Public Consultation Response Template Response Form The
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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 Coast Guard, RNLI and other key responders. Irish Lights also participates in international SAR preparation and training with the Irish Coast Guard, MCA, HM Coastguard and Isle of Man 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