South western approaches and shipping routes, is nonetheless separate from Ireland’s de-facto economic centre of gravity and major population centre on the East coast, contributing in part to recruitment and retention difficulties. The deployment of a Flotilla or Task Unit and associated support structures to the East coast to patrol this key resource post-Brexit could enhance engagement and support for the Naval Service, leading to improved outcomes in recruitment and retention. Regarding any future deployment or siting of an inshore patrol vessel flotilla to the east coast/Dun Laoghaire, Irish Lights would be interested in exploring the potential for shared services in terms of a logistics base suitable for light engineering requirements, storage and office services.

15 White Paper on Defence: Project No. 29F

3. Staffing – In this regard you may wish to consider the HR policies that support the requirement for an agile and adaptive modern military force. You may wish to consider issues such as recruitment and retention, organisational culture and values, gender and diversity, career progression, and industrial relations machinery.

 Agile and adaptive Naval Service – Exchange programme & inter-agency operability

In terms of enhancing Naval Service capability and promoting inter-agency maritime operability, a programme for short-term exchange of ship’s crew or technicians would enhance inter-agency operability and promote career and skill development. This approach was adopted when the Naval Service first introduced Dynamic Position (DP) enabled vessels with the L.E. Samuel Beckett class in 2010 when Irish Lights facilitated DP training for naval officers. Opportunities for crew exchange and shared training opportunities could be examined, including greater interaction with civilian SAR training via the National Maritime College of Ireland.

4. Any other comments you may wish to make in relation to the Defence Forces having regard to the Commission’s Terms of Reference

Nil